333.91616 Glfsr 1988 -m CLARK FORK BASIN PROJECT STATUS REPORT AND ACTION PLAN STATE DOCUMENTS COLLECTION ^ ^^ 2002 i m tfi& !k MONTANA STATE LlbSARY 1515 E. 6th AVE. HELENA, MONTANA 59620 4 4 i I i -FT^rrc'" CLARK FORK BASIN PROJECT STATUS REPORT AND ACTION PLAN Prepared by: Howard E. Johnson, Coordinator Carole L. Schmidt, Environmental Specialist Clark Fork Basin Project Office of the Governor Capitol Station Helena, Montana 5962 0 DECEMBER 1988 itatp of Moniana <§Uice at tt;r (Souernor Helena, Montana 59620 400-444-3 111 TED SCHWINDEN GOVERNOR December 1988 Dear Members of the 51^^ Legislature: In April 1984 I announced the initiation of a long-range comprehensive study of the Clark Fork Basin. A primary goal of the project has been to draw together fragmented information about the river and to develop a management plan for the future. I am pleased to transmit the Clark Fork Basin Project Status Report and Action Plan, which is the culmination of this effort. This document provides a review of the resources and special issues affecting the basin, a summary of efforts now underway to solve problems, and recommendations for future action. Many organizations and individuals have participated in this project and contributed new knowledge about the basin resources. Important investigations have been completed and others are continuing. But most importantly, we now have a far better understanding of the issues and the actions needed to solve the basin's problems. Through public meetings and written comments many individuals and organizations have offered comments on the report and suggestions for future actions. Their contributions are included as an integral part of the report. The efforts to maintain and improve the special resources of the Clark Fork Basin is a complex and long-term process. Some actions recommended in this report should be addressed immediately, but other issues will require continued and systematic efforts by citizens, legislators, and government agencies over the years to come. It is essential that these efforts are continued in a logical and coordinated manner. On behalf of all Montanans, I urge your careful consideration of this report. TED SCHWINDEN Governor ACKNOWLEDGMENTS The patience and skills of Verna Bedard and Ronni Burke, who typed the entire report (including all of the many revisions), are gratefully acknowledged. The efforts of Marnie Hagmann, who skillfully edited the report in a timely manner, and Mary Jo Murray, who assisted with the tables, are also appreciated. The basin maps were prepared by the Montana State Library, Clark Fork GIS Project. The Clark Fork Basin Project is grateful for the assistance of the ten technical work groups whose efforts have contributed greatly to producing this status report and action plan for the Clark Fork Basin. The following lists all work group members including those who may have served through only a portion of the process. John Arrigo Loren Bahls Don Bartschi Mike Beckwith Rod Berg Rich Brasch Tom Brooks Larry Brown Tim Byron Jim Carlson Ken Chrest Dept. of Health and Environmental Sciences, Helena Dept. of Health and Environmental Sciences, Helena United States Forest Service, Missoula Idaho Dept. of Health and Welfare, Coeur d'Alene Dept. of Fish, Wildlife and Parks, Missoula Dept. of Natural Resources and Conservation, Helena United States Geological Survey, Helena Dept. of Health and Environmental Sciences, Helena Dept. of Natural Resources and Conservation, Helena Missoula City-County Health Dept., Missoula Dept. of Health and Environmental Sciences, Helena Dan Corti Bob Davis Ted Dodge Ted Duaime Mike Falter Bob Fox Wayne Hadley Linda Hedstrom Larry Holman Ned Horner Joe Huston Gary Ingman Jon Jourdonnais Roger Knapton John Lambing Warren McFall Marvin Miller Johnnie Moore Joe Moreland Missoula City-County Health Dept., Missoula United States Geological Survey, Helena Headwaters Resource, Conservation and Development, Butte Montana Bureau of Mines and Geology, Butte University of Idaho, Moscow United States Environmental Protection Agency, Helena Dept. of Fish, Wildlife and Parks, Deer Lodge Missoula City-County Health Dept., Missoula Dept. of Natural Resources and Conservation, Helena Idaho Dept. of Fish and Game, Coeur d'Alene Dept. of Fish, Wildlife and Parks, Kalispell Dept. of Health and Environmental Sciences, Helena Montana Power Company, Butte United States Geological Survey, Helena United States Geological Survey, Helena United States Environmental Protection Agency, Boise Montana Bureau of Mines and Geology, Butte University of Montana, Missoula United States Geological Survey, Helena x _:,i-. nrvxfiM Rich Moy Greg Wunther Howard Peavy Larry Peterman Don Peters Glenn Phillips Frank Pickett Steve Potts Tom Ring Mike Rubich Ron Russell Bill Schultz Lee Shanklin Mark Shapley Laurence Siroky John Sonderegger Liter Spence Tim Swant Jack Thomas Dept. of Natural Resources and Conservation, Helena United States Forest Service, Missoula Montana State University, Bozeman Dept. of Fish, Wildlife and Parks, Helena Dept. of Fish, Wildlife and Parks, Missoula Dept. of Fish, Wildlife and Parks, Helena Montana Power Company, Butte United States Environmental Protection Agency, Helena Dept. of Natural Resources and Conservation, Helena Dept. of Health and Environmental Sciences, Helena United States Forest Service, Missoula Dept. of State Lands, Missoula United States Environmental Protection Agency, Helena Dept. of Natural Resources and Conservation, Helena Dept. of Natural Resources and Conservation, Helena Montana Bureau of Mines and Geology, Butte Dept. of Fish, Wildlife and Parks, Helena The Washington Water Power Company, Noxon Dept. of Natural Resources and Conservation, Helena '•{y---. I' iiuFi IE-' ir.u^-.; ^xP'^r-vfi Aioi5 aiJiftJ 'SiTio;:/ ;>t.- ,•. Jack Thomas John Tubbs Vicki Watson Larry Weeks Bill Woessner Roger Woodworth Dennis Workman Hugh Zackheim Dept. of Natural Resources and Conservation, Helena Dept. of Natural Resources and Conservation, Helena University of Montana, Missoula Stone Container Corporation, Missoula University of Montana, Missoula The Washington Water Power Company, Spokane Dept. of Fish, Wildlife and Parks, Missoula Environmental Quality Council, Helena add: fir- t^ .'H- cxcrri ToV, CONTENTS List of Figures vii List of Tables x List of Acronyms xv INTRODUCTION I-l PROJECT ORGANIZATION AND GOALS 1-2 REPORT CONTENT AND ORGANIZATION 1-3 CHAPTER 1 HISTORY AND DESCRIPTION OF THE CLARK FORK BASIN 1-1 INTRODUCTION 1-1 SURFACE WATER 1-1 GROUND WATER 1-3 MINING 1-4 FORESTRY 1-6 AGRICULTURE AND RANCHING 1-7 HYDROPOWER 1-9 WATER RIGHTS 1-10 RECREATION AND TOURISM 1-11 FISH AND WILDLIFE RESOURCES 1-13 IMPORTANT TRIBUTARIES 1-14 CHAPTER 2 CURRENT WATER USES, ACTIVITIES, AND AQUATIC RESOURCES 2-1 MINING 2-1 Montana Resources, Inc 2-1 Montana Mining Properties, Inc. and New Butte Mining, Inc 2-2 Other Mining Operations 2-3 FOREST PRODUCTS 2-4 OTHER INDUSTRIES 2-6 Stauffer Chemical Company 2-6 IRRIGATED AGRICULTURE 2-7 Introduction 2-7 Federal Water Projects 2-8 State-Owned Irrigation Projects 2-9 Benefits and Costs of Irrigation to Western Montana's Economy 2-9 ?-i r.i-i » jsi^ io iOHTll . .Sr ;QYH 1^ [■ c.iOvii; ij.ni ' 1 -£ aaiTivi""''D/ : asT' •- o-cr no-.. ilsn&fi HYDROPOWER 2-11 System Operation 2-11 Columbia River Treaty 2-12 Pacific Northwest Coordination Agreement 2-12 Northwest Power Pool 2-13 Headwater Payments 2-14 Benefits and Costs to Western Montana and the Northwest Region 2-14 MUNICIPAL WATER SUPPLIES 2-18 INDUSTRIAL/MUNICIPAL WASTEWATER DISPOSAL 2-19 WATER RESERVATIONS 2-20 Introduction 2-20 Upper Clark Fork Water Reservations Proceedings 2-21 RECREATION AND AESTHETICS 2-22 MACROINVERTEBRATES 2-24 Silver Bow Creek to Milltown Dam 2-2 4 Milltown Dam to the Confluence of the Flathead River 2-2 5 Confluence of the Flathead River to the Idaho Border 2-27 FISHERIES 2-27 Introduction 2-27 Upper Clark Fork Fishery (Headwaters to Milltown Dam) 2-28 Fish Species Composition 2-28 Trout Population Estimates. , 2-28 Trout Spawning and Rearing Habitat 2-29 Tributary Trout Spawning Migrations 2-30 Middle Clark Fork Fishery (Milltown Dam to Flathead River) .... 2-31 Fish Species Composition 2-31 Trout Population Estimates 2-31 Trout Spawning and Rearing Habitat 2-33 Tributary Trout Spawning Migrations 2-35 Lower Clark Fork Fishery (Flathead River to Lake Pend Oreille) . 2-35 Cabinet Gorge Reservoir 2-36 Noxon Rapids Reservoir 2-36 Fisherman Use and Benefits 2-38 ii -w ^TO'l-^AM CHAPTER 3 ENVIRONMENTAL ISSUES AND PROBLEMS 3-1 WATER RIGHTS 3-1 Introduction 3-1 Pre-197 3 Water Rights Claimed Through Statewide Adjudication . 3-2 Hydropower. . 3-3 Instream Flow Rights 3-4 Status of Statewide Adjudication 3-6 Provisional Permits Issued Since 1973. . . . 3-9 Ground Water Permitting Process 3-10 Indian and Non-Indian Federal Reserved Water Rights. . 3-12 US Forest Service 3-12 The Confederated Salish and Kootenai Tribes of the Flathead Reservation 3-14 INSTREAM FLOW RESERVATIONS 3-16 Introduction 3-16 Hydropower Rights 3-16 Fish, Wildlife, and Aquatic Resources. . . . 3-17 Water Quality Benefits 3-18 Water Supply 3-19 Recreation, Aesthetics, and Tourism 3-20 Riparian Areas 3-20 STATUS OF SUPERFUND INVESTIGATIONS 3-21 Introduction 3-21 Silver Bow Creek/Butte Addition 3-24 Montana Pole 3-27 Anaconda Smelter 3-28 Milltown Reservoir 3-30 METALS -CONTAMINATED LANDS 3-31 Introduction 3-31 Tailings Disposal Areas 3-32 Colorado Tailings 3-32 Old Works 3-3 3 Anaconda and Opportunity Ponds 3-3 4 Warm Springs Ponds 3-35 Lands Affected by Aerial Deposition 3-37 Irrigation-Affected Lands 3-40 Floodplain Mine Wastes 3-42 Sediment Transport Mechanisms 3-4 7 Reservoir Sediments 3-49 Reclamation of Contaminated Lands 3-50 Spangler Ranch Study 3-50 Streambank Tailings and Revegetation Study 3-52 ill Clark Fork Reclamation Demonstration Project 3-53 Anaconda Minerals Company Reclamation 3-55 SURFACE WATER QUALITY 3-56 Introduction 3-56 Historical Surface Water Quality Problems. . 3-56 Silver Bow Creek 3-57 Clark Fork 3-58 Recent and Current Surface Water Quality Monitoring Programs 3-60 Current Surface Water Quality 3-64 Heavy Metals 3-65 Suspended Sediment 3-74 Other Water Quality Parameters 3-78 EUTROPHICATION AND NUTRIENTS 3-84 Excessive Algal Growth 3-8 4 Nutrient Concentrations and Loading 3-86 Silver Bow Creek 3-86 Warm Springs Ponds 3-87 Upper Clark Fork 3-88 Middle Clark Fork 3-89 Lower Clark Fork 3-91 Aquatic Macrophyte Problems 3-91 Additional Monitoring Efforts 3-91 NONPOINT SOURCE POLLUTION 3-92 Introduction 3-92 Agriculture 3-93 Silviculture 3-93 Construction 3-95 Urban Runoff 3-95 Resource Extraction, Exploration, and Development 3-95 Land Disposal 3-95 Hydromodif ication 3-96 NPS Problems in the Clark Fork Basin .... 3-96 Upper Clark Fork Basin 3-96 Middle and Lower Clark Fork Basin . . . 3-96 Current NPS Programs 3-97 DHES-Water Quality Bureau 3-97 Silviculture Programs and Activities. . 3-98 Agriculture Programs 3-100 Resource Extraction Programs 3-101 IV 1>|; 'HTU2 .)V! -yfjuO GROUND WATER QUALITY 3-102 Introduction 3-102 Historical Ground Water Quality Studies. . . 3-102 Current Ground Water Quality 3-104 Upper Silver Bow Creek Area 3-105 Warm Springs and Opportunity Ponds. . . 3-108 Floodplain Mine Wastes 3-109 Warm Springs to Milltown Data 3-109 Milltown Area 3-110 Missoula Area 3-112 Lower Clark Fork Basin 3-113 FISHERIES, RECREATION, AND AESTHETICS 3-113 Effects of Surface Water Quality Degradation 3-113 Effects from Existing Hydropower Development 3-118 Effects from Irrigation Projects 3-121 Large Storage Projects 3-121 Other Irrigation Projects 3-125 Other Water Uses 3-127 CHAPTER 4 FUTURE WATER NEEDS AND ACTIVITIES 4-1 WATER RESERVATIONS 4-1 Introduction 4-1 Consumptive Water Needs 4-1 Instream Flow Reservation Needs in the Basin 4-2 Forest Service Instream Flow Needs 4-3 IRRIGATION 4-4 MINING 4-5 New Butte Mining, Inc 4-5 Pegasus Gold Corporation 4-6 Cable Mountain Mine, Inc 4-7 Sunshine Mining Company 4-8 Montana Mining and Timber Company 4-9 Mark V Mines, Inc 4-10 American Eagle Mining Company 4-10 ASARCO, Inc 4-11 U.S. Borax 4-12 FOREST PRODUCTS 4-13 WATER AVAILABLE FOR FUTURE DEVELOPMENT 4-14 Surface Water v. . . . 4-15 Hydropower Water Rights 4-15 Existing Water Rights 4-17 ^sf• Ground Water 4-17 Clark Fork Basin 4-19 Lower Flathead Basin 4-2 0 Water Exchanges 4-22 The Probability of New Federal Irrigation Projects 4-23 CHAPTER 5 ACTION PLAN 5-1 INTRODUCTION 5-1 COMPONENTS OF THE PLAN 5-1 Data Management 5-1 Public Involvement 5-2 Funding 5-2 Recommendations 5-3 RECOMMENDATIONS 5-4 Upper Clark Fork Reclamation 5-4 Butte Mine Flooding 5-4 Warm Springs Ponds 5-5 Floodplain Mine Wastes 5-6 Soils and Reclamation 5-8 Surface Water Quality 5-10 Nonpoint Source Pollution 5-11 Nutrients and Eutrophication 5-13 DO, Temperature, and Mixing Zones . . . 5-16 Monitoring 5-17 Ground Water 5-21 Fisheries 5-23 Recreation 5-27 Water Management Issues 5-28 Water Rights 5-28 Instream Flow 5-3 0 Land and Water Use Inventory 5-3 2 Natural Resource Damages Claim 5-3 3 Program Implementation and Continuity. . . . 5-34 REFERENCES CITED R-1 APPENDIX PUBLIC COMMENTS AND RESPONSES A-1 INTRODUCTION A-1 COMMENTS FROM PUBLIC MEETINGS A-1 Butte A-1 Missoula A-6 Plains A-17 WRITTEN COMMENTS A-24 VI LIST OF FIGURES 1-1 Clark Fork Drainage of Western Montana. . . . l-la 1-2 Subbasins of the Clark Fork 1-lb 1-3 Upper Clark Fork and Blackfoot Basins .... 1-lc 1-4 Middle Clark Fork, Lower Flathead, and Bitterroot Basins l-2a 1-5 Lower Clark Fork and Lake Pend Oreille Basins l-3a 2-1 Total Trout Per Mile in 31 River Segments of the Upper Clark Fork, Spring 1987 2-29a 3-1 Superfund Sites in the Clark Fork Basin 3-22a 3-2 Colorado Tailings Vicinity 3-32a 3-3 Old Works Area and Anaconda and Opportunity Ponds, Anaconda Smelter Superfund Site. . . . 3-3 3a 3-4 Warm Springs Ponds-Opportunity Ponds Vicinity 3-36a 3-5 Anaconda Smelter RI Soil Sampling Sites 3-37a 3-6 Silver Bow Creek RI Soil Sampling Sites 3-4 la 3-7 Ramsay Tailings Vicinity 3-42a 3-8 Upper Clark Fork Sediment, Soil, and Biota Sampling Areas 3-44a 3-9 Total Arsenic in Bank Sediment, Upper Clark Fork 3-46a 3-10 Total Copper in Bank Sediment, Upper Clark Fork 3 -4 6b Vll d-e ■Ai : V 3-11 Total Lead in Bank Sediment, Upper Clark Fork. . . « 3 -4 6c 3-12 Downriver Trends in Acetic Acid- Extractable Copper 3 -4 9b 3-13 Downriver Trends in Acetic Acid- Extractable Zinc. ... 3-49c 3-14 DHES-WQB Sampling Stations in the Clark Fork Basin. 3-61a 3-15 USGS Sampling Sites in the Upper Clark Fork Basin 3-62a 3-16 Total Recoverable Copper Concentrations in Silver Bow Creek 3-68a 3-17 Median Concentrations of Dissolved and Total Arsenic, March 1985 to September 1987 3-70a 3-18 Median Concentrations of Dissolved and Total Recoverable Copper, March 1985 to September 1987 3-70b 3-19 Median Concentrations of Dissolved and Total Recoverable Zinc, March 1985 to September 1987 3 -7 0c 3-20 Total Recoverable Copper Concentrations in the Clark Fork 3 -7 2 a 3-21 Annual Loads of Total Recoverable Copper in the Clark Fork 3 -72b 3-22 Annual Loads of Total Recoverable Zinc in the Clark Fork 3-72c 3-23 Total Suspended Sediment Concentrations in Silver Bow Creek 3-76a 3-24 Total Suspended Sediment Concentrations in the Clark Fork 3-77a 3-25 Annual Loads of Total Suspended Sediment in the Clark Fork 3 -77b Vlll 3-26 Annual Loads of Volatile Suspended Sediment in the Clark Fork 3-77c 3-27 Total Phosphorus Concentrations in Silver Bow Creek 3-86a 3-28 Total Phosphorus Concentrations in the Clark Fork 3 -88a 3-29 Annual Loads of Total Phosphorus in the Clark Fork 3-88b 3-30 Annual Loads of Total Inorganic Nitrogen in the Clark Fork 3-88c 3-31 USGS Ground Water Study — Well Sites in Upper Clark Fork where Water Chemistry was Sampled 3 -110a 4-1 Duration Hydrograph for Clark Fork below Noxon Rapids Dam (1951-1986) 4-16a IX ;>•: 3nPU IC LIST OF TABLES 1-1 Important Tributaries in the Clark Fork Basin l-14a 2-1 1980 Surface and Ground Water Use in Clark Fork Subbasins 2-la 2-2 Permitted Mining Operations in the Clark Fork Basin 2-3 2-3 Forest Land Ownership in the Clark Fork Basin 2-4 2-4 Acres Irrigated by Ground Water and Surface Water in Clark Fork Subbasins 2-7a 2-5 Irrigated Acreage Estimates and Percentages for the Eight Major Crops of the Clark Fork Basin 2-7a 2-6 Summary of Federal Irrigation Projects in the Basin 2-8a 2-7 Summary of State-Owned Irrigation Projects in the Basin 2-9a 2-8 Summary of Major Hydropower Facilities in the Basin 2-lla 2-9 Generating Capacity and Maximum Flow Capacity of the Five Major Hydropower Facilities 2-15 2-10 Value of One Acre-Foot of Water Used for Hydropower Production 2-17 2-11 Inventory of Municipal Water Supplies in the Clark Fork Basin 2-18a 2-12 Montana Wastewater Discharge Permits in the Clark Fork Basin 2-19a 2-13 Inventory of Wastewater Treatment Plants in the Clark Fork Basin 2-19b 2-14 Summary of Proposed Upper Clark Fork Basin Water Reservations 2-21a ori a-^ roj iD:;■e^ oA i-- V ■■ -tr *+ f^ ' 8-' 8-f .» -».flri —-..*. 5 : -<.• ■■:> V: ■.r?'mi:" .». r-<; 2-15 Distribution of Fish Species in the Clark Fork Basin Excluding the Flathead River System 2 -2 8a 2-16 Location, Length, and River Mile Index Boundaries of Fish Population Study Sections on the Clark Fork 2-32 2-17 Trout Population Estimates in Four Study Sections of the Clark Fork 2-32 2-18 Trout Population Estimates in the Johnsrud Section of the Blackfoot River, Approximately 13 miles Upstream from Bonner 2-33 2-19 Average Size and Relative Abundance of Young-of-the-Year Trout Sampled by Electrof ishing 2-34 2-20 Trout Fry Outmigration Rates Monitored in Five Tributaries of the Clark Fork during 1985 2-35a 2-21 Estimated Fishing Pressure on the Clark Fork and Selected Montana Rivers (1985-86) 2-39 2-22 Net Economic Value of the Clark Fork and Selected Montana Rivers 2-4 0 3-1 Number of Pre-1973 Water Rights Claimed for Major Water Uses in the Clark Fork Subbasins (June 24, 1985) 3-2a 3-2 The Quantity of Water Claimed for Major Water Uses in the Clark Fork Basin 3-2a 3-3 Temporary Preliminary Decree Issuance Dates, Clark Fork Subbasins 3-7 3-4 Provisional Water Use Permits Issued Since 1973 3-10 3-5 History and Status of Superfund Investigations in the Clark Fork Basin 3-22b XI 3-6 Concentrations of Arsenic, Copper, Lead, and Zinc in the Colorado Tailings 3-32b 3-7 Ranges of Metal Concentrations in Old Works Grab Samples 3-33 3-8 Total Metal Averages of Warm Springs Ponds 2 and 3 Bottom Sediments 3-3 6 3-9 Concentrations of Selected Contaminants in Anaconda RI/FS Transect Soil Samples 3-38a 3-10 Metal Hazard Levels for the Helena Valley near the East Helena CERCLA Site 3-39 3-11 Average Concentrations of Selected Metals in Floodplain Sediments 3-44 3-12 Concentrations of Trace Metal Associated with Fine-Grained Bed Material in the Clark Fork and Major Tributaries 3 -4 7a 3-13 Mean Concentration and 95 Percent Confidence Limits for Trace Elements in Surface Sediments from Clark Fork Reservoirs and Tributaries 3-49a 3-14 Maximum Concentrations of Copper and Zinc in Mainstem Clark Fork, 1970-72 3-59 3-15 Water Quality Criteria for Key Parameters 3-65a 3-16 Federal Drinking Water Standards for Public Water Supplies 3-65a 3-17 Analytical Techniques Used for Heavy Metals Water Quality Analysis 3 -66a 3-18 Summary of Characterized and Potential Sources of Contamination to Silver Bow Creek 3-67 3-19 Sources and Effects of Nonpoint Source Pollutants 3-92a Xll ■ na'-'O £I-t ei-e i-X-S t,' J. 3-20 Categories and Subcategories of Nonpoint Source Pollution 3-94 3-21 Nonpoint Source Pollution Problems in the Upper Clark Fork Basin 3 -9 6a 3-22 Nonpoint Source Pollution Problems in the Middle and Lower Clark Fork Basin 3-96J 3-23 Current NPS Programs in Montana 3-97a 3-24 Active MGWPCS Permits in Deer Lodge, Granite, Mineral, Missoula, Powell, and Silver Bow Counties as of 11-15-88 . . . 3-104 3-25 Licensed Solid Waste Sites in the Clark Fork Basin 3-104a 3-26 Summary of Potential Ground Water Contamination Sources Found During the SBC RI 3-106a 3-27 Chemical Analyses for Selected Parameters, Berkeley Pit and Kelley Shaft Samples 3-106b 3-28 Results of MPC Sampling of Monitoring Wells at Milltown Dam (Feb. -March 1987) 3-111 3-29 Summary of Bioassay Results in the Clark Fork Drainage 3-114a 3-30 Results of Instream Bioassays in the Clark Fork Drainage Using Fry and Finger ling Rainbow Trout 3 -115a 3-31 Inventory of Dams by County with 50 AF or more Capacity in the Clark Fork Basin 3-126 4-1 Estimated Arable Land in Subbasins of the Clark Fork 4-4 4-2 Timber Management in National Forests of the Clark Fork Basin 4-14 Xlll V;;- 4-3 Time Periods when Flows Exceed 50,000 cfs, Clark Fork below Noxon Rapids 4-16 4-4 Comparison of Streamflows with Claimed Rights and Estimated Actual Water Use for Irrigation 4-17a A-1 Travona Shaft Contaminant-Specific Water Quality Based ARARs A-4a XIV LIST OF ACRONYMS AF Acre- feet AMC Anaconda Minerals Company ARARS Applicable and Relevant or Appropriate Requirements ASCS Agricultural Stabilization and Conservation Service BIA Bureau of Indian Affairs ELM Bureau of Land Management BMPs Best Management Practices BOD5 Biochemical Oxygen Demand BOR Bureau of Reclamation BPA Bonneville Power Administration CDC Centers for Disease Control CDD Conservation Districts Division CDM Camp, Dresser and McKee CFR Clark Fork River cfs Cubic feet per second DFWP Montana Department of Fish, Wildlife and Parks DHES Montana Department of Health and Environmental Sciences DNRC Montana Department of Natural Resources and Conservation DO Dissolved Oxygen DSL Montana Department of State Lands EC Electrical Conductivity ECC Energy Content Curve EE/CA Engineering Evaluation/Cost Analysis EIS Environmental Impact Statement EPA U.S. Environmental Protection Agency EQC Environmental Quality Council ERA Expedited Response Action EWI Equal Width Increment FERC Federal Energy Regulatory Commission Flip Flathead Indian Irrigation Project FLCC Firm Load-Carrying Capability FS Feasibility Study XV •"\A ^5<;;.. CXi r *. GIS Geographic Information System gpd Gallons per day gpm Gallons per minute HJR House Joint Resolution HLA Harding Lawson Associates IPC Institute of Paper Chemistry kwh Kilowatt hour LOEL Lowest Observable Effect Level MAPA Montana Administrative Procedures Act MBMG Montana Bureau of Mines and Geology MCCHD Missoula City-County Health Department MDA Montana Department of Agriculture MEPA Montana Environmental Policy Act MGD Million Gallons Per Day mg/kg Milligrams per kilogram mg/1 Milligrams per liter MGWPCS Montana Ground Water Pollution Control System MMPI Montana Mining Properties, Inc. MMTC Montana Mining and Timber Company MOU Memorandum of Understanding MPC Montana Power Company MPDES Montana Pollutant Discharge Elimination System MRI Montana Resources, Inc. MSD Metro Storm Drain MSU Montana State University MW Megawatt NAE National Academy of Engineering NAS National Academy of Sciences NBMI New Butte Mining, Inc. NPDES National Pollutant Discharge Elimination System NPL National Priorities List NPS Nonpoint Source NRIS Natural Resource Information System NWPPC Northwest Power Planning Council O&M Operation and Maintenance XVI 'i'^.t' OSM Office of Surface Mining PCB Polychlorinated Biphenyl PCP Pentachlorophenol PER Preliminary Environmental Review ppb Parts per billion ppm Parts per million PRP Potentially Responsible Party PURPA Public Utilities Regulatory Policies Act PWA Public Works Administration RC&D Resource Conservation and Development RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study RIT Resource Indemnity Trust RM River Mile ROD Record of Decision SBC Silver Bow Creek SC Specific Conductance SCS Soil Conservation Service SHWB Solid and Hazardous Waste Bureau STARS Streambank Tailings and Revegetation Study SWCB State Water Conservation Board TSS Total Suspended Sediment ug/g Micrograms per gram ug/1 Micrograms per liter UM University of Montana USDA United States Department of Agriculture USES United States Forest Service USFWS United States Fish and Wildlife Service uses United States Geological Survey VSS Volatile Suspended Sediment WETS Western Fish Toxicology Station WPA Works Progress Administration WQB Water Quality Bureau WWP Washington Water Power Company WWTP Wastewater Treatment Plant XVI 1 a ^Wii f I ^i^- INTRODUCTION The Clark Fork of the Columbia River had been seriously polluted even before Montana achieved statehood. Historical accounts of the early mining camps indicate the upper Clark Fork and many of its tributaries were used as sewers for mining and smelting byproducts and domestic waste. Because of its poor condition, few efforts were made to protect the river. In the 1950s, new federal water pollution control legislation required wastewater treatment. Wastewater settling ponds were installed at the headwaters, reducing the river's pollution load, and the river began its slow recovery. Now, as Montana approaches its first centennial, the Clark Fork no longer runs red with mining wastes, and trout thrive at the headwaters, but its recovery is far from complete. New attention was focused on the basin in November 1983, when the Department of Health and Environmental Sciences (DHES) Water Quality Bureau (WQB) proposed to issue a modified wastewater discharge permit for the Champion International pulp mill located west of Missoula. In the controversy surrounding the WQB's decision, deficiencies in water quality and fisheries data were recognized. The data deficiencies magnified the need for a basin- wide study of the Clark Fork. Diverse sources, including environmental groups, private citizens, the Montana Environ- mental Quality Council, and members of industry, encouraged state government to conduct a comprehensive investigation of water quality in the Clark Fork drainage. These groups urged that a study be developed to identify major water quality- related issues and problems and to provide government and local leaders with a broad range of choices for making future resource management decisions. In April 1984, Governor Ted Schwinden announced the initiation of a long-range comprehensive study of the Clark Fork Basin. He said, "Montanans must make responsible decisions affecting the Clark Fork Basin in the future. We need a solid base of information upon which we can act, and it is imperative we pull together the fragmented studies now underway." The Governor encouraged all groups and indi- viduals with interests in the Clark Fork Basin to help fund and define the nature of the study. Funding for the Clark Fork Basin Project was initially provided with a grant of $200,000 from the Anaconda Minerals Company and later with funds from the state Resource Indemnity Trust Fund. Additional funds for the many individual investigations have come from a variety of public and private sources. I-l PROJECT ORGANIZATION AND GOALS The Clark Fork Basin Project is a special program in the Governor's Office in Helena. The project coordinator, assisted by an environmental specialist, has worked with an Interagency Task Force to develop the goals and scope of the project. The Task Force is composed of scientists from federal and state agencies, the Montana State University System, the State of Idaho, and Regions VIII and X of the Environmental Protection Agency (EPA) . A Citizens Advisory Council appointed by the Governor in 1984 has also provided assistance in identifying issues and priorities. The Clark Fork Basin Project has provided administrative continuity to existing or planned Clark Fork studies, has identified what additional information is most urgently needed to understand the water quality and fishery problems facing the basin, and — most importantly — has developed an action plan for the resolution of water-related resource problems within the Clark Fork Basin. Although there are four Superfund sites in the upper Clark Fork Basin, the focus of the project has been on non- Superfund activities, including many that are unrelated to hazardous wastes. However, Superfund and non-Superfund issues often overlap and must be considered jointly in water quality management and land reclamation. Important data and basic information collected by investigators throughout the basin are useful for Superfund purposes. Through coordina- tion with all agencies, the Clark Fork Basin Project has provided a link between Superfund and non-Superfund activ- ities and has provided technical assistance on some issues. Many of the interrelated issues are discussed in this report. As part of the federal-state coordination effort, the Clark Fork Data Management System has been adopted to manage the vast amount of technical data that has been collected in the basin. The system is implemented through a cooperative agreement between EPA and the DHES and managed by the DHES with coordination support provided by the Clark Fork Basin Project. A Geographic Information System (GIS) component is managed by the Montana Natural Resource Information System (NRIS) located in the Montana State Library. The data management system uses an IBM PS/2 Model 80 Personal Computer dedicated exclusively to the project. The facilities are located in the DHES office in Helena where a full-time operator is available to perform retrievals and analyses upon request of agencies and organizations associated directly with the Clark Fork Superfund sites. The system is also accessible through a PC LAN network serving 1-2 the DHES-Solid and Hazardous Waste Bureau. Telecommun- ications equipment effects rapid data transfer and remote access. It is intended that all data relevant to Clark Fork Superfund sites eventually be incorporated into the data base or referenced in the data base and maintained on site in hard copy. Data will be recorded in a standard format compatible with the system. Contractors working directly with EPA and DHES on Clark Fork Superfund Projects, and who elect to adopt the Environmental Information System or a compatible system for data management, may receive routine updates of the data. The goals of the Clark Fork Basin Project were iden- tified and listed in a project work plan prepared in June 1985 (Johnson and Knudson 1985) . The plan provided a general description of the basin's aquatic resources, a summary of environmental issues, and a description of information needs. The specific objectives of the project were to 1) conduct an analysis of the quality of the Clark Fork's aquatic re- sources, 2) determine feasible alternatives to maintain and enhance the Clark Fork's aquatic resources, and 3) develop an action plan to maintain and enhance the quality of the Clark Fork Basin's aquatic resources. REPORT CONTENT AND ORGANIZATION This report describes the present status of the Clark Fork Basin and outlines actions needed to restore and maintain water resources for future needs. The report has been developed by the Clark Fork Basin Project with the assistance of ten work groups and an interagency task force. Chapter 1 provides a brief history of the basin's development, including events and activities that led to existing environmental conditions. Chapter 2 describes current water uses in the basin, including some indication of how these uses cost and benefit Montana. Chapter 3 addresses the many environmental issues affecting the basin's water resources. Historical actions have seriously affected the Clark Fork headwaters. Emphasis is given to recent investigations and monitoring efforts designed to identify specific problems and solutions. 1-3 Chapter 4 focuses on future water uses in the basin. Special emphasis is given to water rights, water reserva- tions, and water availability questions. The chapter recognizes the conflict between water quantity and water quality and the ultimate conflicts that must be resolved. Chapter 5 provides a distillation of the specific issues and proposes alternative actions to address these issues. The specific strategies and actions are intended to guide future management efforts. The Appendix is a summary of comments received at the three public meetings held in the basin plus the written comments received during the comment period. Responses are provided where appropriate. 1-4 CHAPTER 1 HISTORY AND DESCRIPTION OF THE CLARK FORK BASIN This chapter describes the Clark Fork Basin and provides a chronology of the major activities and events that have led to current environmental conditions in the drainage. INTRODUCTION The Clark Fork originates at the confluence of Silver Bow and Warm Springs creeks in the Deer Lodge Valley of west central Montana (Figure 1-1). The river drains over 22,000 square miles, including nearly all of Montana west of the Continental Divide and a small part of northern Idaho. The Clark Fork flows north and west from its headwaters for about 340 river miles through a variety of terrain, including broad, semi-arid valleys, high mountain ranges, and steep- sided valleys. It terminates at Lake Pend Oreille in northern Idaho, approximately seven miles west of the Montana-Idaho border. The drainage can be divided into 13 subbasins (Figure 1-2) . With the exception of water quantity issues, the six subbasins forming the Flathead Basin above Kerr Dam are not covered in this report because Flathead Lake and its drainage basin form a distinct aquatic ecosystem. This area has been studied extensively, and the Flathead Basin Commission was established in 1983 to coordinate water quality management programs in that basin. SURFACE WATER The Clark Fork is often described in terms of upper, middle, and lower river segments because the character of the river and the nature of the problems differ substantially from one area to another. The upper river segment extends about 125 river miles from the headwaters to below Milltown Dam (Figure 1-3) . Major tributaries that feed the river in this segment include Silver Bow Creek, Warm Springs Creek, the Little Blackfoot River, Gold Creek, Flint Creek, Rock Creek, and the Blackfoot River. Below the Milltown Reser- voir, the average annual discharge of the Clark Fork is approximately 3,000 cubic feet per second (cfs) . Streamflows in this segment are determined by weather conditions, geology, and irrigation. 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HI S C ITJ lU (0 (1) o I c 10 8 —I » 10 0> .r-t i 3 "8 I. — 1 X l-lAo CHAPTER 2 CURRENT WATER USES, ACTIVITIES, AND AQUATIC RESOURCES The Clark Fork flows through diverse terrain that supports a variety of land uses. Many of these land uses depend heavily on the river system, utilizing surface and ground water for consumptive and nonconsumptive uses. This chapter provides a description of current land and water uses along the mainstem Clark Fork and its major tributaries. The relative benefits and costs of some activities are discussed, although there are limitations on quantifying these benefits and costs. The amount of water in acre-feet (AF) used for different purposes varies considerably among the seven Clark Fork subbasins covered in this report, as illustrated in Table 2-1. This chapter also describes the aquatic resources in the basin, including macroinvertebrates and fisheries. MINING From the late 1800s until the early 1980s, mining and metal processing industries were the mainstay of the economy in the upper Clark Fork Basin. The largest employer, the Anaconda Minerals Company, shut down its smelter operations in Anaconda in 1980 and its mining operations in Butte in 1983. The closure of these facilities marked the end of an era, but the recent rise in prices of copper and precious metals has spurred renewed interest in mining throughout the basin. Several companies are now in the exploratory phase, and others have submitted conceptual plans or permit applications to regulatory agencies (see Chapter 4) . A few companies are currently operating in the basin, the largest of which is Montana Resources, Inc., in Butte. Montana Resources. Inc. MRI purchased most of the Anaconda Minerals Company's Butte holdings in December 1985 and assumed its permits and liabilities for the permitted mine area. MRI began open pit mining of copper and molybdenum in June 1986. It currently employs about 320 people in Butte, and the expected life of the mine is 13.5 years. In the course of the operation, approximately 200 million tons of ore will be processed and 80 million tons of low-grade waste rock will be removed from the top of the ore body and placed on permitted waste rock dumps . 2-1 £ o CO ^ 8 o I CM l-l s. 12 u o o u u 4) jj -* r^ (^ m « x> m v< o « m m <»> 1/1 9' w o 1-( 00 lO oo r^ r- vO i-H f^ A *• •4 M •o PM -i fH r^ — < f-H CO •H 2: !3 § 00 CI ^ '" o o u R) ■H o b, ^ o < b. Ck: — o ;< b. a >i Eh u l4 O^ <^ CO -4 m f^ irt irt rH 0> 00 0> •O ^ «n 00 in r» in s « CO in O 00 in O- tH ?^ 1^ 00 ^ r^ in >o CO OS 4 o ^ tO 3 CO 00 CM O W » g 1 ts u »4 ^ •H ■H » :» t3 0) 4) U i 4J •I-* o (4^ 0) •rH •o U 2 s. 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The agricultural sector, in turn, accounts for approximately 1 percent of total income in the region and employs about 5 percent of the work force. In some counties, however, agriculture accounts for as much as 9 percent of county income and 19 percent of employment. Irrigation not only increases average production but also stabilizes production during drought periods. Thus, irrigation has had a stabilizing effect on the livestock industry and agriculture in western Montana. The value of irrigation to each operation depends on many site-specific factors and is estimated to range between $5 and $60 per acre-foot (Frank et al. 1984). Based on the low-end estimate of 230,000 irrigated acres and a crop requirement of two AF of water per acre (MDA 1987) , the total value of irrigation to western Montana lies between $2 million and $28 million per year. The cost of irrigation to western Montana cannot easily be quantified. The direct costs associated with irrigation and crop production are not necessarily costs to Montana or the Pacific Northwest. Most of the needed labor, equipment, and material can be purchased in western Montana or in the Pacific Northwest. Therefore, while irrigation is a cost to the individual farmer, workers, retailers, and manufacturers in the Pacific Northwest benefit from this business. Irrigation depletions affect other beneficial uses such as fish and wildlife habitat, water quality, and recreational opportunities. Each new depletion can also further reduce hydroelectric generating capabilities. These impacts represent the primary costs of irrigation to the region. Approximately 1.5 to 2.0 AF per year are consumed for every acre irrigated (MDA 1987) . In most of western Montana, depletions should tend to be on the lower end of this range given high elevations and relatively high rainfall, which reduce net irrigation requirements. However, in some areas, such as the Flint Creek and Rock Creek drainages, the soils are quite porous and require more water to derive an irrigation benefit. Based on a range of 230,000 to 400,000 acres of irrigated cropland in seven of the Clark Fork sub- basins, total consumption is estimated to range from 345,000 to 800,000 AF per year. The cumulative impacts of water quality degradation in the Clark Fork Basin associated with irrigation are not quantified and will be difficult to quantify in the future. However, general water quality impacts are known to include increased sedimentation from streambanks and overland runoff, decreased channel stability and headcutting, increased water temperature related to decreased streamflows, increased nutrient levels that occur as a result of a combination of 2-10 both irrigation and fertilization of cropland, increased salinity, and a potential for decreased dissolved oxygen levels associated with an increase in algae growth. The tradeoff between instream uses, such as power generation, and irrigation uses has become an important issue, as power demand occasionally exceeds hydropower system capacity even though system capacity has increased. The lands currently under irrigation will probably be maintained, given the large capital investment associated with irrigation development. However, in addition to any other development costs, future irrigation developments may only be justified if the net benefits exceed the lost value of power generation and other interests associated with depletions. For the Columbia River Basin, this would mean that the net benefits of irrigation are greater than $4 0 per acre-foot consumed (see next section) . HYDROPOWER As a headwater state, Montana is an important con- tributor to the regional hydropower system of the Columbia River Basin. The average quantity of water flowing from Montana at the Montana-Idaho state line is about 26 million AF per year, of which about 16 million AF per year flow in the Clark Fork. The Montana water contribution (total flow minus 8.3 million AF entering from Canada) is about 57 percent of the upper Columbia River flow and 11 percent of the average annual streamflow at the mouth of the Columbia River (Wright Water Engineers and DNRC 1982) . There are four hydropower dams on the Clark Fork mainstem and three hydropower facilities located on major tributaries in Montana. The mainstem dams contain very little storage capacity and have little influence on seasonal discharge patterns. Two major storage projects on the Flathead River system, Kerr and Hungry Horse dams, do have potential to alter seasonal flows in the Clark Fork. A description of the basin's major hydropower facilities and their operations is pfoyided in Table 2-8. System Operation The organizational structure of the Columbia River hydroelectric power system has evolved over a period of 40 years. 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O ■<* -tJ rH a § ^ •S ro a: Dl <4H O -H s u "c i»-i r-l 4-> £ H W I n u E nj to M o _2 ti. -3 :z 0) [Ju M f—t o rH Bl (0 5 XI o W^ o M l4^4 «-l i-H +-' 10 X +J fH O ." 1 IM 1— 1 -H g g s 10 g o O tj •r-t ClL, 'x n 'x o S 8" s s 0) t— t 1 •rH o 5 M M O ^ o 3 2 Ul LO s in S Ol Q. h -♦-> CJ S 6 t*-t 'H E m -(-> •H .!-> •H u !^ I 2, to IH t< u ■* o >^ LTJ D< tb EJh (0 •< M kC O •p 3 s -tJ J= cn ty- w o • H 0) 0) r-1 00 > ON 3= 5 ^ • rH ^ O V u V E-i m p< CN O •C c IV 0) > +J H-l to •H •H .12 O O M a a •H s s s H-» to ^ to ^ •rH o. hJ 1 to to u i ts 0) B ° i 0) r-( Ol iS g i ^ o -M LO OO 00 cs ^ (0 fS rO > T3 to 0) -s *-> to i3 § 0) hJ x: c t: £ s > •g •« in ON -s 1X3 i! oi: ♦J to IH x: o s n i 2-lle Columbia River Treaty The "Treaty between Canada and the United States Relating to Cooperative Development of the Water Resources of the Columbia River Basin," was signed in 1964, and it will end in 2003. This agreement, a keystone in the development of the vast hydropower system of the Pacific Northwest, provides for both flood control and power benefits. Some key provisions of the treaty that affect water management in the Columbia River Basin are summarized below: • Canada is required to develop 15.5 million AF of storage in British Columbia available for power in the U.S. and for downstream flood control. 9 Construction of Libby Dam on the Kootenai River in the U.S. was approved and some inundation upstream in Canada was allowed. • The U.S. is required to operate downstream projects on the Columbia River in such a manner to make effective use of the added streamflow resulting from Canadian storage. • The two nations are required to divide the resultant downstream power benefits equally. Canada's share of the downstream benefits for the first 30 years were sold by Canada to a group of Pacific Northwest utilities. • The U.S. is required to pay Canada for the flood control provided by Canadian storage. The payment reflects the flood damage prevented in the U.S. and compensates Canada for the economic loss arising from foregoing alternative uses of storage used to provide for flood control. Pacific Northwest Coordination Agreement The Pacific Northwest Coordination Agreement is a contract for planned operation among the 16 major operating utilities. The agreement became effective in 1964, and it is scheduled to end in 2003. The agreement provides operational guarantees that insure usability of the Columbia River Treaty storage to -downstream generating plants and specifies the restoration Oi. pretreaty capabilities to certain plants under certain conditions. A fundamental concept of the coordination agreement is "Firm Load-Carrying Capability," commonly abbreviated as FLCC. For the coordinated system of all 16 parties, the FLCC 2-12 is the aggregate firm load that the system could carry under coordinated operation with critical period streamflow conditions and with the use of all reservoir storage. To accomplish such coordinated operations, the combined power facilities of the parties are operated to produce optimum firm load-carrying capability. Prior to the start of a contract year, a reservoir operating and storage schedule is set up to provide the optimum FLCC of the coordinated system. An energy content curve (ECC) is derived for each storage reservoir from the same critical period operation study that was used to derive FLCC. This curve represents the schedule of levels that the reservoir should follow to assure FLCC for the system. If, as may frequently happen, the good of the system requires a utility to cut back on releases and to hold storage for later use, thereby reducing its present generation below its FLCC and perhaps below its load requirements, it has the right to call for and receive interchange energy from a party with excess capability. Later, when the first party's storage is scheduled for release, it will be able to return the energy. Provision is made to pay for any imbalances in such interchange energy exchange accounts that may remain at the end of a contract year. The Coordination Agreement provides that, upon request, a project is entitled to the energy that it could generate at its plants if upstream reservoirs released all water above their energy content curves. The upstream party can either release the water, or, if it has surplus energy and wishes to conserve its storage for later use, it may deliver energy in lieu of the water. An intent of coordinating the system is to maximize use of the water resource, minimize waste, and consequently defer the need for new generating resources. Northwest Power Pool The Northwest Power Pool is another institutional arrangement governing the operation of the regional power system. The Northwest Power Pool was created in 1942 as a result of the War Production Board order directing utilities throughout the U.S. to cooperate to increase electric capacity. After the war, the utilities continued the coordinated operation on a voluntary basis. The Northwest Power Pool is a strictly voluntary organization, a confederacy of autonomous electrical systems. It is not a formal operating pool managed by a separate group of officers. The operating organization of the pool consists of an operating committee and a coordinating group. 2-13 Major functions of the Northwest Power Pool are: to coordinate power generation to insure that each member can meet its requirements; to schedule maintenance outages to the extent possible so that the region's needs can be met at all times; to control the whole system and ensure that proper voltages and frequency are maintained; to coordinate communi- cation among members; to represent the Northwest as a group on the national level; and to collect data for future planning on a regional basis. It is important to both the region and the members of the pool that these functions be carried out to insure an efficient and smooth operating system. Headwater Payments A third component of the operational organization is the provision for headwater payments. Downstream dams are required to make payments to owners of upstream storage facilities based on the benefits received from the release of upstream storage. For each reservoir, a computation is made to determine the cost of storage, which includes the capital costs of the dam, operation and maintenance costs, taxes, interest, depreciation, insurance, interim replacements, and joint use costs. The cost of storage does not include any costs associated with power production at site. The computed cost may be bound by a predetermined cost limit adjusted each year for every reservoir. The headwater payments are determined by the smaller of the computed storage costs or the cost limit. The portion of the costs payable by a downstream dam depend on the portion of the benefits received. An assess- ment is made to determine the total energy available from the storage at the upstream reservoir. This calculation includes the power generation produced at site and the generation produced at all the downstream dams. Each downstream dam's portion of the cost is the ratio of its benefits to the total benefits multiplied by the storage cost (or the cost limit) . Benefits and Costs to Western Montana and the Northwest Region "For more than a half century, electrical power has been the cornerstone of the Pacific Northwest economy" (Northwest Power Planning Council [NWPPC] 1986) . The extensive hydropower system of the Columbia River Basin — the largest in the nation — supplies about 70 percent of the electricity in the Northwest. 2-14 Hydroelectric development in the Clark Fork Basin provides a significant part of the electrical energy generated by the WWP, MPC, and the BOR. The five major hydropower facilities in the Clark Fork Basin have a total maximum generating capacity of approximately 1,332 megawatts (MW) (Table 2-9) . On average, however, these five plants generate approximately 600 MW of power. In comparison, hydropower facilities in the Northwest have the capacity to generate approximately 20,000 MW, and on average generate 16,400 MW (NWPPC 1986). Thus, these five facilities account for approximately 4 percent of the average hydropower generation in the region. In addition to power generation. Hungry Horse Reservoir provides substantial headwater benefits associated with its large storage capacity, 3,468,000 AF, and its location in the basin. This storage is released to augment streamflows that are then used to generate power by the downstream facilities. The facility owners listed in Table 2-9, as members of the Pacific Northwest Coordination Agreement, operate their hydropower facilities in concert with others in the Northwest to maximize the utilization of water discharges for optimum energy production and minimum wastage, thereby deferring the need for new energy resources. TABLE 2-9. GENERATING CAPACITY AND MAXIMUM FLOW CAPACITY OF THE FIVE MAJOR HYDROPOWER FACILITIES Generating Capacity Maximum Flow Facility Owner Max Avg Capacity fMW) fMW) rcfs) Hungry Horse BOR 328 107 55,000 Kerr MPC 180 128 14,540 Thompson Falls MPC 40 34 11,120 Noxon Rapids WWP 554 199 50,000 Cabinet Gorge WWP 230 130 36,000 Source: NWPPC 1986. Hydropower plants provide benefits to the local area through employment and dollars spent in the operation and maintenance of the facilities. In addition, the nonfederal facility owners pay generation-based taxes on the production output of the plants and property taxes, which contribute significantly to the local tax base. In addition to revenues gained from hydropower production, damming of the Northwest's rivers provides additional benefits associated with irriga- tion, navigation, flood control, and diverse recreation. 2-15 The power production from hydropower plants is used Vf the utility owners to meet the requirements of their customers. Undeniably, the people of the region have come to expect the availability of electrical energy when they require it. The dependability of hydropower generation contributes greatly to the reliability of the region's power supply. Hydropower plants such as Noxon Rapids and Kerr Dam are also important for load control, which is necessary to insure that the generating system responds to instantaneous changes in the customer's demand for electrical power. The Northwest currently is capable of generating more power, on average, than there is demand. This surplus may not continue into the next century, however. In the 1986 Northwest Conservation and Electric Power Plan, the Northwest Power Planning Council estimated that between 1990 and 1996, the demand for power will exceed the region's generating capacity, on average, and new generation capacity will be required. Residential uses of power in the Northwest account for approximately 36 percent of current regional power demand. Industrial uses account for 39 percent of regional power demand. Commercial uses demand 20 percent, and irrigation power requirements account for most of the remaining 4 percent (NWPPC 1986) . In western Montana, industrial demand for power accounts for 64 percent, residential 21 percent, commercial 13 percent, and irrigation 2 percent (Bonneville Power Administration [BPA] 1985) . Water for power production has contributed greatly to the economic well-being of the region, as cheap hydroelectri- city has been a significant factor in encouraging industry to locate in the Northwest. Low energy costs help businesses that provide much needed jobs to local areas, which in turn allow the people who work and live here to enjoy the many other qualities of the region. The existing hydroelectric base contributes greatly to the comparatively low electrical prices that exist in the Northwest. The capital cost to replace the hydropower facilities of today with new thermal plants could be eight to ten times more than the original construction cost. Because the "fuel" for hydropower generation is water, and the cost has not been subject to price fluctuations, the region has enjoyed a large measure of rate stability. This situation should continue in the future to the extent that these hydropower developments are maintained. The economic value of Clark Fork water used for power production is difficult to measure because many factors are involved. One way to measure the value of hydropower is to estimate the cost of replacing hydropower generation with 2-16 the next best alternative. Based on work conducted by the Northwest Power Planning Council, the current replacement cost (excluding construction) for hydropower is approximately 2.5 to 3.5 cents per kilowatt hour (NWPPC 1986). Replacement power provided by new thermal power plants may be three to four times higher than these rates, however. Using site- specific power factors that relate power generation to flow and converting this flow to a volume of water, the value of an acre-foot of water passing through the hydropower facilities in Montana and the Columbia River Basin can be estimated. Table 2-10 shows that every acre-foot of water consumed in Montana will cost the region approximately $50, excluding hydropower facilities in Montana. For the Montana hydropower facilities, the location of the depletion is important. For example, if the depletion occurs in the Flathead drainage below Hungry Horse Dam, the lost value of an acre-foot depleted would be approximately $11/AF, or $61/AF for the entire region. TABLE 2-10. VALUE OF ONE ACRE-FOOT OF WATER USED FOR HYDROPOWER PRODUCTION Incremental Value Cumulative Value for for Regional Location Montana Facilities Montana Facilities Value ($0.025/kwh to ($0.025/kwh to ($0.025/kwh to $0.035/kwh) $0.035/kwh) $0.035/kwh) Hungry Horse $7 $9 $15 $21 $50 $70 Kerr Dam 4 5 8 11 43 61 Thompson Falls 1 1 4 6 40 56 Noxon Rapids 3 5 3 5 39 55 MT-ID Border .. .- 36 50 (Based on at site and HKSUM factors from BPA) Source: John Tubbs, DNRC, Helena, April 1988, personal communication. The BOR recently completed a planning study analyzing the effects of future irrigation development in the Clark Fork Basin and the potential for Hungry Horse Reservoir to mitigate these impacts (BOR 1988) . Analyzing the effect of 120,000 new acres of sprinkler irrigation development, the study found that depletions would result in a loss of 261 million kilowatt hours (kwh) per year. This translates into a financial loss of approximately $6.5 million per year, assuming the current rate of 2.49 cents per kwh. The estimates shown in Table 2-10 above compare favorably with 2-17 the BOR's more detailed estimates. Using the same assump- tions about the location of developments, depletions, and electric rates, there was only a 20 percent difference in the calculation of losses ($7.84 vs. $6.5 million). The potential for storage at Hungry Horse to mitigate these losses was found to be limited. The BOR study found that, while total generation within Montana could be restored, there was great disparity in gains and losses at each of the hydropower plants. There were substantial generation gains at Kerr Dam (MFC) resulting from releases from Hungry Horse, but the effect at Noxon Rapids (WWP) could not be mitigated. This is because Noxon Rapids has the capacity to use almost the entire annual flow of the Clark Fork. Using storage to reshape the timing of these flows increases generation at Kerr by making flows usable that might otherwise exceed plant capacity and be lost to spill. Furthermore, the BOR points out that there would be significant impacts associated with changing the operation of Hungry Horse Reservoir. "An increase in winter releases would increase the risk that Hungry Horse would not refill in the spring. This could affect the reservoir fishery and recreation use. Additional restrictions on Hungry Horse may cause other headwater projects in the Columbia River system to be drafted more heavily in the coordinated system operation, as the Northwest utilities reformulate their system operation to maximize the FLCC based on new deplistions and contractual constraints." MUNICIPAL WATER SUPPLIES Public water supplies in the Clark Fork Basin are derived from a number of sources. The majority of the communities use ground water as their primary source of water, but a few rely heavily on tributary surface water* In the Missoula area, the public water supply is obtained primarily from the Missoula Aquifer, which is partially recharged by the Clark Fork. An inventory of municipal water supplies in the basin is provided in Table 2-11. The DHES-WQB administers the Safe Drinking Water Act, and, in conjunction with public utilities, it monitors these public water supplies to insure that bacterial, chemical, and radiological contents remain within safe limits. WQB personnel review and approve all construction and modifica- tions to public water systems and conduct annual inspections of each system. 2-18 C/} CQ Eh U) CQ E-i l-H M M Ul M Ul U OS 8 § > b: u w u z CD o •« l-l CO ^ 3 U 03 VI 0) -O 0) Pi •2 -I 8" 02 C C 9 S o o o o o o s 1)5*^ * S y rO U-^ ro (U • • Ld X l-l (U 1 s| (V 'DOM §(S )-( i«-i (1) O h t*. Ij D 0) o cn £ « l-l o a> o o> o (0 - o u s 2 I r-i & s t. in 3 S ' 3 (4-4 S o g .H •H B 4-1 UJ ID JC a » o . +-> Id -^ M f 3 .-H 1 1 o. -tj 01 B n o o> t4 0) ti n g £ "S V •H o ^ 1" r^ (0 ^ « Q .-H E-l '^ i ^ ^ % ns o U gnu 2 ■§ §• ^_^ • O B '^ P §! o 5 Q Q CO •'^ 5E SB r-i ic ac o t>- o O 10 o O "O o § 8 4 mi day 2.75 900, per 320, 120, 60,C ^. .. 01 .. O 14 S l-l ^ i y H ii i " O S f^ +-> i r-( •!-> <• 6 rH B i -< C i B o 3 (0 -H i:^ m t3i 3 ° 3 (0 -H s 3 -H en 3 TJ- III II I 2-18a 01 -H >1 > 05 -H U E S B i . 01 — 01 Q, O I— I 01 rH 3 « l-l s 2 11 o o o % 2 04 M l-H OS ij SN a. o s» g OS Id o V} u s g s s ►-4 s = i 1 "^ s s g 5 u V4 2 S B I ■s g •H V s •H Li s 5 J= * tj w M s s •H ■-I «— 1 s. 2L •a o o o -u o w n .H 3 ID r— I 0) g t>1 (0 +J XI OS s i kl 1 g ^ ^ o ui u M s 0) o IS t^ b. o 8 I Si (N s "3 £ 1^ s S o o 8 8 S CO ('l »-l III — 1 t/J 3 8 S O IS 8^ I 8. o o o IB (N £ 2L s. s. S. H •H •H •" a, . a • cx • Q, ■ >H >i >1 >i - ■!-> N 4-» *• +J - " W -H M 'f-l Is 3 M I1 11 Oi Ol &, Ol a Ol CL Ol 2. B Id & +J Ol § s. g (0 •». 1-1 o o 3 g r-( m ro I1 rH .-H a< Ol a. • II ig i * "8 5 S •H 2 fel. *1 % S in I . i-H n o B c>i o gi 3 S - . 5 1 « ^. s 2 8. 2- 18b '& on u Eh i ^ l-H U) t-> td «C M S t_) 1-3 (-H U3 U o «s 3 Eh o «e «2 3 > oe u w CaJ z o M E-t O »: ^ D kS 04 3 1 (0 i •H O ^ 1 .9 >< +J CQ ^ s •H rH XI 1 g c 8. •H PQ H M M IS ri G* w u 1-1 «s Q b cu 1 O ^^ r-l (0 (1> Ol l-l o 2. Q> « V ^ o -t-" (N n U (^ •• (U M ■VJ 01 0) gCT ♦J C [0 •H » <1> IH U G, TS ID C/1 C fj 3 y ^ 2 en a: o s •iH 0} to S •H O rH I I I O O o u V ■M o 1—1 s B 13 • •. 3i tj> M IH O (0 O U V O IT) 4-> CS M ■U s o I 1 u & OJ c u Lj ^ $• & 2- 18c INDUSTRIAL/MUNICIPAL WASTEWATER DISPOSAL A number of industries and municipalities discharge wastewater to the Clark Fork and its tributaries. These are point source discharges that are permitted by the DHES-WQB under the Montana Pollutant Discharge Elimination System (MPDES) . A list of MPDES permittees in the Clark Fork Basin is provided in Table 2-12. These industries and municipal- ities discharge a variety of substances to the Clark Fork and its tributaries, including nutrients, organic wastes, and sediment. An MPDES permit for wastewater discharge is designed to protect all beneficial uses of the receiving water. It is designed to assure water quality protection when streamflows are as low as the minimum consecutive 7-day average flow that may be expected to occur on the average of once in ten years. Nearly all of the cities and towns in the basin have wastewater treatment plants, although a few of the smaller communities such as Gold Creek, Clinton, Bonner, and Noxon are served solely by septic systems. The wastewater treatment plants range from fairly simple lagoon systems to more elaborate secondary treatment facilities in the larger cities such as Butte and Missoula. An inventory of WWTPs in the basin is provided in Table 2-13. All of the operators (except Anaconda, whose system does not currently discharge to state waters) are required to monitor their discharges and report to the DHES-WQB. These monitoring reports are reviewed by WQB personnel to ensure compliance with permit requirements. Regular inspections of the facilities are also conducted by the WQB. Among the larger dischargers in the basin, the two that have raised the most controversy are the Frenchtown pulp mill (previously owned by Champion International Corporation, now owned by Stone Container Corporation) and the Missoula WWTP. In 1983, Champion International applied for a permit that would allow it to discharge a portion of the wastewater into the Clark Fork year-round, rather than only during spring high flows (as stipulated by its previous permits) . Although the WQB was initially inclined to approve the permit, public concern over the lack of scientific data to support such a permit modification resulted in the issuance of an interim two-year permit and the initiation of a number of scientific studies. The WQB analyzed the information gathered during the two-year study period and issued a draft environmental impact statement (EIS) late in 1985, recommending renewal of the permit for five years. Public concerns over the EIS led to the issuance of an addendum to the EIS, wherein some of the disputed issues were clarified. A five-year permit for the pulp mill was finally issued in November 1986. The 2-19 TABLE 2-12. MONTANA WASTEWATER DISCHARGE PERMITS IN THE CLARK FORK BASIN Permit Permittee Expiration Date Anaconda Company 1-31-88* Montana Resources, Inc. 2-28-88* Butte WWTP 5-31-93 Rocker Water & Sewer District 5-31-93 Montana Warm Springs State Hospital 5-31-93 Montana Galen State Hospital 1-31-91 Montana Fish & Game Washoe Hatchery 8-01-89 City of Deer Lodge 5-31-93 Town of Philipsburg 5-31-93 Town of Drummond 5-31-93 Missoula WWTP 3-31-93 Champion Building Products 3-31-93 Stone Container Corp. 9-30-91 J. R. Daily 3-31-92 Lolo WWTP 10-31-92 Stevensville WWTP 12-31-88 Town of Stevensville 12-31-88 City of Hamilton 6-30-93 Town of Darby 5-31-93 Town of Alberton 5-31-92 Town of Superior 5-31-92 Montana Power Company, Kerr Dam 6-3 0-89 City of Ronan 9-30-88* City of St. Ignatius 9-30-88* Montana Fish & Game Jocko Hatchery 8-01-89 Charlo Sewer District 6-30-89 Town of Hot Springs 1-31-90 Town of Thompson Falls 11-30-88 Western Materials, Inc. 3-31-90 Dillon Exploration 10-31-93 *These permits have been administratively extended, Source: DHES 1988b. 2- 19a O OS b. o a: u u w b. 3 v> as 0) 1 s S. •H M 5 •-a 1 ^ 1—* V o •H LP o rH g ^ S S 1— 1 ?. >i U-4 -3 is 4J o i 0) i •H u 1-* 3 S Ol t"? 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I I 4-* <4-l ■H a a B o l^e > •H 0 r-i 8 r-H « d oc o 2-19n 8 I— I t •H •U E-1 «C M CJ oa M u bu i-i M cS U 3 u Oi CO g z o M M U (n t_> Cd U M OS «S t-l I? s g (0 U VO > I* o c •H J3 ■1-' •H 3 I & 8, Q> w o 1 B g ac3 1 ^.. m 1 f-H to IM 0) (0 a> •r-* U 0) n L4 u o CO -H O i-H ^ -2 12 I g S S u-i I en 12 n u a> ■4-> —1 o i 3 c 00 00 o i I -8 •H kl I O ro O in 1 I w ? g. i! 1 •H O a> 4-> ■H b. g S* g •S >- t^ $ » ^ s. > 1(1 Q) 1— 1 2-19p permit stipulated that wastewater could not be discharged to the Clark Fork during low-flow periods. The discharge permit for the Missoula WWTP expired on September 30, 1987, but was administratively extended into 1988. The WQB prepared a preliminary environmental review (PER) in January 1988 and issued a notice in February 1988 of its intent to issue and/or review the permit. The tentative permit drafted by the WQB contained interim (one- year) biochemical oxygen demand (BOD5) and total suspended solids (TSS) effluent limitations that were less strict than National Secondary Standards. These interim limits were intended to allow the city to remain in compliance while making changes that should solve the problem of periodic treatment plant upsets. The tentative permit also limited the amount of phosphorus discharged to no more than 1982 levels and required the city to conduct bioassays on the plant effluent. There was a considerable amount of public reaction to the tentative state permit. Many people felt that the WQB was holding the city to a different (more lenient) standard for discharging than the one applied to Stone Container Corporation when its permit was renewed. There was concern over the interim BOD5 and TSS limits and over the possibility of increased phosphorous loading to the river. Although the plant will be held to 1982 phosphorus limits, those limits are considerably higher (593 pounds/day) than the plants actual phosphorus discharge in 1986 (275 pounds/day) . A final permit was issued by the WQB in July 1988 with an effective date of August 1, 1988. The interim limits for BODc and TSS were removed from the permit. Final effluent limitations for BOD5 and TSS are equivalent to the National Secondary Standards. A lower phosphorus limit has been imposed as a goal, along with conditions requiring additional studies to be done that will result in examination of various phosphorus-reducing alternatives . WATER RESERVATIONS Introduction Montana's 1973 Water Use Act allows public entities, such as conservation districts, municipalities, counties, and state and federal agencies to reserve water for future uses. These include diversionary and consumptive uses, as well as instream flows for the protection of fish, wildlife, and water quality. 2-20 The main advantage of a water reservation over an individual water use permit is that once approved, the reservation sets aside water for a particular use. Thus, the reservation law allows for the planning and allocation of water for future uses. Those entities eligible to use reserved water have a longer time period (up to 30 years or more) to put the water to beneficial use and still maintain their early priority date. By comparison, water use permits must be put to beneficial use within a few years. To justify the need for a reservation for irrigation or domestic uses, an applicant must prepare a water use plan that identifies future water users and their estimated water needs. This information explains why the water must be limited to a specific future use and why the applicant is ineligible to appropriate water by means of a permit. The reservation statute and rules require the applicant to fully support the purpose, need, amount, and public interest of a proposed reservation. Reservations for instream flow are limited to 50 percent of the average annual flow on gaged streams. The statute assigns administrative responsibilities to the Board of Natural Resources and Conservation. The Board, which is made up of seven citizens from around the state, is appointed by the governor. The Montana Environmental Policy Act (MEPA) requires ah environmental impact statement for actions of state govern- ment that have the potential to create a significant impact on the environment. The EIS examines the environmental, social, and economic impacts of the reservation. Upper Clark Fork Water Reservations Proceedings The DNRC has received two applications to reserve water in the upper Clark Fork Basin above Milltown Dam. One applicant is the DFWP, which wishes to reserve instream flows in the mainstem of the Clark Fork and 17 of its tributaries (DFWP 1986) . The other. Granite County Conservation District, is seeking to reserve water for irrigation use by developing a storage reservoir on the North Fork of Willow Creek between Drummond and Philipsburg. Table 2-14 sum- marizes the reservation applications. A draft EIS on the reservation applications in the upper Clark Fork Basin was issued in November 1988 (DNRC 1988a) . Following a 60-day comment period, the final EIS will be prepared and distributed. The DNRC will then publish the notice and receive written objections to the reservation applications. If the DNRC determines that the objections are valid, a formal contested case hearing will be held. The Board will probably make the decision on the upper Clark Fork 2-21 TABLE 2-U. SUMMARY OF PROPOSED UPPER CLARK FORK BASIN WATER RESERVATIONS Stream Name Length of Stream Reach (miles) Flows and Volume of water Requested Year-Round Instream Flows for Water Qual i ty Jan 1 to May 1 A) DEPARTMENT OF FISH, WILDLIFE AND PARKS (instream flow) Clark Fork mainsteM Reach 1 37.8 (Warm Springs Creek to Little Blackfoot River) Reach 2 28.1 (Little Blackfoot River to Flint Creek) Reach 3 35.8 (Flint Creek to Rock Creek) Reach 4 17.2 (Rock Creek to Blackfoot River) 180 cfs 130,314 AF 400 cfs 289,587 AF 500 cfs 361,983 AF 600 cfs 434,380 AF None None None None Warm Springs Creek Reach 1 (Confluence of Middle Fork Warm Springs Creek to Meyers Dam) Reach 2 (Meyers Dam to mouth) Barker Creek Storm Lake Creek 1 15.3 16.6 5.1 10.0 50 cfs 36,198 AF 40 cfs 28,959 AF 12 cfs 8,688 AF 10 cfs 7,240 AF 3 cfs 2,172 AF For all Clark Fork tributaries, all of the instantaneous base flow, subject to existing, law- fully appropriated water rights until such a time as mine waste reclamation allows copper concentra- tions entering the Clark Fork above Warm Springs Creek to reach acceptable levels in downstream reaches. Flow is requested at each stream's confluence with the Clark Fork. Cable Creek 5.8 10 cfs 7.240 AF Twin Lakes Creek 7.5 13 cfs 9,412 AF Lost Creek Racetrack Creek Reach 1 (Confluence of North Fork Racetrack Creek to USFS boundary) Reach 2 (USFS Boundary to mouth) 19.9 9.3 10.8 16 cfs 11,583 AF 26 cfs 18,823 AF 3 cfs 2,172 AF 2-21a TABLE 2-U (COMT.). SUMMARY OF PROPOSED UPPER CLARK FORK BASIN UATfR RESERVATIONS Stream Name Length of Stream Reach (iwiies) Flows and Volume of water Requested Year-Round Instrean Flows for Water Oual i ty Jan 1 to May 1 Dempsey Creek Little Blackfoot River Reach 1 (Blackfoot Meadows to Dog Creek) Reach 2 (Dog Creek to mouth) Snoushoe Creek Dog Creek Gold Creek Flint Creek Reach 1 (Georgetown Lake to Boulder Creek) Reach 2 (Boulder Creek to mouth) Boulder Creek North Fork of Flint Creek Stuart Mill Creek Harvey Creek 17,1 17.4 26.9 9.2 15.5 15.0 28.0 15.7 15.4 7.5 0.3 14.6 3.5 cfs 2,543 AF 17 cfs 12,307 AF 85 cfs 61,537 AF 9 cfs 6,516 AF 12 cfs 8,688 AF 54 cfs 24,61$ AF 50 cfs 36,198 AF 45 cfs 32,578 AF 20 cfs 14,479 AF 6 cfs 4,344 AF 14 cfs 10,136 AF 3 cfs 2,172 AF in»«V t -.-, ■•tl:j noj.^; 2-28a The most useful data of the 1987 study were the fish population estimates for the spring-early summer period. Figure 2-1 displays estimates of the numbers of rainbow and brown trout 7.5 inches or more in total length in 31 sections covering 135 river miles (RM) . Exact comparison with estimates generated in previous years is not possible because section lengths vary due to the improved mapping and measuring techniques in 1987. Older estimates were based on numbers of trout 6 inches or more in most cases. Despite these computational differences, estimates from 1987 are very similar to those from previous years. Data presented in Figure 2-1 show that fish population distribution varies considerably from the headwaters to Milltown. In the uppermost sections from the Warm Springs Pond 2 outflow to the end of the pH shack section (RM 501- 498), brown trout densities were between 1,500-2,000 fish per mile. A precipitous drop in trout numbers to a level of about 500 per mile, occurred between the end of the pH shack section and the Galen Bridge (RM 498-491) . From the Galen Bridge to below Drummond (RM 491-409) populations slowly declined in density from about 250 per mile to 150 per mile. A more abrupt change occurred from about Bear Creek to Beavertail (RM 409-385) where populations of trout were about 50 per mile. Rainbow trout numbers became significant in this section, presumably reflecting the influence of recruitment from Rock Creek. Trout population numbers increased substantially to about 250 per mile in the segment from about the mouth of Rock Creek to Milltown Dam (RM 385- 366) . Rainbows were the most abundant trout, with brown trout the other dominant species in this segment. Trout Spawning and Rearing Habitat Throughout the Clark Fork above Milltown, with the exception of the Warm Springs section, trout populations appear to be of lower density than the habitat might support. The factors that determine trout abundance over much of the upper river are not well known nor easily discernable. If physical habitat in the most basic sense is present in excess of population levels, then some other factor (s) must be limiting population density. Either the number of trout available from reproductive efforts is inadequate to fill the available habitat, or something kills a significant fraction of the population on a regular or, at least, frequent basis. Conditions for trout reproduction in the river are poor. Most of the upper river seems unsuitable for trout reproduction due to siltation and other substrate deficien- cies. Successful reproduction may occur in the uppermost reaches of the river near Warm Springs, at least in some 2-29 0 ^ c Z 0 ^ ir Q £ ^ ■ 0 '^ 2 i^v^--^^ ■ o n ■ 0 9 oo 00 o a. a u u 3 O 10 N 3 KSW.^ r Q KW-'^\'^\'' ^,\V\\\A i 0 < liJ Si r-.'>y..v,> (\\\\\\\' TswV-.V IVVanv LVsvVv\'>^ ^ lil KWVVWnn'' > T- s ' t o 0 i- ffl III i» ^^\^^\V^\\^> uJ ?i [AV\\\v Q J |,\\W\\\\'\''\ K\\^\V\VV>>W PTWNW'WO^ t.XVK'^SWW; k,-\\\Vvs\\VA\'-'VJ (v^\\^\\v■^^'^^^'>'^'>^'>''^ ■'—'■'' (>\\\\\A.Y.VA'>\\SN\\\NS'\\\\\\\\'.\\\.N\\\V\\\\\V.V.\-.\\\\V,V.\\> K\\\Y,^^V^\\^\^\Y^\^\\V^\A\\^\^^^V.\\\^\\V.^\\\\\\vVA^\\^^\\^A\V^^^\\\\^\\\\\>.V^ t'--\\V\\\\\\\\\\',\V\v<>\AV\S\\\>\x^\\\\\\\\\\\\\V\\\\\\\\V\''A-A\\^''N\VV\\'\X\\\\\'A\NV iCA\\\'\\\\\\V\'\'\>j\|\\\\\\\\\\\\\\\\\\x\\W.\\x\\\\\\\\>- E f 1 1 10 • 1 • I Q 0 0 0 0 0 0 0 0 5 10 0 10 « T- T- anii^x ±noa± OO atf cu OB o u. :^ OS < -1 as u a, a. U ac H o M H Z U o u > Z H O OS H _] < H O H U 2-29a years. Numbers of juvenile brown trout were not estimated during the 1987 survey due to the unsuitability of the gear used, but numbers of brown trout smaller than 7.5 inches, ages 0 and 1, were recorded. In general, those numbers vary in concert with adult population estimates. Highest numbers of small (young) fish were observed in the Warm Springs area. Numbers declined generally to a low near Bearmouth and increased immediately upstream and downstream from the mouth of Rock Creek. Except in the Warm Springs area, the numbers of young trout were generally very low. During the summer of 1987, marked juvenile hatchery rainbows were released in the low population areas below Drummond. If these fish persist in the river, then it may suggest that reproduction and juvenile survival is indeed a major limitation on population levels. A few of those stocked fish were recaptured by electrof ishing in the fall of 1987. Eggs and sperm were taken from brown trout spawners in the Warm Springs area in 1987 and placed in the hatchery for rearing. Fish reared from these eggs were marked and released in the summer of 1988, and their survival will be monitored in future years. Assessment of timing and estimates of numbers of outmigrating juvenile brown trout from spawning tributaries began in 1988 and will continue in following years. Tributary Trout Spawning Migrations Tributary spawning habitats appear to be limited in the upper river segment. Warm Springs Creek has been shown to have a run of hundreds of brown trout during the spawning season, and limited numbers of browns also enter Lost and Racetrack creeks. The 1987 trapping of brown trout entering the Little Blackfoot River yielded fewer than 400 trout, which is far fewer than the Little Blackfoot appears capable of supporting. A similar number of river migrants were shocked in Gold Creek where access to trout is limited to only 300 yards of stream due to an artificial barrier. The importance of Flint Creek for spawning trout is unknown, but spawning substrates there are of poor quality. Rock Creek is no doubt a significant contributor to recruitment in the Clark Fork, particularly for rainbow trout. In summary, available data are presently equivocal on the questions of recruitment, available habitat, and rates of trout mortality in river environments. However, the catch from the Little Blackfoot spawning migration trap in fall 1987 may offer some clues regarding fish population dynamics in the upper Clark Fork. Water quality and substrate 2-30 conditions in the Little Blackfoot seem to be well suited to brown trout reproduction, and upstream migrants should have access to more than 30 miles of stream. The available spawning habitat would appear to easily accommodate several thousand fish. This suggests that factors controlling fish populations in the mainstem are limiting available spawners to numbers below the available spawning habitat capacity. Middle Clark Fork Fishery (Milltown Dam to Flathead River) Fish Species Composition The bulk of the sport fishery in this 119.4-mile reach of the river is provided by rainbow trout along with a few brown, bull, and westslope cutthroat trout. Mountain whitefish provide an important winter sport fishery. Common nongame fish species found in the reach include squawfish, redside shiners, longnose dace, coarsescale suckers, and slimy sculpins. Trout Population Estimates Trout populations have been estimated by electrof ishing and mark/ recapture procedures in four study sections on the middle Clark Fork. The study sections are located in the vicinities of Milltown Dam, Missoula, Huson, and Superior (Table 2-16) . Estimates in the four study sections indicate the river supports from 175 to 402 catchable rainbow trout per mile (Table 2-17) . Rainbow trout constituted more than 90 percent of the catchable trout population in all of the study sections. Catchable brown, westslope cutthroat, and bull trout were present in the river, but their numbers were usually too low to estimate. In September 1986, estimates of 16 catchable brown and 22 catchable westslope cutthroat trout per mile were obtained in the Missoula study section. The density of catchable trout is less than expected for comparable trout streams the size of the Clark Fork. While the Clark Fork supports an average of 200 to 400 catchable trout per mile, other large trout rivers in Montana often support 2,000 to 3,000 or more catchable trout per mile (Berg 1984) . Major tributaries to the Clark Fork support larger populations of catchable trout than the mainstem of the river. The mean number of catchable rainbow trout per mile in the Blackfoot River over a three-year period from 1983 to 1985 was 445 percent larger than the mean number of catchable 2-31 TABLE 2-16. LOCATION, LENGTH, AND RIVER MILE INDEX BOUNDARIES OF FISH POPULATION STUDY SECTIONS ON THE CLARK FORK Sectfon Description Section River Mile Name of Location Length (mi) Index Boundaries Milltown MiUtown Dam to 2.8 miles upstream 3.4 364.4 to 361.0 from confluence of Rattlesnake Cr. Missoula Confluence of Bitterroot R. to 0.5 8.6 350.5 to 341.9 mile upstream from Harper Bridge Huson Confluence of Sixmile Cr. to 4.0 4.5 328.2 to 323.7 miles upstream from confluence of Petty Cr. Superior Confluence of Cedar Cr. to 6.3 286.6 to 280.3 confluence of Dry Cr. Source: Berg 1986a. TABLE 2-17. TROUT POPULATION ESTIMATES IN FOUR STUDY SECTIONS OF THE CLARK FORK Study Date of Fish Section Catchable Catchable Section Estimate Species Length (mi) Trout/Section Trout/Mi le Missoula Sept. 1984 Rainbow 8.6 Missoula June 1985 Rainbow 8.6 Milltown June 1985 Rainbow 3.4 Superior July 1985 Rainbow 6.3 Huson Sept. 1985 Rainbow 4.5 Missoula Sept. 1986 Rainbow 8.6 Brown 8.6 W.S. Cutthroat 8.6 Huson Sept. 1986 Rainbow 4.5 All Section-Rainbow Mean (X) 288 Catchable trout 7 inches total length and larger. Source: Berg 1986a. 1,506 175 1,804 210 1,035 288 1,382 219 1,749 389 3,461 402 137 16 187 22 1,504 334 2-32 rainbow trout per mile in the Clark Fork during a three-year period from 1984 to 1986 (Tables 2-17 and 2-18) . The com- parison of the Blackfoot River with the Clark Fork is appropriate because both rivers have similar physical habitat characteristics . TABLE 2-18. TROUT POPULATION ESTIMATES IN THE JOHMSRUO SECTION OF THE BLACKFOOT RIVER, APPROXIMATELY 13 MILES UPSTREAM FROM BONNER Date of Fish Section Catchable^ Catchable'' Estimate Species Length (mi) Trout/Section Trout/Mile June 1985 Rainbow 3.6 5.225 1.451 June 1984 Rainbou 1.4 3,186 805 June 1983 Rainbow Iwl 5.445 1,512 Mean (X) 4,618 1,2W Catchable trout 7 inches total length and larger. Source: Berg 1986a. Scales were collected from trout during population samplings to determine growth rates and age structure of the trout populations. Preliminary findings indicate growth rates of trout in the Clark Fork are relatively high when compared with trout streams of similar size. This indicates that food supply is probably not a limiting factor for trout populations in the Clark Fork. Furthermore, it suggests that the Clark Fork may be "under seeded" and that recruitment may be a limiting factor. Trout Spawning and Rearing Habitat Visual surveys have been made in the Milltown, Missoula, Huson, and Superior study sections during the rainbow and brown trout spawning periods in an attempt to locate trout redds. To date, only brown trout redds have been located, in the Milltown and Missoula sections. Because a very limited amount of time has been spent on visual surveys, additional observations must be made to evaluate the extent of trout spawning in the river. 2-33 The search for trout redds in the middle Clark Fork is hindered during both rainbow and brown trout spawning periods by poor visibility in deep water areas where spawning could occur. Visibility is sometimes precluded even in shallow water during the rainbow trout spawning period due to highly turbid spring runoff conditions. For this reason, use of the Clark Fork for trout spawning is also being evaluated by electrofishing during the spawning periods in an attempt to locate concentrations of mature fish in spawning condition. Suitable rainbow, westslope cutthroat, and brown trout rearing habitat is found primarily along the edge of the Clark Fork's channel. Limited electrofishing surveys of this habitat indicated young-of-the-year trout were rela- tively more abundant in the Milltown and Superior study sections than in the Missoula and Huson sections during late summer of 1985 (Table 2-19) . Young-of-the-year trout were relatively scarce in all four study areas (Berg 1983) . TABLE 2-19. AVERAGE SIZE AND RELATIVE ABUNDANCE OF YOUNG-OF-THE-YEAR TROUT SAMPLED BY ELECTROFISHING Study Section Date Trout Species Average Length (mm) Juveni le Trout E I ectrofi shed/Hour Milltown 8-26-85 Rainbow Brown 57 90 Missoula 8-28-85 Rainbow 76 (side channel) Brown 94 Missoula 8-28-85 Rainbow 63 (main river) Brown -- Huson 8-30 & 9-4- ■85 Rainbow Brown 60 77 Superior 9-5-85 Rainbow Brown 58 81 7.1 10.1 1.7 10.0 1.4 0.0 3.6 0.3 14.6 1.1 Source: Berg 1986a. 2-34 Tributary Trout Spawning Migrations In an effort to evaluate spawning periodicity and sources of trout recruitment in the middle Clark Fork, the lower reaches of several tributaries were electrof ished or set with traps during trout spawning periods to locate spawning migrants from the Clark Fork. Most members of the trout family migrate during the spawning season in search of suitable spawning sites (Hubbs and Lagler 1970) . Spawning movements of lake dwelling salmonid populations into inlet or outlet streams have been extensively documented for rainbow (Rayner 1942; Hartman et al. 1962; Calhoun 1966; Scott and Crossman 1973) and brown trout (Fenderson 1958; Stuart 1957) and mountain whitefish (Snyder 1918; Calhoun 1966). Less information is available on spawning movements of river-dwelling salmonid populations into feeder streams. Calhoun (1966) reported that resident rainbow trout popula- tions in streams tend to move upstream, and if possible into tributaries to spawn. River-dwelling brown trout in Ontario normally seek tributary streams for spawning purposes (MacKay 1963) . Spawning movements of mountain whitefish from larger streams into some tributaries have been observed in Montana (Liebelt 1970; Brown 1971). Electrof ishing and fish trapping surveys indicate considerable numbers of rainbow, brown, and westslope cutthroat trout migrate from the Clark Fork into tributaries to spawn (Berg 1986a) . Significant trout fry outmigrations from several tributaries, monitored with fry traps, indicated tributaries provide considerable recruitment of juvenile trout to the Clark Fork (Table 2-20) . Lower Clark Fork Fishery (Flathead River to Lake Pend Oreille) Fish species composition in the lower Clark Fork has been significantly altered by habitat changes and the introduction of new species. Of the ten game species found in the lower Clark Fork, only the westslope cutthroat, bull trout, and mountain whitefish are endemic. Six game species introduced since the impoundment of the reservoirs are northern pike, black crappie, burbot or ling, kokanee salmon, silver salmon, and smallmouth bass. Northern pike and black crappie resulted from illegal introductions while the other four species were planned introductions by DFWP. Of the ten nongame fish species, only the bullhead, pumpkinseed, and perch were introduced by man. 2-35 o 9 60 It 0) 5 ^ a, H (U O _ H 2 5 4-1 D tlO ■~~ Z i-i o a •p 3 i-H « < o 4J u H l-H 0) 4-J ~ O H T3 01 5 0) 60 i-i < 4-1 x: 60 u H •a 01 3 4J ^3 4-1 o. x; n) 60 0) l4 4-> o d o o o o o o o o in o o o o to o o o ^ -* o o d to o o o o o o o oo PO vO in o -* vO -* to t^ ) »-4 •H x; 4-1 4J Q ifl c 4J 4J X •H •H 4) s •r4 b. a: Ol. W 43 00 On 60 M (V OQ o to 2-35a Attempts to establish a viable sport fishery in the Noxon Rapids and Cabinet Gorge reservoirs have been mostly unsuccessful. However, a shift in management emphasis in 1982 away from cold water fish species, such as rainbow trout, to cool water species, such as smallmouth bass, h^fe shown great promise for future fisheries. Efforts on each reservoir have differed due to different reservoir condi- tions. Cabinet Gorge Reservoir The Cabinet Gorge water exchange rate (or flushing time) is currently about one to three days during spring high water and about one week during the remainder of the year. Reservoir fluctuations from 1953-85 were slightly different because Cabinet Gorge was used as a reregulation reservoir for Noxon Rapids Reservoir, which came on line in 1959. Typically, daily and weekly fluctuations during that period often were two to four feet respectively; annual maximum fluctuations seldom exceeded ten feet. Attempts to establish a sport fishery at Cabinet Gorge Reservoir during the period of 1953 through 1963 included planting large numbers of hatchery-reared salmonids. During these years, a total of about 1.7 million kokanee salmon, 1.2 million Yellowstone cutthroat, 0.1 million silver salmon, and 0.5 million rainbow trout were released into the reservoir. These planted fish provided a very limited sport fishery and did not establish self-sustaining populations within the reservoir. From 1963 to the present, fish planting has been limited to planting catchable-size rainbow trout near the Bull River campground and eyed brown trout eggs near the mouth of Elk Creek in an attempt to establish a spawning run. The emphasis for fishery management has been shifted to Noxon Rapids Reservoir because the fishery that develops there will probably determine the fishery in Cabinet Gorge Reservoir. Noxon Rapids Reservoir This reservoir has rapid water exchange rates of about one exchange per week during a normal spring high water period and one exchange per three weeks during the remainder of the year. During maximum drawdown of 54 feet, the surface area is reduced from 8,600 acres at full pool to 5,500 acres. Reservoir operation during the 1958-79 period followed two distinct patterns. From 1958-60, maximum annual drawdown was limited to ten feet, and from 1961-79 maximum annual 2-36 drawdown ranged from 2 6 to 54 feet and averaged 35 feet. In 1961, Noxon Rapids Reservoir was integrated into the Northwest Power Pool under terms of the Northwest Power Coordination Agreement. Deep, spring season drawdowns were in response to calls for power from the Bonneville Power Administration or other utilities. The spring drawdowns also created up to 230,000 AF of storage space for flood control. Initial fisheries management efforts to establish a viable fishery in Noxon Rapids Reservoir were mostly unsuccessful. Chemical treatment to remove unwanted rough fish followed by planting rainbow trout fingerlings produced an excellent fishery for a brief period when the river was first impounded. Subsequent fish plantings have included brown trout (690,000 fry), kokanee salmon (1,000,000 fry), westslope cutthroat trout (926,000 fingerlings), burbot (420 adults), and rainbow trout (200,000 fingerlings). These plants have been unsuccessful. Fish populations noticeably increased from 1980 to 1985. During this period, Noxon Rapids Reservoir drawdowns were within a maximum of 12 feet. Increased numbers of game fish and forage fish during this period are believed to be a result of the relatively more stable reservoir conditions. In 1982 and 1983, smallmouth bass were planted in the reservoir, and by 1984, the fish were being caught by anglers. At the same time, the numbers of largemouth bass were also increasing. A new reservoir operation plan that reduces the extent and frequency of drawdowns was initiated in 1986 following a meeting of the Washington Water Power Company, the Northwest Power Planning Council, and the DFWP. In 1985, the DFWP and WWP began a three-year pilot fisheries development program. Hundreds of thousands of brown trout eggs and fingerlings and over 2,000 adult burbot have been planted in the reservoirs. The program was recently extended through 1989 and expanded to include enhancements for bass. The fish populations of both Noxon Rapids and Cabinet Gorge reservoirs have been periodically sampled with gill nets since 1958. The results indicate a shift in species composition, probably as a response to the more stable water levels in the 1980s. Mountain whitefish, rainbow trout, and bull trout are substantially reduced in Cabinet Gorge, while the numbers of largemouth bass, brown trout, and yellow perch have increased. Surveys also indicate increased numbers of brown trout are spawning in the Bull River, a tributary to Cabinet Gorge Reservoir. Fish population samples from Noxon Rapids Reservoir indicate fairly stable populations from 1960 through 1982, 2-37 followed by a marked increase in 1987. Much of the increased catch consisted of yellow perch, squawfish, and coarsescale suckers. Brown trout increased during 1982-87 probably due to improved natural reproduction. Bull trout and rainbow trout numbers have remained relatively stable, while large- mouth and smallmouth bass appear to be increasing. The stabilization of reservoir levels appears to have improved benthic populations and enhanced populations of forage fish species, such as redside shiners, yellow perch, peamouth, and pumpkinseed. Burbot have not been taken in the gill net samples, and special sampling efforts will be required to determine their success. Growth rates of brown trout and yellow perch have increased during the 1980s. The drawdown restrictions of Noxon reservoir is expected to result in both improved growth rate and greater fish numbers in the future. Fisherman Use and Benefits The number of fishermen using a body of water is one measure of its value as a recreational resource. Fisherman use, or "fishing pressure," on Montana waters has been estimated by the DFWP each year since 1982. The Montana Fisheries Survey uses a questionnaire mailed to a sample of fishing license holders to determine where and how often they have fished. The data are compiled for individual lakes and streams and summed to provide a measure of fishing pressure in an entire drainage. The estimated total fishing pressure on all lakes and streams within the Clark Fork Basin (excluding the upper Flathead River drainage) has ranged from 215,272 to 242,691 angler days per year in the four annual surveys conducted since 1982. The fishing pressure statistics indicate resident fishermen accounted for 83 percent of the total, while 17 percent were nonresidents from various locations in the region (McFarland 1988). A comparison of fishing pressure between streams and between segments of a stream is an indication of relative recreational importance. Table 2-21 provides a breakdown of the 1985-86 fishing pressure statistics for streams in the Clark Fork Basin and for some selected Montana rivers. The data indicate that all segments of the Clark Fork sustain significant fishing pressure. Fishing pressure on individual segments of the river (upper and middle river) are comparable to pressure on the Blackfoot River and Rock Creek. Much higher fishing pressure occurs on Montana's more famous trout streams such as the Madison and Big Hole rivers. 2-38 TABLE 2-21. ESTIMATED FISHING PRESSURE ON THE CLARK FORK AND SELECTED MONTANA RIVERS (1985-86) Fishing Pressure River (Angler days per year) Lower Clark Fork (includes tribs.) 21,237 Middle Clark Fork (mainstem) 3 0,414 Middle Clark Fork Tributaries 6,835 Upper Clark Fork (mainstem) 17,578 Upper Clark Fork Tributaries 24,208 Bitterroot River (mainstem) 56,024 Blackfoot River (mainstem) 28,974 Rock Creek (mainstem) 27,881 Big Hole River 47,910 Madison River 108,712 State Total 1,192,658 Source: Duf field et al. 1987. Although differences in pressure among streams may reflect fishing success, other factors such as access, distance to population centers, aesthetics, fishing regula- tions, etc., may have an equally important influence on the numbers of fishermen using a stream. In the past, the primary indicator of the economic value of fish and wildlife in Montana has been dollars spent by sportsmen. Although these expenditures are important to local and state economies, they do not reflect the total recreational value of the resource that includes the personal benefits one receives from hunting and fishing (Montana Department of Fish, Wildlife and Parks 1988b) . In 1985, the DFWP in cooperation with the U.S. Forest Service (USES) and the Bureau of Land Management (BLM) , initiated a two-year study to document the recreation value of sport fishing and hunting in Montana (Duf field et al. 1987) . Using widely accepted recreation analysis methods (U.S. Water Resources Council 1979, 1983), the department was able to develop an estimate of how much additional amount recreationists would be willing to pay over and above their actual travel costs to have access to a particular site for fishing. The study data provide net economic values appropriate for benefit/cost analysis or where economic efficiency decisions are being made. The data used in the study of fishing values were obtained through questionnaires mailed to approximately 36,000 resident (92 percent) and nonresident (8 percent) 2-39 fishermen. Fifty-four percent, or 19,271 of the surveys were returned. In addition, a supplemental survey was administer- ed to obtain socio-economic data from approximately 2,000 fishermen. All data were then analyzed to estimate fishing pressure, net economic values (willingness to pay) , and actual expenditures by fishermen on the major fishing streams and lakes in Montana. The net economic value for the Clark Fork and other important Montana rivers is shown in Table 2-22. The value per day multiplied by fishing pressure provides estimated annual site value. The site values for the Clark Fork mainstem indicate the upper Clark Fork is valued at about one-half the middle river. The lower river value is the highest, but data for this segment include tributary data that undoubtedly influenced the results. The upper Clark Fork is valued at a fraction of the more popular fishing streams such as the Big Hole, Bitterroot, and Blackfoot. The sum total value of stream fishing in the Clark Fork Basin is estimated to be approximately $8.1 million. Lake fishing in the basin was estimated to be worth an additional $2.6 million. The authors of the economic evaluation consider these values to be highly conservative but useful measures of the relative economic importance of sport fishing in Montana. TABLE 2-22. NET ECONOMIC VALUE OF THE CLARK FORK AND SELECTED MONTANA RIVERS Stream Value/ Day Site Value (in thousands of dollars) Lower Clark Fork (includes tribs.) Middle Clark Fork (mainstem) Upper Clark Fork (mainstem) Bitterroot (mainstem) Blackfoot (mainstem) Rock Creek (mainstem) Madison Big Hole State Total $64.51 $ 1,370 30.27 921 23.97 421 $32.41 $ 1,816 65.30 1,880 61.82 1,724 $75.16 $ 8,171 61.82 1,724 $57,081 Source: Duf field et al. 1987. 2-40 CHAPTER 3 ENVIRONMENTAL ISSUES AND PROBLEMS This chapter outlines current environmental issues and problems in the Clark Fork Basin. While water quality problems have often been the focus of discussion in the past, serious water quantity issues in the basin need to be addressed as well. Many of the environmental problems identified in this report occur throughout the drainage. However, the nature and severity of the problems vary in the three river segments. The most critical issues in the upper basin are heavy metals contamination of surface and ground water, soils, and sediments; seasonal dewatering of the mainstem and tributaries; and high nutrient inputs that result in excessive algae growth. In the middle river segment, the main concerns are industrial and wastewater treatment plant discharges that contain nutrients and toxic compounds; a poor-quality fishery in some reaches; seasonal dewatering of tributaries; and loss of aesthetic qualities. The lower river's problems stem largely from the flow regime and water level regulation in the three reservoirs, which has resulted in poor fisheries. Other concerns include nutrient con- centrations, nuisance algae and aquatic weeds, and the threat of eutrophication in Lake Pend Oreille, Idaho. The chapter begins with a discussion of the issues of water rights and instream flow reservations. Sections on the status of Superfund investigations, metals-contaminated lands, surface water quality, eutrophication and nutrients, nonpoint source pollution, ground water quality, and fisheries, recreation, and aesthetics follow. WATER RIGHTS Introduction The 1979 Montana Legislature enacted legislation modifying the current statewide general adjudication. All water-right holders, including those in the Clark Fork Basin, were required to file claims on their pre-1973 water uses before April 30, 1982, with the DNRC. Those entities claiming Indian and non-Indian federal reserved water rights had the option of either submitting claims to the DNRC by the April 30, 1982 deadline or initiating negotiation with the 3-1 Reserved Water Rights Compact Commission. This commission has the authority to negotiate the quantification of Indian and non-Indian federal reserved water rights. Negotiated compacts, after being ratified by the Montana Legislature and tribal governing body, would be included in the appropriate preliminary and final decree as part of the statewide general adjudication. The 1973 Water Use Act gave the DNRC responsibility for approving provisional water use permits and changes to water rights. A provisional permit is a right to beneficially use water where the right has been acquired through application to and approval of the DNRC. The applicant must show that water is available and no adverse effect will result to senior users before a provisional permit cna be administra- tively granted. Similarly, a change in place of use, purpose of use, point of diversion, or place of storage can be administratively authorized for perfected water rights. The DNRC will authorize changes in water rights if the applicant shows adverse effect will not result to other users and the proposed change is still a beneficial use of water. The 1973 Water Use Act also required that DNRC develop a centralized records system that included both existing and permitted water rights. The computerized records system established by the DNRC contains a variety of specific information on certain types of water rights or summary information on water rights by drainage basin. Information on water availability for future development within specific drainage basins is not easily obtainable. Many variables, including water use system efficiencies, the magnitude and timing of return flows, variations in the timing of withdraw- als and applications, storage rights, changing hydrologic and meterologic conditions, and the magnitude, location, and seniority of water rights affect the supply available at any given time. However, such information is essential for management of water resources in the future. Pre-1973 Water Rights Claimed Through Statewide Adjudication A summary of the number of pre-1973 claims for major water uses by drainage basin has been compiled in Table 3-1. A number of claims were submitted after the filing date, and their legal status is unknown. The pre-1973 water right claims submitted as part of the general adjudication were computer sorted from the DNRC's centralized records. Six general types of water use were identified — hydropower, fish and wildlife, municipal, irrigation, rural domestic, and other. The amount of water claimed for each type is listed in Table 3-2. Because 3-2 TABLE 3-1. NUMBER OF PRE-1973 WATER RIGHTS CLAIMED FOR MAJOR WATER USES IN THE CLARK FORK SUBBASINS (JUNE 24, 1985) Major Water Uses Subbasins Stock I rrigation Domestic Other Total Middle Fork Flathead 3 11 85 79 178 South Fork Flathead 0 1 34 89 124 Swan 60 142 286 69 557 Lower Flathead 1,143 1.133 534 161 2,971 North Fork Flathead, 548 1,470 2,493 481 4,992 Stillwater, and Flathead Lake Flint Creek-Rock Creek 551 723 196 241 1,711 Blackfoot 1,490 953 640 535 3,618 Upper Clark Fork 1,665 2,027 452 508 4,652 Bitterroot 2,857 5,015 545 490 8,907 Middle Clark Fork 543 977 402 537 2,459 Lower Clark Fork 296 322 368 182 1.168 9,156 12,774 6,035 3,372 31,337 Source: DNRC 1985. TABLE 3-2. THE QUANTITY OF WATER CLAIMED FOR MAJOR WATER USES IN THE CLARK FORK BASIN Number of Flow Rate Volume Acres Use C I a i ms (cfs) (AF) Irrigated Hydropower 93 203,568 Fish & Wildlifi e 533 220,137 Municipal 117 548 276,469 Irrigation 10,961 329,393 62, ,240,779 1,937,721 Rural Domestic 3,063 829 1, ,775,115 Other 781 15,548 15.925 770,400 _L 66, .936.932 ,229,795 Totals 1,937,721 (Consumptive) 346,695 (Nonconsumptive) 423,705 Source: DNRC 1988b. Note: The total number of claims referenced in Table 3- 1 does not equal the number of claims tallied in Table 3-2 because diversion information was incomplete on some of the claims accounted for in Table 3-1. Claims with incomplete diversion data were not included in Table 3-2. 3-2a hydropower and fish and wildlife are primarily nonconsumptive uses, the water can be re-used to satisfy appropriations downstream and/or nonconsumptive appropriations upstream. By definition, consumptive water rights include appropriations of water withdrawn from the stream or ground water profile and used generally outside an aquifer or stream channel. Consumptive uses usually affect the flow of the river by causing a certain depletion. Water that does return to the stream may not do so in a timely and predictable manner. The information in Table 3-2 suggests that the amount of water claimed would exceed by several times the normal flow or volume of the Clark Fork. The number of claimed irrigated acres exceeds by about four times the 400,000 acres refer- enced in Chapter 2. These statistics indicate that con- siderable overestimating of water use occurred during the claim filing as part of the general adjudication of the Clark Fork. One reason that the number of acres associated with adjudication claims is greater than the DNRC's estimate of actual acreage in use is that the same irrigated acreage has been claimed under more than one water right. Hydropower There are several large hydropower projects in the Clark Fork Basin. These include the Bureau of Reclamation's Hungry Horse Dam on the South Fork Flathead River; the Montana Power Company's Kerr Dam on Flathead Lake and Thompson Falls Dam on the lower Clark Fork; and Washington Water Power Company's Noxon Rapids and Cabinet Gorge dams on the lower Clark Fork. The hydropower claims for the five largest Montana facilities are: Claimant River Flow Bureau of Reclamation South Fork 55,156 cfs (Hungry Horse) Flathead Washington Water Power Co. Lower Clark Fork 35,000 cfs (Noxon Rapids) Montana Power Company Lower Flathead 14,540 cfs (Kerr) Montana Power Company Lower Clark Fork 11,120 cfs (Thompson Falls) Montana Power Company Middle Clark Fork 2,000 cfs (Milltown) 3-3 Instream Flow Rights In 1969, the Montana Legislature passed a law that allowed the Montana Fish and Game Commission to appropriate water for instream flows in 12 "blue ribbon" streams. Section 89-801 RCM 1947 (Chapter 345, laws of 1969) is the authority for these appropriations. In the Columbia Basin, these streams were Rock Creek near Missoula, the Blackfoot River, and the Flathead River and its north, middle and south forks. These appropriations were completed by the Commission in December 1970 and January 1971 under the water law procedures of that time and became known as "Murphy Rights," after the sponsor of the legislation. This legislation was repealed with the passage of the Water Use Act of 197 3 that created the water reservation process. Rock Creek and the Blackfoot River are the only Murphy Rights streams in the portion of the basin considered in this report. Those rights are described below. Rock Creek (near Missoula) . Rock Creek has an instream flow right with a priority date of January 6, 1971, from the mouth to Ranch Creek (14 miles), and January 7, 1971, from Ranch Creek to the headwaters (42 miles) . The following flow quantities were claimed under Senate Bill 76: Stream Reach Mouth to Ranch Creek (14 miles) Ranch Creek to headwaters Period of Flow Volume the Year fcfs) fAF) 7/16-4/30 250 143,272 5/1-5/15 454 13,504 5/16-5/31 975 30,935 6/1-6/15 926 27,544 6/16-6/30 766 22,785 7/1-7/15 382 11,363 7/16-4/30 150 85,963 5/1-5/15 454 13,504 5/1-6-5/31 975 30,935 6/1-6/15 926 27,544 6/16-6/30 766 22,785 7/1-7/15 382 11,363 Blackfoot River. This stream has an instream flow right with a priority date of January 6, 1971, from the mouth to the Clearwater River (34 miles), and January 7, 1971, from the Clearwater River to the north fork of the Blackfoot River (18 miles) . The following flow quantities were claimed under 3-4 Senate Bill 76: Period of Flow Volume Stream Reach the Year rcfs^ fAF) Mouth to Clearwater River 9/1-3/31 650 273,257 (34 miles) 4/1-4/15 700 20,822 4/16-4/30 1,130 33,612 5/1-6/30 2,000 241,926 7/1-7/15 1,523 45,302 7/16-8/31 700 65,241 Clearwater River to north 9/1-3/31 360 151,343 fork of the Blackfoot 4/1-4/30 500 29,475 (18 miles) 5/1-5/15 837 24,897 5/16-6/15 1,750 107,578 6/16-6/30 1,423 42,327 7/1-7/15 848 25,224 7/16-8/31 500 46,601 Other Claims. Under Section 85-2-223 MCA, the DFWP filed an instream flow claim on the Bitterroot River as the exclusive state representative of the public to establish a prior and existing public recreational use of these waters. use. A priority date of July 1, 1970, is claimed for this The following instream flows were claimed: Stream Reach Mouth to Stevensville Bridge 10/1-4/30 Stevensville Bridge to Sleeping Child Creek Sleeping Child Creek to junction of east and west forks Period of Flow Volume the Year fcfs) rAF) 10/1-4/30 900 378,356 5/1-6/30 7,700 916,146 15,000 29,745 (1 day) 7/1-9/30 600 109.462 1,433,709 10/1-4/30 500 210,198 5/1-6/30 5,500 654,390 11,000 21,813 (1 day) 7/1-9/30 300 54,731 941,132 10/1-4/30 350 147,139 5/1-6/30 3,000 356,940 6,000 11,898 (1 day) 7/1-9/30 250 45,609 561,586 3-5 In addition, recreational claims related to fish and wildlife have been filed on 11 lakes in the Clark Fork Basin below Kerr Dam. One lake is a pothole on the Ninepipe Wildlife Management Area and the other ten lakes are in the Blackfoot drainage. The following is a list of the claims: Flow Volume Claimed Unnamed pothole rcfs fAF/Y) Priority Date 1. 2.0 15.0 5-4-62 Ninepipe WMA 2. Brown • s Lake 50.0 7,273.0 5-14-28 3. Clearwater Lake 25.0 10,399.2 9-30-36 4. Harper ' s Lake 5.0 273.2 5-24-33 5. Lake Alva 500.0 88,013.0 9-5-28 6. Lake Inez 1.5 101,936.0 8-7-28 7. Placid Lake 800.0 104,741.0 9-15-28 8. Rainy Lake 300.0 23,105.0 5-7-31 9. Salmon Lake 2 ,800.0 242,749.0 9-13-28 10. Seeley Lake 1 ,500.0 203,091.0 9-20-28 11. Upsata Lake 5.0 1,477.9 5-27-58 Status of Statewide Adiudication A total of 31,337 claims were filed in the 13 subbasins of the Clark Fork drainage. Temporary preliminary decrees have been issued in seven of the 13 subbasins as part of the statewide general adjudication (Table 3-3) . A temporary preliminary decree (which precedes a preliminary decree) does not include Indian and non-Indian federally reserved water rights. The negotiated reserved water rights are required by statute to be included in a preliminary decree. A total of 10,862 claims have been incorporated in temporary preliminary decrees in seven subbasins. Temporary preliminary decrees have yet to be issued in six subbasins that affect 20,488 claims. The DNRC is providing claim examination assistance to the Montana Water Court by identifying certain issues and factual discrepancies related to the claimed historic water use. From 1982 through 1985, the DNRC followed a set of verification procedures that were authorized by the Water Court. These procedures were not open to public inspection and comment during their drafting and implementation. In addition, the rules were frequently changed by the Water Court as they were being applied by the DNRC. 3-6 TABLE 3-3. TEHPORARY PRELIMINARY DECREE ISSUANCE DATES, CLARK FORK SUBBASINS Subbasin Name Issue Date C I a i ms Submi tted Total Claims Decreed Lower Clark Fork 2-28-84 1,168 1,128 Flint Creek-Rock Creek 3-29-84 1,711 1,699 Middle Fork Flathead 8-09-84 178 200 South Fork Flathead 8-09-84 124 124 Swan 8-09-84 557 633 Middle Clark Fork 3-05-85 2.459 2,486 Upper Clark Fork 5-17-85 4,652 4,592 Lower Flathead 2,971 North Fork Flathead, Stillwater, and Flathead Lake 4,992 Blackfoot 3,618 Bitterroot 8.907 31,337 10,862 Source: DNRC 1988b. A petition for writ of supervisory control of the Water Court was filed before the Montana Supreme Court in July 1985. The petition questioned the accuracy and validity of the decrees, charged due process violations, and alleged substantive errors in the adjudication. Before the Supreme Court ruled on the petition, a stipulation was negotiated out of court and signed by the Water Court and several parties agreeing to resolve the petitioned allegations. Among other things, the stipulation called for new procedures for examining pre-1973 water right claims. The stipulation also confirmed what assistance the DNRC would provide to the Water Court in the adjudication process. The DNRC would factually analyze water right claims for accuracy and completeness and identify issues. The issues would include apparent factual discrepancies that appear to have uncertain support from historical evidence. The legal and due process considerations would not be issues reported by DNRC as part of their assistance to the Water Court. The stipulation also described how the DNRC's analysis would be incorporated into the Water Court's decrees. In response to the stipulation, the DNRC drafted a set of procedural rules for examining water right claims. The Montana Water Court ordered the DNRC to refrain from adopting the rules under the Montana Administrative Procedures Act (MAPA) . The Water Court, as the judicial authority for the 3-7 general adjudication of water rights, claimed autocratic control over all adjudication activity and preferred to adopt the administrative rules as judicial rules. This issue went before the Montana Supreme Court. On March 31, 1986, the Supreme Court decided the claim examination procedures were judicial in nature and so reserved for the Supreme Court. On that basis, the Supreme Court adopted the rules with a notice and review similar to the MAPA process. The DNRC, working with the Water Court, submitted a draft of the rules to the Supreme Court for adoption on April 30, 1986. The Supreme Court issued these Water Rights Claim Examination Rules with an effective July 15, 1987, date for implementation. A review period until March 15, 1988, was provided to allow comment and suggestion on the application and structure of the rules. A final ruling is pending. The Supreme Court's Water Rights Claims Examination Rules are expected to provide a markedly improved opportunity for an equitable and thorough claims examination. The rules are intended to provide a standard format for the DNRC to provide assistance to the Water Court. The new rules will also improve the consistency of claims examination. The Supreme Court's opinion adopting the examination rules, however, did not decide due process and separation of judicial and executive power concerns. The rules do not address the consistency of previously issued temporary preliminary decrees with the new standards. Following adoption of the rules by the Montana Supreme Court, several parties, such as the U. S. Department of Justice, the Montana Department of Fish, Wildlife and Parks, and the Montana Power Company, asked the Water Court to have the DNRC prepare reports comparing the former claims examination with the recently adopted Supreme Court proce- dures, and in some cases to order actual reexaminations. The Water Court denied requests for reexamination and took requests for comparison reports under advisement but ordered none. The parties feel that the new rules may afford a factually prudent examination that is more consistent, thorough, equitable, and accurate than the previous Water Court verification procedures. At the current rate of claims examination and with the current level of staffing, the DNRC believes that it will require until the year 2000 to examine the remaining non- decreed claims within the Clark Fork drainage. In 1987, the DNRC estimated that it would take four and one-half years to reexamine the Clark Fork drainage claims previously entered into temporary preliminary decrees, using procedures consistent with the new examination rules (Larry Holman, DNRC, Helena, personal communication, April 1988) . 3-8 The timetable for the final adjudication of all water rights in the Clark Fork drainage is uncertain for several reasons. First, it is uncertain if and when compacts regarding Indian and federal reserved rights will be reached. Second, because of the controversy over the adequacy of the present adjudication, a legislative study (Water Policy Committee) of the adjudication by out-of-state consultants is presently underway. That study, due to be completed in the late fall of 1988, is to recommend possible legislative changes. It is unclear at this time what changes, if any, might be recommended or enacted and how they might affect the timing of the adjudication. Third, litigation over the adequacy of the adjudication continues and could increase. The federal government has recently been before the Water Court claiming that the present adjudication is not adequate as currently applied. Additionally, the Confederated Salish and Kootenai Tribes are currently before the Montana Supreme Court arguing that the Supreme Court's adoption of the new examination rules, which allow total control of the DNRC by the Water Court, violates due process and separation of powers principles. Provisional Permits Issued Since 1973 The Montana Water Use Act of 1973 requires that an application for a provisional water use permit be filed with DNRC for any new or additional development of water made after July 1, 1973. Applications for permits can be made at the DNRC Water Rights Field Offices located in Helena, Missoula, and Kalispell. Before the Department can issue a provisional permit, the applicant must show that the new use will not adversely affect senior users holding water rights. The statutes (85-2-311, MCA) outline the criteria that must be met before a provisional permit can be issued. Table 3-4 identifies the number of provisional permits issued since 1973 for each major category of use. Irrigation accounts for the largest percentage of the diversionary uses of surface water. The number of domestic use permits issued is increasing because of many new rural subdivisions. Indus- trial uses include both commercial and mining. There were a number of provisional permits issued for fish and wildlife purposes, and many of these were for fish farms. The largest new-user category is hydropower. However, it should be noted that 15,000 cfs of the total flow rate under the hydropower category is associated with the provisional permit issued to the Washington Water Power Company. The remaining 26 provisional permits for 441 cfs are for small-scale hydro- power developments. Because of the projected need for additional power during the early 1980s and tax-related 3-9 financial incentives, there was considerable interest in developing small-scale hydropower facilities. TABLE 3-4. PROVISIONAL WATER USE PERMITS ISSUED SINCE 1973 Purpose Number of Permits Total Flow (cfs) Volume AF/Y Acres Irrigation Industrial 765 53 720.0 73.0 73,677 28,325 35,664 Domestic 707 26.0 1,520 255 Municipal Hydropower* Fish & Wildl ife 2 27 150 3.7 15,441.0 130.0 2,142 180,282 67,599 790 Other 80 9.0 1,900 76 * A water permit for 15,000 cfs was granted to Washington Water Power, which, when added to its existing water right flow of 35,000 cfs, allows the hydroelectric facility to be operated at full capacity. Source: DNRC 1988b. Ground Water Permitting Process The interaction of surface and ground water raises some difficult questions about basinwide management in the Clark Fork system. Generally, DNRC's ground water permitting decisions consider the surface water effects of ground water withdrawals only where the relationship is straightforward and the interaction a proximal one. Most commonly, this means that if it is shown that a ground water diversion is inducing recharge of an aquifer from a surface water source (or "pumping surface water") , then the ground water proposal will be viewed critically with regard to surface water avail- ability. In the absence of such readily calculable inter- actions, DNRC may notify controlling surface water users in the basin, but beyond that step it will not normally analyze ground water applications in the context of surface water availability, instream flows, or surface water quality objectives. Aquifers constitute one flowpath component by which water moves from the headwaters to the mainstem Clark Fork and beyond. Most major aquifers in the Clark Fork Basin receive recharge from the surface environment (precipitation, 3-10 losing reaches of tributary streams, or the Clark Fork itself) , and most discharge along relatively short flowpaths back to the surface environment. Aquifers respond to new ground water withdrawals (wells) with potentiometric adjustments that either increase inflow to the aquifer or decrease discharge to the surface environment or both. Some part of this response may involve increased inflows from other aquifers with more remote relationships to the basin's surface water environment. More often, the major hydrologic response is likely to be an eventual adjustment of surface water flows in some other part of the system. The fact that DNRC's ground water permitting has not always reflected these physical realities can be attributed to two factors. First is the information requirement for realistically assessing the overall hydrologic consequences of a given level and manner of ground water development. This level of understanding is only achieved for a given aquifer system through an intensive research program. Often, complex aquifer responses are only predictable through the creation of computer simulations, which in turn rest heavily on an adequate base of regional field information. Because DNRC does not collect much of this type of data itself (viewing it as a research function appropriately left to other agencies and the university system) , the opportunities for the ground water permitting process to meaningfully consider integrated hydrologic implications are limited by others' research priorities and DNRC's ability to direct those priorities. The second factor is the comparative scale of existing ground water withdrawals with respect to surface water use in the major hydrologic basins. In the Missoula Aquifer, for instance, annual withdrawals for all purposes average about 60,700 acre-feet (Missoula City-County Health Department 1987) , some of which returns to the aquifer as water main leakage, septic system discharge, and other recharge flowpaths. This appears minor in relation to the discharge of the Clark Fork, which averages 2.2 million acre-feet/year at a point upstream of the Missoula Aquifer's recharge area. However, the generous hydraulic characteristics of the Missoula Aquifer present the possibility of substantially increasing ground water withdrawals on a sustainable basis. Ground water withdrawals amounting to several percent of the raainstem Clark Fork's flows seem significant where consump- tive and instream priorities, including surface water quality, compete for available flows. Similar arguments could be made regarding other aquifers in the basin that are capable of supplying high yields to wells, as most have significant recharge/discharge relationships with the basin's streams. 3-11 The correlation between water management and physical ground water behavior could be improved if water use permitting recognized the unity of water resources in the basin's streams and principal aquifers. Surface water permitting would have to recognize aquifer recharge among the significant "instream" water needs and ground water permit- ting would have to recognize effects on downgradient gaining streams, though the consequences may seem minor on an individual project basis and remote at the time of permit- ting. In a practical sense, this means adopting as manage- ment tools the research data and aquifer model derived from areas where such work has been done. Just as importantly, the permitting process needs to recognize the concept of conjunctive surface water and ground water management. This concept provides the framework in which to incorporate detailed information on regional aquifer behavior as it accumulates. Indian and Non-Indian Federal Reserved Water Rights U. S. Forest Service Rights Claimed by the U. S. for National Forest Purposes . Water claimed by the United States on behalf of the USDA Forest Service in the Clark Fork Basin is both consumptive and nonconsumptive. These claims are based upon "Federal reserved rights" and Montana water laws. Reserved rights are established when lands are withdrawn from the public domain for a federal purpose. At that time, appur- tenant water, then unappropriated, is implicitly reserved to the extent necessary to accomplish those purposes. The extent of these "rights" and the specific purposes of the reservation is an ongoing litigative process and is yet unclear. Consumptive claims are a minor part of the U.S. Forest Service reserved water rights in the Clark Fork Basin. However, claims have been filed with the Montana Water Court for many uses, such as: stock water, summer homes, recrea- tional facilities, and Forest Service work facilities. Federal reserved rights claimed by the Forest Service for national forests in the Clark Fork Basin are generally grouped into two categories — channel maintenance flow needs and other resource needs. Both of these flow needs are nonconsumptive, and the water claims would be available to other users below the forest boundaries. Channel maintenance flows are needed to maintain natural stream channel systems and are an integral part of sound watershed management. These flows help to maintain streambank stability and 3-12 riparian vegetation and provide for sediment transport. Channel maintenance flows are similar to maintaining irrigation ditches so that irrigation water can flow freely. While the irrigator uses mechanical means to keep his ditches clean, the Forest Seirvice aims for channels that maintain themselves naturally through instream flows. Flows for other resource needs include purposes as set forth by Congress for wild and scenic rivers, fisheries, wildlife, etc. Flows for the various purposes will be negotiated with the Reserved Water Rights Compact Commission. Status of Negotiation with Reserved Water Rights Compact Commission. The Forest Service is the only USDA agency with reserved rights claims in the Clark Fork Basin. Negotiations between the Reserved Water Rights Compact Commission and the USDA have been initiated. Although this negotiation is currently inactive, the USDA negotiator is still optimistic that a compact can be developed by the parties. Current Water Related Litigation. In United States v. Jesse, the federal government asserted that lands withdrawn for the Pike and San Isabel national forests in Colorado included the water necessary to maintain minimum instream flows. The claim was based on a definition of favorable conditions of water flow as identified in the Organic Administration Act of 1897. The act requires streamflows necessary to maintain stream channels so that hydrologic function is not impaired. The decision against the United States by the District Court was reversed and remanded by the Colorado Supreme Court on the basis of recent advances in the science of fluvial geomorphology. While the Colorado Supreme Court has stated in United States v. City and County of Denver that the Organic Act did not implicitly reserve water necessary to maintain instream water flows in national forests, it was also not excluded. Because the United States has not attempted to prove instream flow rights in previous litigation, the court found that the matter had not been litigated and that the Forest Service should have its day in court. While the court did not give the Forest Service instream flow rights, it has provided the opportunity to prove the case. ■ g ■ ft 3-13 The Confederated Salish and Kootenai Tribes of the Flathead Reservation The Flathead Indian Reservation, located in Lake, Sanders, Flathead, and Missoula counties, consists of 1,242,969 acres, over half of which is tribal or individual trust land. The population on the reservation is approxi- mately 4,550 Indians and 16,000 non-Indians. The BIA, on behalf of the Tribes, made claims for Indian water rights, all appropriative water rights previously acquired, and water rights appurtenant to lands owned by the Confederated Salish and Kootenai Tribes as required by the statewide adjudica- tion. The generic claims are for "all water arising upon, flowing by, through, or under the reservation, necessary for purposes of the reservation. . .as of the date of the reserva- tion, and/or from time immemorial based on the tribe's aboriginal ownership of the lands and waters that now comprise the reservation, whichever is earlier." The BIA has also submitted claims for instream flows in the Flathead Basin necessary to protect the Tribes' aboriginal rights recognized and guaranteed pursuant to the treaty of Hellgate, Montana, July 16, 1855. A major concern of non-Indians on this reservation is the effect the tribal water rights will have on non-Indian water rights and uses associated with the Flathead Indian Irrigation Project. The tribes have met a few times with the Reserved Water Rights Compact Commission over the past ten years, but little progress has been made. The Compact Commission has made no attempt to meet with the Confederated Tribes since 1985 because of the legislature's directive to focus the adjudica- tion on the Milk River Basin. Although the Tribes have chosen to proceed with negotiation of their reserved rights, litigation in federal court has occurred over their claimed water rights. In 1985 the Tribes determined that drought conditions would diminish flows and decrease water levels in the reseirvation's rivers and reservoirs. The Tribes sought to prevent irreparable damage to the tribal fisheries by enjoining the BIA from distributing waters to the Flathead, Mission, and Jocko Irrigation Districts in such a manner as to deplete the streams and reservoirs. The Joint Board of the Flathead, Mission, and Jocko Irrigation Districts (Joint Board) intervened. After the Federal District Court issued a temporary restraining order in the favor of the Tribes, the parties entered into a stipulation that established minimum streamflows and reservoir water levels for the 1985 irriga- tion season and set the procedure for establishing future minimum flows and water levels. The case was later dismissed as moot. 3-14 In 1986 the Joint Board took exception to the BIA's new operating strategy that provided greater protection for tribal fisheries by ensuring minimum streamflow and minimum reservoir levels. The Joint Board brought a suit for injunctive relief (in essence arguing for an eguitable sharing of the water) , and this time the Tribes intervened. The Federal District Court issued a temporary restraining order against the BIA and after a hearing issued a prelimi- nary injunction enjoining the BIA from continuing to deliver water according to the new operating strategy. The Federal District Court counseled that the BIA must be guided by the principle of "just and equal distribution" of "all waters of the reservation." On appeal the Ninth Circuit Court of Appeals reversed the District Court, holding that "just and equal distribution" applied by a certain federal statute only where all of the parties derived their rights from the same source and all showed the same priority date, but did not apply on the Flathead Reservation to the extent the Tribes exercised the aboriginal fishing rights and where treaty language clearly preserved those rights and the water needed for them. The Ninth Circuit Court ruled: ...it was error, therefore, for the district court to hold that water claimed under potentially prior tribal fishing rights must be shared with junior appro- priators, and that the requirement of equitable sharing could be imposed without addressing the Tribes' claim of aboriginal fishing water rights. The Ninth Circuit concluded that because any aboriginal fishing rights secured by treaty are prior to all irrigation rights, neither the BIA, nor the Tribes are subject to a duty of fair and equal distribution of reserved fishery waters. Only after the fishery waters are protected does the BIA have a duty to distribute fairly and equitably the remaining waters among irrigators of equal priority. It is important to note that this case did not amount to an adjudication of the Tribes' water rights. It did, however, give credence to those claimed rights and sought to protect them. The extent of those rights remains to be concluded, either in a compact or an adjudication through Montana's general stream adjudication. 3-15 INSTREAM FLOW RESERVATIONS Introduction A water right for instream beneficial use for fish, wildlife, and recreation may be obtained only through the water reservation process. Since the implementation of the 1973 Water Use Act, the DFWP has objected to the issuance of water use permits where such permits were thought to adversely affect instream flows necessary to protect fish and wildlife. The DNRC has determined that objections to new water use permits are invalid unless the objector has a water right that would be adversely affected. DNRC has determined that the DFWP has valid objections only on those streams where it has instream flow reservations or Murphy Rights. DFWP has no such reservations in the Clark Fork Basin and has Murphy Rights only on Rock Creek (near Missoula) and the Blackfoot River. Water reservations will not make more water occur in streams. They only establish a water use priority date for fish and wildlife relative to other water right uses. They prevent further dewatering through use of the appropriation doctrine "first in time is first in right," and can affect only those water users whose priority dates are later than those of the reservations. The reservations' priority dates are, by law, effective only after the reservations are granted by the Board of Natural Resources. Some proponents of instream flow protection have suggested that Montana should recognize the public trust doctrine as part of the state water management policy. In a state that recognizes the doctrine, its agencies, courts, or both, have the authority to reexamine and modify existing water uses to protect public interests. The state, as a trustee of natural resources, has a responsibility to protect public uses whenever feasible. If the doctrine were accepted in Montana, the state would screen and condition all water appropriations on public interest criteria. The following sections explain why instream flows are important for the Clark Fork Basin. Hvdropower Rights The Washington Water Power Company has a water right of 50,000 cfs at Noxon Rapids Dam, of which 15,000 cfs is by a provisional water use permit issued in 1976, and 35,000 cfs is by a right filed in 1951. A flow of 50,000 cfs equals more than 36 million AF per year — over twice the average 3-16 annual discharge of the river at Cabinet Gorge Dam (about 16 million AF) . These rights and the rights at the other hydropower projects could, theoretically, preclude, or at least limit, the issuance of additional upstream consumptive water use permits. However, in addition to the 1976 permit issued to the Washington Water Power Company, DNRC has issued, since 1973, 1,683 water use permits upstream of Noxon Rapids Dam, for a total of 380,589 AF of water (as of September 1986) . Approximately 20 percent of this total volume has been appropriated for irrigation purposes. Of the 1,683 water use permits, 214 permits totaling 95,436 AF have been issued in the upper Clark Fork Basin above Milltown Dam. The downstream hydropower water rights holders have not objected to the issuance of water use permits by DNRC nor to the use of water by the junior appropriators. Studies now underway by BOR and DNRC may clarify existing circumstances and stimulate new activity in those areas. DNRC may intervene in the relicensing and amending of operating licenses issued by the Federal Energy Regulatory Commission (FERC) with the intent of subordinating the hydropower water rights to upstream consumptive use (primarily irrigation) if state interests are not adequately addressed. DNRC is investigating whether water exchanges between the large hydropower projects would allow increased consump- tive use while still satisfying existing hydropower rights. An example of such a water exchange would be the transfer of stored water from Hungry Horse Reservoir to Noxon Rapids to satisfy Noxon 's hydropower rights, while at the same time •• ^t' allowing continued issuance of consumptive water use permits in the upper Clark Fork Basin. A recent study by the BOR (1988) suggests that this may not be feasible and even if it were, dewatering problems would continue in other parts of the basin. In view of these circumstances, it has not been practical or prudent to rely on the downstream hydropower water rights to protect instream flows in the Clark Fork Basin. Fish. Wildlife, and Aquatic Resources Fish, wildlife, and other living organisms depend upon the flow of the Clark Fork and its tributary streams for their basic habitat requirements. Due to the serious and chronic nature of the pollution in the upper Clark Fork, adequate streamflows must be maintained to prevent further deterioration in water quality and to help protect the investment being made to restore the river's water quality. 3-17 The reservations are needed to maintain fish habitat, aquatic insect populations, and other aquatic plant and animal life that sustain fish. Channel configuration in conjunction with flow provides the only living space available to aquatic organisms in streams. Adequate streamflows are necessary for maintaining spawning and rearing areas, providing suitable shelter, and producing food organisms, including aquatic macroinvertebrates and forage fish. In an aquatic ecosystem, water quantity is as critical a component of fish habitat as is water quality. Water Quality Benefits Surface water in the upper Clark Fork suffers from dramatic water pollution problems. The most serious problems are the result of decades of mining and smelting activities in the headwaters. There are massive deposits of mine tailings in the Butte area, along Silver Bow Creek, and at the sites of the Anaconda Smelter and Opportunity Pond system. Runoff entering Silver Bow Creek from these areas is acidic and has high concentrations of metals. Silver Bow Creek is treated with lime at the Warm Springs Ponds on a seasonal or streamflow basis to raise the pH and precipitate the metals that are in solution. In addition to mine tailings in the Butte-Anaconda area, there are substantial deposits of mine tailings in the riparian zone and floodplain of the upper Clark Fork itself. These deposits are chronic sources of metal contamination to the upper Clark Fork and they may contribute acutely toxic concentrations of metals during periods of precipitation and runoff. There are several reasons why water pollution in the Clark Fork is related to flows: 1) high streamflows greatly increase metal concentrations by eroding mine tailings that have been deposited in the floodplain. Some of the highest metal concentrations in the Clark Fork occur during spring runoff; 2) flows in Silver Bow Creek that exceed the capacity of the Warm Springs Ponds are bypassed directly into the upper Clark Fork; and 3) low-flow conditions can aggravate water quality problems by reducing the amount of water available for dilution of industrial and municipal discharges and nonpoint pollution. Montana law does not recognize dilution of wastewater as a beneficial use of water. As new provisional water use permits are issued in the basin, individuals holding wastewater discharge permits may be affected but they do not have a legal basis for objecting to the new permit applications. Current and future industrial and municipal waste discharge permits could be affected by chronic low-flow conditions, i.e., the allowable amount of 3-18 discharge would be reduced to accommodate the reduction in dilution water of the receiving stream. However, adjusting wastewater discharges in permits in response to chronic low- flow conditions would be a slow process and would rely on accurate, long-term stream discharge measurements for calculating 7-day, 10-year low flows. It is important to recognize that industrial and municipal wastewater discharge permits do not provide water rights. Water use permits allow diversion and consumption of water without regard to impacts on water quality. (An exception is for large diversions for which the applicant must show compliance with specific public interest criteria.) Reduced streamflows during the normal low-flow period can affect the quality of water that is necessary to sustain aquatic organisms. Other possible consequences of this lowered streamflow are higher water temperatures, increased amounts of dissolved solids, increased nutrient concentra- tions, and lower dissolved oxygen levels. Reduced stream- flows seasonally limit the ability of the Clark Fork to assimilate its present pollution load. A reduction in tributary streamflows will reduce the current capability of tributary streams to discharge clean water into the Clark Fork for dilution of pollutants. An instream flow reservation can help to prevent the further deterioration of water quality during low-flow periods. A reservation can also help to provide adequate flows for enhanced aquatic populations that may occur in the future as existing pollution problems are reduced or, hopefully, eliminated. Water Supplv Instream flows in the Clark Fork Basin are also important from a water supply standpoint, particularly in the Missoula area. The Clark Fork provides about 46 percent of, the annual recharge to the Missoula Aquifer, which is the major source of drinking water for the Missoula area. It also supplies water to over 30 small community water systems and to several industrial users. An estimated 65,000 of Missoula County's 77,400 residents use water from the Missoula Aquifer (Missoula City-County Health Department 1987) . Therefore, maintaining adequate instream flows in the Clark Fork is crucial to these residents and to others in the basin who derive their water from aquifers recharged by the river. 3-19 Recreation. Aesthetics, and Tourism The Clark Fork and its tributaries are important fishing and recreation areas. Montana statutes recognize this resource as worthy of protection. The fish species that would be protected by instream flow reservations contribute to the well-being of the people of Montana and visitors who enjoy the fishing opportunities Montana has to offer. In addition to sustaining existing recreation, adequate instream flows would preserve the opportunity to enhance fish populations as water quality improves. This, in turn, would result in more recreational opportunities in the future. If the instream flow reservations requested by DFWP in the upper Clark Fork Basin are not granted, the deterioration of aquatic habitat and recreational interests is inevitable. The rate of deterioration would depend upon the degree to which further dewatering would be allowed to occur. Such deterioration is already evident in the Bitterroot River drainage and in portions of the upper Clark Fork Basin. The DFWP reservations are for the amounts of water necessary to sustain the organisms without significant long- term reduction in quantity and quality. Increased water withdrawals over existing levels would, in the long run, reduce the availability of habitat and, consequently, the number of organisms that can occupy that habitat. There is a limit to the amount of water that can be removed from any stream channel without severely changing the quantity and quality of the aquatic species present or limiting the biological potential of the stream. In portions of the Clark Fork Basin, that limit has already been exceeded. Tourism for recreational purposes is rapidly becoming Montana's second-most important industry. The high quality and abundance of Montana's natural resources provide unique opportunities for fishing, hunting, boating, river running, and simply relaxing in an aesthetic environment. The City of Missoula, for example, seeks to maintain adequate flows in the Clark Fork through its riverside park and greenway and to develop a kayak racecourse in this same river reach. The tourism, recreation, and aesthetic values are directly related to the adequacy of instream flows. Reservations of instream flow are the only current means to preserve these amenities. Riparian Areas The riparian ecosystems of the Clark Fork and its tributaries are transitional zones between the aquatic and terrestrial habitats. This streamside zone of vegetation is 3-20 characterized by the combination of high species diversity, high species densities, and high productivity. Many of the trees and shrubs that dominate this zone require ground water within the rooting zones through the growing season. Fluctuations in streamflow cause concomitant fluctuations in associated shallow ground water tables. The riparian zone is ecologically important because it provides seasonal and year-long habitat for a greater number of species of wildlife than any other habitat in Montana. In addition to its rich assemblage of plants and animals, the riparian zone plays an essential role in determining the quality of the aquatic environment for supporting fish and aquatic invertebrates. Although the specific relationships among riparian vegetation and the amount and availability of ground water have not been quantified in the Clark Fork drainage, the existing plant communities and associated wildlife popula- tions require adequate instream flows for their perpetuation. STATUS OF SUPERFUND INVESTIGATIONS Introduction Although this document primarily addresses non-Superfund issues, the activities at the Superfund sites are of the utmost importance to the future of the Clark Fork Basin. Certainly, the fate of at least the upper river is inexorably tied to the outcome of Superfund. The Superfund program was created by Congress in 1980 to identify, investigate, and clean up hazardous substances that have been or may be released into the environment. EPA has initiated Superfund activities in the Clark Fork Basin primarily because of the problems left by over 100 years of mining and processing operations. Waste disposal practices have resulted in the contamination of soils and water by metals and other substances throughout a large area of the upper basin. The Superfund program provides for investigation and cleanup of hazardous wastes by either the potentially responsible party (PRP) or the government. If there is a PRP, EPA and/or the state oversees the cleanup efforts by the PRP through an administrative order. If there is no PRP, or the PRP declines to undertake the studies and cleanup efforts, EPA conducts the studies or provides funds to the state to do so. The PRP is provided the results of the studies and is asked to conduct appropriate cleanup. If the responsible party refuses, EPA may use resources from the 3-21 Superfund to clean up the site and then seek to recover up to three times the cost of the cleanup from the responsible party. If the responsible party undertakes the recommended cleanup, EPA oversees the activity through a court-ordered consent decree. Studies were initiated by EPA in 1982 to characterize the extent and severity of contamination in the headwaters area. There are currently four separate, but contiguous Superfund sites in the Clark Fork Basin (Figure 3-1) . The three in the headwaters are the Silver Bow Creek/ Butte Addition site, the Montana Pole site, and the Anaconda Smelter site. The fourth is the Milltown Reservoir site a few miles upstream of Missoula. Site histories, current status, and future activities for each site are presented in Table 3-5. Seventy-seven existing or potential contamination problems were initially identified within the four sites. The EPA, with state support, has developed a Superfund Master Plan to describe these problems and their inter- relationships, define cleanup goals and objectives, and coordinate the actions that will be taken to reach these goals (EPA and DHES 1988) . The Master Plan is intended to be a public document that briefly describes the problems at the sites and the corrective actions and schedules for dealing with the problems. Schedules for priority activities planned for the next several years are presented in the plan, which was released in October 1988. Some of the more specific objectives of the Master Plan are the following: • Communicate information on Superfund activities to all interested parties. • Identify, prioritize, and coordinate intersite activities. • Coordinate Superfund activities with other environ- mental improvement programs. • Provide for consistent and uniform data require- ments and cleanup standards for all sites. Investigations at each site must include an evaluation of the applicable and relevant or appropriate requirements (ARARs) . These evaluations are intended to determine the standards that must be achieved during cleanup. There is a strong linkage between Superfund ARARs and water quality standards in the Clark Fork Basin. Superfund actions taken 3-22 O 00 00 < a. V u u 6 CO < DQ :>^ OS c :>^ < rJ O U) X V) H a z (b o: U Ou to I on OS l-l [14 3-22a g 5 5> to OS § S M *J M fe a g g ia; (/] ^ s o. 0) •H ^ >i 1 M c § .2 r-H o o: •H b >(-( ii >-l c •H «) X S g ^ J3 O g ^ a » Jai m g -H CO -t-" tj •H T) o. +J Lj J3 •c U in T3 ■U -U 3 +j C B -5 10 0) ■<-' •H c t3 o o 0) 3 (X o ^ w T3 [^ ■*-> M 3 w 00 X +> ID cr\ >i O U M » T-H ja o fO 0) .H QO 6-1 •H S 0) » °^ ;3 ■g ^ 5 ^-' Oi U> u w (0 10 ^ ■I-' Oi oc c — - O -iJ o u c ii 8. < O +-■ >H o o S XI IV a I o ID -o 1 10 ID r-i •fJ u M x: o j<: V tJ 10 1 Oi l-l +J M u +J Li O a) 0) t*-( c i-i v> > o Q •H u rH «: T3 0) U 3 2 ■" t: a 0) to 3 I>i I— I T3 o as 3 *-■ ^-' C M >i 10 -tJ —I C C •--1 'H C C O ->-' c 10 ID 3 2 10 ID O <« Ciu C/3 3-22b £■ » CO S 0) oo s CO •H •s 4-> .-H -^ IM •H ti »H o rH u a: 01 •iH <0 V ♦J a> u u •S c ..-H o (0 «J 1 10 W iw a. a> rH u A 0 ^ 0) 2 Si (—1 •^ *j u •H g c •H « o £ 8 1 § ^ § 0) jj ^ > (0 >^ ■IJ u a A CO x: rH •a 0) (0 i 1 •H a^ c i > u 41 ^j s. ^ o ■t-f 4-* c (0 —1 § ? o (V 10 TJ •H CT > tl ii 01 u i in +J 5 M 10 -1-' u3 u a. • H w IS t>i c ^ r^ (0 00 — ( »• en w r-H 0! 8. 1-1 -s 01 U 00 "3 S" 0) * J2 oo C •-( -s a -s 0> ^ I l-l u I 3 73 O fl> 1-1 ■-( 10 0) ■♦-• C CO •H C C -rt ID 10 *-> 00 10 o> Eh »-( >-3 t-H OQ t-t to I ■H CO CO 1-1 r-i C 0) o> 2 IS 10 0) 0) > .c u <0 •H Oi c *J •H ■a 10 m 01 ft •I-' u •a: Ij ^1 o a O 0) ^ 01 m w -*-> u .c iS u a *»-* i a 5 V. §: 10 CO 0) n 1^ u u o> n 5 ? 3-22C CQ % b3 P g CO Q S >■ •c s g &3 (-H o g g o z o M E-i in rt ro -^ u 2 Eh 6- U5 M E-i CO h- 1 CO O a. % o u m 3 Hj a) -o if T3 f— I 0! u S i 3 o +-» rH » 10 'Ji Vi XI oo 5 OO V E ■rH § tJ 10 ^ u as to -»-) 10 +-» 13 >i oo X T3 *j o ^ Ji: 0) to V3 •H a; +J t-H r-l ■H f— t 0) c % 1-1 (4-1 o r-* '£ 2 U-1 4-J kM • H u u •u u o T3 ^ 1—* a) o to ■H Ul r-t L. J3 f— 1 c ^-^ o (0 hJ to 0) r-l O. +-• V a. +-> !fl £ .^ OS 8 ■s x: ■u c »-H !0 i 'A 3 >1 <1) 1 •g X) 0) u 01 4J (0 x: c s s M-i o tj o 9-1 to to ID a> to — < •H 10 r-H is +-> 01 <0 id > S 8 ^ ^ M O 10 •g to 10 a) 3 ■M T) 0) T3 W 10 O i-H n o e 3-22d w 3: o t-H >< e-i g t-H h-i U^ E- (—1 •-3 oa c/) z o t/3 E- I— ( x: I 4-> in ■g 5 S ^ . 1— I «-> -o T) oo 10 3 S OO > 01 ■I-' ♦J *J W 10 O u ^H (0 0) a> (0 4-> ^H t-t e a> ■ti ^ ■" B -H o o ".si . a s. i id S "-I o ^ o u ou >j w-i !3 tn 2 o 3 > c ae n S (0 u 1 £ >1 » ■^ - ^ •a (1) oa Q) O _ u to U (V 01 - -O M c 3 01 1? c u o X O Q -s 10 c Ol 0) 0) -o •0 (1) & •^ J^ ^ nH •H a 3 0) > ca 0) •H c -t-> +J 1 •H (0 8 cu w b 1 x: -% o tx> >—( ro 3 l-t 2 00 CI -tJ IH >■ a> 4-J -M 1 en n 1 2 § (0 o 0) 1-1 a> r-H •- *J o L< > U 10 c o •w e 1) o § 0 rH Cb a: 1 .—1 .M 4J 4) rH VI (M !3 8 •t 1-H •H g i—t a Ut 0) o II •H O C/) 1 4-» 5 4J 10 *-» CO ti I o •H +J •H rO ■4-> CO O , IV ■>-> •M C ^ ;s 3 g-'S '^ 0) S C "t-l fH JJ ■H o d. a 10 & —I -f-> c S g. ■§ o " B V 0) ^ --1 O 0) x: 1—1 C f-c a> (0 c i 8 o _ 5 i g 0) ^ 0) ♦J o > (0 IH -H 0> B. -tJ •H (0 U CO > cn 9. 3 S •H C to O ^ I & 8 0) ^ ♦J 00 (0 o\ o 10 m u 0) ■M (0 1 CO OS o J o u I oi O I— ( 3-32a TABLE 3-6. CONCENTRATIONS OF ARSENIC, COPPER, LEAD, AND ZINC IN THE COLORADO TAILINGS SOURCE MATERIAL SAMPLE TYPE/LOCATION ARSENIC COPPER LEAD ZINC iEm} Duaime et at. Tailings Center field 1987* Series (13 holes) Tailings West field Series (7 holes) Tailings East field Series (8 holes) Max — Min ... Mean — Max — Min ... Mean — Max — Min ... Mean — Max 2,960 Min 678 Mean 1,742 Max 1,550 Min 504 Mean 821 6,775 1,383 183 331 1,370 667 8,965 942 222 277 3,055 615 4,059 1,196 661 410 1.390 765 Thornell 1985 Tailings One drill hole Max 2,960 6,730 2,740 8,230 (8 intervals) Min 678 663 480 2,430 3,058 1,264 4,945 Peat One drill hole Max 1,550 14,300 14,900 22,500 (6 intervals) Min 504 1,730 6,370 13,800 6,022 9,933 17,333 Alluvium One sample from — — 188 28 300 a dri 1 1 hole Peckham 1979 Tailings 48 in auger hole 1,400 1,300 11,000 24 in auger hole 500 470 3,700 50 in auger hole 3,900 530 12,000 Bohn et al. 1979 Natural Typical value 5 20 10 50 soils Range 1-50 2-100 2-200 10-300 * These samples were analyzed using metal assay techniques rather than digestion techniques. 3-32b edge of the tailings, and construction of a drainage ditch along the southern edge of the tailings (Hydrometrics 1983a) . The ultimate fate of the Colorado Tailings will be determined by the Superfund program. The Colorado Tailings and the Butte Reduction Works (adjacent to the Colorado Tailings) constitute a separate operable unit that is being evaluated by the state and EPA. This operable unit is a fairly high priority, with Phase II activities scheduled to be underway in first-quarter FY 89. If a removal alternative were chosen, the tailings and the contaminated peat layer beneath them would have to be addressed. Old Works As mentioned in the Superfund section, the Old Works area (Figure 3-3) is the site of the first smelters in Anaconda. Nine discrete waste deposits have been identified in the vicinity of the Old Works. Waste types include tailings, black slag, heap-roast slag, and red sands (mixed slag and tailings) . Flue dust deposits are also found near the flues of the Upper and Lower Works. Combined, these wastes are estimated to cover about 326 acres (Tetra Tech 1987) . For the Stage I Remedial Investigation, Tetra Tech (1987) collected grab samples, tailings cores, and trench samples from these wastes. The ranges of selected metals concentrations in the grab samples are provided in Table 3-7. The EPA considers the Old Works area to be a high- priority operable unit due to its proximity to a housing development and Warm Springs Creek. Work plan negotiations are underway with the Anaconda Minerals Company, and work will likely begin there this fall. TABLE 3-7. RANGES OF METAL CONCENTRATIONS IN OLD WORKS GRAB SAMPLES Number of Arsenic Cadmium Copper Lead Zinc Waste Type Samples (ppm) (DPm) (ppm) (ppm) (ppm) Black slag 2 54-80 1.3-1.9 4,580-6,030 594-634 8, ,840-9,460 Red sands 2 1,200-2,170 7.7-13.3 2,160-3,170 292-618 2, ,420-4,640 Tail ings 1 1,840 8.5 3.420 459 4,510 Heap-roast slai 3 2 910-1.070 12.8-13.4 6,100-7,000 985-1,030 17, ,400-18,100 Flue material 11 68-10,400 0.9-71.5 184-37,100 17-639 46-2,140 Source: Tetra Tech 1987. 3-33 J3 CO ON 3-33a Anaconda and Opportunity Ponds Tailings from operations at the Anaconda Smelter were slurried into a series of ponds northeast of the smelter complex (Figure 3-3) . The first pond. Opportunity A, was built in 1914. The Opportunity B, C, and D ponds were constructed as needed through the next 40 years. Anaconda pond 1 was constructed in 1943, and Anaconda pond 2 was built in 1954. Together, the Anaconda and Opportunity ponds cover approximately 4,000 acres and contain an estimated 185 million cubic yards of tailings material (Tetra Tech 1987) . Wastes in the Anaconda and Opportunity ponds are relatively homogeneous compared with other wastes in the upper Clark Fork because they are almost all mill tailings generated at the smelter. However, even the materials in this system exhibit considerable physical and chemical variability due to evolving smelting processes, extensive reworking of the deposits, and variabilities in the parent ores. Average concentrations of several key trace elements are 210 ppm arsenic, 470 ppm lead, 2,030 ppm copper and 1,200 ppm zinc (Tetra Tech 1986b) . An initial remedial investigation (Tetra Tech 1986b, 1987) has been concluded for the Anaconda and Opportunity ponds. Included in the remedial investigation were waste characterization, surface and ground water studies, ground water modeling, and geochemical modeling. Waste charac- terization studies indicated the following: • In most of the tailings boreholes, three zones were recognized: an oxidizing zone in the upper part of the tailings, a transition zone, and an unaltered reduced zone. • Concentrations of arsenic and most metals were generally lower near the tailings surface, in- creased with depth, and then decreased. • The tailings are underlain by carbonate-rich alluvial gravels. At the tailings-alluvium interface, dramatic decreases in metal concentra- tions usually occurred, although the levels in the upper alluvium were still elevated relative to typical background values. Where multiple samples were recovered in the alluvium, the deepest samples often approached background levels. 3-34 As a result of changes instituted during the smelter demolition, the Opportunity Ponds system is in a state of physical and geochemical flux. Tailings areas that were continuously flooded since the early 1950s as a dust control measure are now draining. At present, the only external source of water to the site is treated wastewater from the city of Anaconda. This source may be discontinued in the near future. As the tailings dry out, an oxidizing front is predicted to move down through the tailings. Acid produced during this process could liberate significant quantities of trace metals to the ground water system. Elimination of surface water to the site has resulted in increased wind migration of contaminants to adjacent areas, a gradual lowering of the ground water elevation across the site, and the potential for increased contamination movement into ground waters as tailings become oxidized. Assuming that the remedial investigation is validated, additional investigation activity is likely to focus mainly on providing information for the evaluation of permanent control strate- gies. Possible control options for the ponds include a variety of capping alternatives, erosion control measures, ground water containment, and perhaps ground water treatment. AMC has already invested millions of dollars towards controlling fugitive emissions by covering the ponds with limestone as they dry out. Ground water conditions in the vicinity of the Opportunity Ponds are discussed in more detail later in this chapter. Warm Springs Ponds The Anaconda Copper Company constructed three treatment ponds near Warm Springs, Montana,. in 1911, 1916, and between 1954 and 1959. The purpose of the ponds was to settle out industrial wastes to improve the quality of water released to the Clark Fork. Lime has been added to pond inputs on a seasonal or streamflow basis since 1959 to aid in precipi- tating dissolved metals. The ponds cover about 2,800 acres, and Hydrometrics (1983a) estimated that they contain approximately 19 million cubic yards of mill tailings, mine waste rock, natural sediments, and precipitates. A comprehensive study of the ponds is now underway as part of the Silver Bow Creek Superfund site investigations. Phase I of this study was conducted by MultiTech (1987b) and Phase II is being conducted by CH2M Hill. For this Superfund investigation, the study area extends from the upper pH shack on Silver Bow Creek to below Pond 1 and includes the Mill- 3-35 willow Bypass and the Wildlife Ponds (Figure 3-4) . The Mill- Willow Bypass is a manmade ditch along the edge of the Warm Springs Ponds that contains the combined flows of Mill and Willow creeks. The ditch was cut through historic tailings deposits left by Silver Bow Creek before the ponds were built and contains more recent tailings deposited when the creek is allowed to bypass the treatment ponds during periods of high runoff. An extensive bottom sediment sampling effort at the Warm Springs Ponds was completed during the fall of 1987 as part of the Phase II RI activities. The objective was to gain an understanding of the volumes and chemistry of sediments that have accumulated in the various settling and treatment ponds. Average concentrations of selected metals in bottom sediment samples collected for the Phase II RI are provided in Table 3-8. TABLE 3-8, TOTAL METAL AVERAGES ; OF ' WARM SPRINGS PONDS 2 AND 3 BOTTOM SEDIMENTS Met a] r total . ppm dry weiaht) Pond As Cd Cu Pb Fe Zn 2 590 36 4,661 726 69,344 4,859 3 301 195 7,015 252 98,233 17,318 Bypass 121 22 3,713 215 29,777 4,258 Source: CH2M Hill : 1988a. The Warm Springs Ponds are designed to contain a flow of about 700 cfs (U.S. Army Corps of Engineers 1978). Silver Bow Creek flows greater than this are diverted around the ponds into the Mill-Willow Bypass, where they continue untreated into the Clark Fork. However, dike failure and bypass due to collection of debris on the gates has occurred at flows much less than 700 cfs (MultiTech 1987a) . Bypass events occur on the average of once per year. Although no water quality samples of Silver Bow Creek were obtained by MultiTech during a bypass event, historic data and recent studies by the Water Quality Bureau and DFWP (Phillips 1985) show that such events trigger large increases in TSS and most metals in the Clark Fork. 3-36 Warm Springs Ponds - Opportunity Ponds Vicinity Clark Fork River \ $0J' Prepared by Montana State Library Clorli Fork CIS Project 0 3000 6000 9000 12000 15000 Feel N FIGURE 3-4. WARM SPRINGS PONDS-OPPORTUNITY PONDS VICINITY 3-36a The 100-year flood was estimated by CH2M Hill (1988b) to be 4,000 cfs for Silver Bow Creek, and the pond structures would probably withstand a flood of that magnitude. However, during floods slightly larger than the 100-year flood, risk of pond failure increases significantly. At flows greater than 4,000 cfs on Silver Bow Creek, the diversion structure at the upper pH shack would no longer function reliably, and the full flood would possibly enter the Mill-Willow Bypass through the diversion ditch (lECO 1981) . This flood probably would cause failure of at least one of the pond berms and loss of the contents of that pond (U.S. Army Corps of Engineers 1978) . Pond 3 could fail directly when its outflow reached 5,600 cfs, and a flow of 7,000 cfs would overtop both Ponds 2 and 3, causing their failure (lECO 1981). Failure of the ponds also could occur if a large magnitude (6.9 Richter scale) earthquake weakened the pond embankments. Failure of the Warm Springs Ponds embankments would release large amounts of mining and milling wastes to the Clark Fork. Under those conditions, the Warm Springs Ponds would become a major source of contamination. An evaluation of the remaining useful life of the Warm Springs Ponds treatment system indicates that incoming sediment loads are the principal controlling factor and suggests that the life of the pond system could exceed 100 years under existing operating conditions (this calculation assumes no major changes in pond design or operation for the next 100 years) . However, the pond sediments have some of the highest concentrations of toxic metals found anywhere in the area, and they pose a long-term potential threat to the water quality of the Clark Fork (MultiTech 1987a) . Lands Affected by Aerial Deposition Nearly 100 years of smelting activities at the Anaconda Smelter resulted in the migration of a large burden of heavy metals, arsenic, and sulfur compounds to soils in the area. The main mechanisms were smelter stack emissions and fugitive dust from various waste deposits in the Anaconda area. Studies conducted for the Stage I Superfund investiga- tion of the Anaconda Smelter site included a soils investi- gation to determine the extent and severity of soil con- tamination from smelter stack emissions. Soil profiles (0- 2", 2-10", 10-25" intervals) were sampled at 23 sites along four transects emanating from the smelter stack in four directions (Figure 3-5) . Where possible, adjacent tilled and untilled fields were sampled to determine if there was a difference in the vertical distribution of metals in the soils. Such pairs were sampled at seven of the sample sites. 3-37 INVERSION TRA^BECT » OE=H LODGE VALLEY TRANSECT WARM SPRINGS PONDS OPPORTUNmr PONDS STACK OPPORTUNITY TRANSECT CT-SB I MIUS CRACKERViaE TRANSECT CT--( to z I— I a. s < o OS St: Of O 1^ o ca a: Ct] > t-i CO I a: 3-41a In July 1985, Schafer (1985) took this analysis a step further by addressing lands that had reduced yields — a more subtle vegetative productivity effect. Based on photo inter- pretation and very limited field reconnaissance, he estimated that there were approximately 28,000 acres of irrigated or previously irrigated land affected in some way by tailings contamination in Deer Lodge, Silver Bow, Powell, Missoula, and Granite counties. This total yield loss would be equivalent to 12,475 acres at full production (Schafer 1985). It is not clear whether mitigation of irrigation- affected lands will be addressed within the confines of the Super fund program. A variety of techniques, including soil treatment, water treatment, and crop management, could be employed to treat these lands (MultiTech and Stiller and Associates 1984) . \ Floodplain Mine Wastes Between the late 1880s and the mid-1950s, mining and smelting wastes were discharged directly into Silver Bow Creek and large quantities of tailings were transported downstream to the Clark Fork. The Milltown Reservoir near Missoula, which is the first major impoundment below the Butte-Anaconda mining district, trapped substantial amounts of mine wastes and contaminated sediment. However, a large volume of river-borne mine wastes has been deposited across the floodplain in the Deer Lodge Valley. The most severely affected area is between Butte and Deer Lodge, although floodplain mine wastes occur down to Missoula. These deposits have had significant detrimental effects on the Clark Fork riparian system, and they may be a source of continued contamination (Johns and Moore 1985) . The first large floodplain deposit in the headwaters is Ramsay Flats, located along Silver Bow Creek near Ramsay (Figure 3-7) . This deposit covers approximately 160 acres and consists of fluvially transported tailings mixed with natural sediment (MultiTech 1986) . Its average depth is estimated to be about six feet, and metal analyses conducted in a study by Peckham (1979) indicated a range of 69-5,400 ppm copper, undetected-1, 900 ppm lead, and 460-5,500 ppm zinc. For the tailings portion of the Silver Bow Creek Remedial Investigation, 15 samples were collected between Butte and the Warm Springs Ponds. Samples of soil buried by tailings were also collected to determine if metals had migrated out of the tailings. Results of the metal analyses are summarized below (MultiTech 1987c) . 3-42 z. u t— t > CO o 2 l-H J I— t < >- < T. < a: I u O 3-42a Tailings fppm) Total arsenic 399 (geom mean) Total cadmium 13.4 (average) Total copper 2,350 (average) Total lead 989 (average) Total zinc 3,070 (geom mean) Buried Soil fppm) 53 (geom mean) 58 (max) 98 (geom mean) 336 (geom mean) As expected, these data show greatly elevated concentra- tions of metals in the tailings. Metal levels in the underlying soils are generally several times higher than typical geochemical background values, indicating that enrichment via leaching is occurring. MultiTech also collected some samples of the bluish surface salts that form on the floodplain surface in some areas during the summer. These samples contained 7 to nearly 10 percent total copper and 2 to 3 percent total zinc. Brooks (1988) recently conducted a detailed investiga- tion of the distribution and concentration of metals in sediments and water in the upper Clark Fork floodplain. The study area included about two miles of floodplain near Racetrack Creek. The author mapped the floodplain sediments using aerial photos and data obtained from cores, trenches, and augering. Soil samples were collected at various distances from the river to determine mineralogy, grain size, and lateral distribution of metals concentrations. Water movement into the vadose zone was measured at selected sites with suction lysimeters. Sandpoint piezometers and augered wells were used to measure water levels and collect water samples from the alluvial aquifer. By examining stratigraphic profiles of floodplain sediment, Brooks delineated three major periods of mine waste deposition: 1) pre-mining, represented by coarse sand and organic overbank deposits under reducing conditions; 2) syn- mining, characterized by transition sediments and tailings deposits under oxidizing conditions; and 3) post-mining, distinguished by grass-bound topsoil. In areas contaminated by tailings deposits, the author documented enriched concentrations of cadmium, copper, manganese, and zinc in sediments and porewater and arsenic in ground water. Mechanisms that chemically distribute metals between particulate and dissolved phases are mainly dependent on the redox conditions and on the pH of the system. Thus, changes in redox conditions or fluctuations in pH could create a potential source of metals and arsenic to local ground water and surface water systems (Brooks 1988) . 3-43 The distribution of metals indicates that both vertical and lateral migration have occurred. During high-evaporation and low-precipitation periods, metals and sulfate in solution migrate to the surface and are precipitated as metal-enriched sulfate salts. Subsequent intense precipitation and rapid surface runoff results in the instantaneous dissolution of these salts, causing an abrupt lowering of pH and mobilizing metals to surface waters. Also, during flood conditions, metals can be incorporated into bed sediment and surface waters where tailings deposits are directly exposed to the active channel (Brooks 1988) . Downward vertical migration within the stratigraphic profile is indicated by the highly elevated concentrations of metals in organic-rich clayey silt directly underlying the tailings deposits. Complexation of metals in this unit is highly enhanced by the abundance of organic material, the proximity of the redox boundary, and the fine-grained nature of the sediment. Consequently, these factors prevent movement into the underlying coarse sand and gravel aquifer. Any small-scale downward mobilization of metals into the aquifer would likely be masked by dilution from ground water (Brooks 1988) . Ray (1983) conducted an investigation of metals-enriched fluvial sediments in the upper Clark Fork. Samples were collected from the floodplain near Rocker, Racetrack, Garrison, and Drummond (Figure 3-8) . A check site was sampled in the Tin Cup Joe Creek drainage, and a control site was sampled in the Blackfoot River drainage. Results of this study are summarized in Table 3-11. TABLE 3-11. AVERAGE CONCENTRATIONS < OF SELECTED METALS : FLOODPLAIN SEDIMENTS Site No. of Average ppm in soi! L^ Samples Copper Arsenic Cadmium Clark Fork Floodplain Rocker 3 1,102 164 10.0 Racetrack 8 2,375 402 11.6 Garrison 8 1,587 629 5.0 Drummond 7 4,155 578 12.9 Other Floodplains Tin Cup Joe Creek 3 53 26 1.7 check site Blackfoot River 1 13 4 <0.03 control site ^ Arithmetic means Source: Ray 1983. 3-44 00 ON >> to OS T3 c <3 w U 0 01 DO"-" Qi . •'-arr) u £>t^ ^ u 0 M J 3 o u a V) ^ -^-zz LJIZIr— — )CD •* Iki 4) -=33 ^ ^ • ^^^fl U J< (0 CO 4) — ^ ce ^ -CTcn CO L< fS ij o ^ -C=CT O — ki o 41 = '^ 4J 0 O J.! _Q - = r, 4J C CO O <0 r— » ■>»C3 •^ ^-4 •M _: b. 2 O OS •—4 ca — ^^ -r^C3 CO U. O J3 o bb CJ -«CC3 to Ui t-t ^ S 1 ca 1 Ll. CD. -J 1 1 1 1 -to CM -•JOCV -— CT ' .1 '.1 •-rCM ■cT7in ■CNJ^r ■— CT ■ — «-«• > 1 — 1 1 h —^L ^ ^T" —i — ^^^^^^^^ •a CS C2 CO en a a u: cv a a C3 CM a a a a a a c: a U3 cnLuc=iH-.z :llj: z.: — ZDLD (-JZD\CD ^;_, a: o < o Cu H Z u Z i-i o bl CO < CO u Du o u < H O I u U 3-46b O X> O U ^ CO OS n V —< J£ n ij Q 0) o U '^ b O V 3 O «-i — I u O Ji u C m ^ u u -r^ to u Id • H f— ) *^ O ^^ ^ Ul4 Z ai ca (i^ U J3 U Cb 03 [b — I a: D9 00 u o o a) o D O CD O on < u Ui CL 3 H Z u z: i-i a u C/] !^ Z < OQ a < ■J < H O H I U OS O 01 LJ Q >— . ::i !jj m :— 3-46c point bars and thin overbank deposits along this reach (Hydrometrics 1983b) . Sediment Transport Mechanisms To effectively deal with the problems caused by floodplain tailings in the Clark Fork system, it is important to have at least a fundamental understanding of the processes of metal transport and accumulation in the sediments. Research that addresses these issues is summarized below. Andrews (1987) collected fine-grained bed sediment samples at 21 sites along the Clark Fork from the downstream edge of the Warm Springs Ponds to just below the mouth of the Flathead River in 1984. He also collected a sediment sample from each of the five largest tributaries, including the Little Blackfoot River, Flint Creek, Rock Creek, the Blackfoot River, and the Bitterroot River. Concentrations of arsenic, cadmium, copper, lead, zinc, aluminum, iron, and manganese are summarized in Table 3-12. Andrews concluded that the arsenic, cadmium, copper, lead, and zinc were primarily associated with ferromanganese material on the particle surface, and that with the exception of lead, very little of these elements was bound in silicate minerals. In bed sediment samples, copper, zinc, and manganese increased significantly with decreased particle size. Concentrations of arsenic, cadmium, copper, lead, and zinc in fine-grained bed sediments decreased downstream but at different rates. Copper concentrations decreased downstream much more rapidly than lead concentrations, while arsenic, cadmium, and zinc decreased less rapidly than copper but more rapidly than lead (Andrews 1987) . The author also found that the addition of relatively clean water and sediment from tributaries had little effect on the distribution of trace metals in the Clark Fork. For example, mixing the sediments with background metal con- centrations from the Bitterroot River did not appreciably dilute the trace metal concentrations in mainstem bed sediments. The exchange of sediment between the river and floodplain in the mainstem is large relative to the quantity of sediment contributed by tributaries; therefore, the tributaries have no appreciable effect (Andrews 1987) . In 1986, Brook and Moore conducted a study to evaluate the distribution of metals and the control exerted by sediment particle size on metals concentrations in upper Clark Fork bed sediments. Bed sediments were collected from 26 locations in the mainstem Clark Fork and from several locations in the Little Blackfoot River, Flint Creek, and the 3-47 TABLE 3-12. CONCENTRATIONS OF TRACE HETAL ASSOCIATED WITH FINE-GRAINED BED MATERIAL IN THE CLARK FORK AND MAJOR TRIBUTARIES Location River Kl lometer et«rk Fork Arsenic Total Partial mg/kg Cadmium Total Partial mg/kg Copper Total Partial mg/kg Lead Total Partial mg/kg Zinc Total Partial mg/kg U.3 21.2 34. S 48.1 78.4 89.2 94.1 104.4 115.7 130.7 HO. 8 153.4 168.3 181.5 207.1 222.4 228.4 264.9 299.6 387.7 399.7 165.0 164 199.0 194 151.0 195 100.0 60.0 39.0 46.0 44.0 54.0 69.0 49.0 40.0 33.0 35.0 18.0 15.0 19.0 17.0 8.5 17.0 9.4 1 1 1 <0 7.3 1,290 1,300 173 117.0 1,660 1,580 10.0 2,490 1,410 179 136.0 1,770 1,770 11.0 1,660 1,540 213 151.0 1,850 1,880 1,620 1,080 170 116.0 1,460 1,380 1,700 990 139 89.8 1,380 1,390 1,000 641 100 62.2 1,030 1,030 17.0 1,050 747 111 67.9 1,130 1,090 650 680 100 63.4 560 1,130 400 418 112 77.2 900 916 420 428 116 84.9 940 916 335 345 95 36.8 830 836 305 305 87 52.1 800 761 325 321 79 43.5 325 780 333 345 80 51.9 900 873 225 230 54 30.2 690 685 245 231 62 30.1 540 489 325 353 62 37.0 760 740 212 221 45 20.9 610 613 <0. 1 121 107 34 <0.5 330 300 235 245 57 27.4 540 527 0.79 93 101 24 1.4 250 267 Major Tributariea Little Blackfoot River Flint Cretk Rock Creek Blackfoot River Bitterroot River 3.2 17.0 0.7 0.8 126.0 128.0 1.5 0.7 5.4 14.0 <0.5 <0.1 4.8 6.4 <0.5 0.3 3.0 5.0 <0.5 <0.1 25 27.5 31 4.2 153 128 48 51.0 165 124.0 560 542 10 12.0 6 <0.5 38 35 19 17.0 9 <0.5 54 41 30 29.0 24 <0.5 80 79 Source: Andrews 1987. 3-47a Blackfoot River. Fine-grained bed sediments were collected in areas of low-flow velocity and were separated into mud and sand fractions in the laboratory. The authors reported that mean concentrations of cadmium, copper, manganese, and zinc in mainstem samples were well above those in tributary samples. All four metals showed general decreases in concentration downstream (this trend was more pronounced in the mud fraction) and varia- bility among sites was high. Brook and Moore attributed these results to the downstream decline in frequency of metals-laden floodplain deposits and speculated that dilution by uncontaminated tributary sediments might also be a factor. They also found that more of the bulk metals concentrations were derived from the sand fraction than from the mud fraction (Brook and Moore, unpublished manuscript) . Using the data on bank sediments from Moore's 1985 EPA study (discussed in the previous section), Moore et al. (in press) examined the controls exerted by sediment particle size on metals concentrations in the Clark Fork system. The traditional view of metal-sediment association is that most of the metals are carried in the fine fraction. Moore et al. (in press) found that this relationship held true in the tributaries, where there were significant correlations between most of the metals and the percentage of clay. However, in the mainstem, most or all of the size fractions were found to be important contributors to the high metals concentrations. The Clark Fork is a high-gradient, coarse- grained system that commonly carries coarse sand in suspen- sion during spring runoff. Some of this coarse sand is actually extremely metal-rich mine and smelter tailings. The authors also suggested that the coarse-grained floodplain sediments may reside in an oxygenated environment longer than fine sediments and may have more time to accumulate oxide coatings and associated trace metals. Moore et al. (in press) concluded that distribution of metals in a complex system such as the Clark Fork is more likely to be based on chemical associations than on grain- size parameters. Application of traditional methods to correct for grain size effects may lead to erroneous conclusions about metal trends in the Clark Fork and other contaminated systems. Researchers with the U.S. Geological Survey (USGS) are conducting investigations in the Clark Fork using sediments to determine the fate and distribution of trace metals in river systems. They are also using aquatic insects as indicators of biologically available metals. The Clark Fork has been selected for these investigations because of the predominance of mine waste metals and the lack of other major 3-48 metal sources. Although these investigations are part of a larger investigation of rivers in general, the data should be useful for understanding Clark Fork problems. The investi- gations involve the mainstem Clark Fork and several major tributary streams (Luoma 1988) . Reservoir Sediments Milltown Reservoir acted as a primary catch basin for mining-related sediment from the time of its construction (1906) until the construction of the Warm Springs Ponds (1911) . This reservoir is basically full, with an estimated 120 million cubic feet of metals-contaminated sediment behind the dam (Woessner et al. 1984). Johns and Moore (1986) undertook a study to demarcate the lower boundary of detectable metals-contaminated sediments derived from mining and smelting activities in the headwaters. They collected samples from the Thompson Falls, Noxon Rapids, and Cabinet Gorge reservoirs in the lower portion of the Clark Fork Basin. Samples were also collected from three drainages tributary to Noxon Rapids and Cabinet Gorge reservoirs to serve as background checks. Data from these lower reservoirs and tributaries were compared with data from the Clark Fork and Blackfoot arms of the Milltown Reservoir collected during the Milltown Superfund Remedial Investigation. Results of this study are summarized in Table 3-13. Total metals concentrations, measured in micrograms per gram (ug/g) , in the sediments of all four reservoirs are clearly elevated compared with Blackfoot and tributary sediments. In almost all cases, total metals levels in the reservoirs decreased progressively downstream. The same trends were evident for acetic acid-extractable metals, as illustrated by the copper and zinc plots in Figures 3-12 and 3-13. Although some of the metals concentrations in the three lower reservoirs were not highly enriched over background levels, it is clear that elevated levels of copper and zinc occur as far downstream as Cabinet Gorge Reservoir, some 34 0 miles from the major source of those metals. Transport of the metals-laden sediment down river may have occurred prior to construction of the Milltown Dam, during exceptional events such as dike breaches at the Warm Springs Ponds, during operational and maintenance drawdowns of the Milltown Reservoir, and as part of the current total suspended sediment load in the Clark Fork. Metal-rich sediments were and are likely diluted by additions of "clean" sediments from major tributaries such as the Blackfoot, Bitterroot, Flathead, and St. Regis rivers (Johns and Moore 1986) . This conclusion appears to contradict the findings of Andrews (1987) . 3-49 TABLE 3-13. HEAN CONCENTRATION AND 95 PERCENT CONFIDENCE LIMITS FOR TRACE ELEMENTS IN SURFACE SEDIMENTS FROM CLARK FORK RESERVOIRS AND TRIBUTARIES Trace Element Reservoir/ (ug/g) Tributary As Cu Mn Pb Zn Blackfoot U.7 22 295 15.8 «8 River (13.1-16.5) (16-28) (250-348) (11-22.7) (57-80) Mill town 50 422 1,260 75.8 1.585 Reserve) r (41.7-60.3) (344-517) (841-1,880) (64.2-89.6) (1,080-2,330) Thompson Falls 19.3 108 417 28.4 331 Reservoi r (U. 8-25.1) (86-135) (257-676) (19.7-40.9) (246-445) Noxon Rapids 21 95 631 35 309 Reservoir (19.7-22.5) (79-113) (513-776) (31.6-38.8) (281-339) Vermi I ion River 15.5 23 225 16. B 70 Trout Creek U 28 290 21.7 72 Cabinet Gorge 12 42 398 19.4 200 Reservoir (8.8-15.5) (27-64) (262-605) (14.9-25.3) (132-301) Bull River 8.3 12 167 7 45 Reservoir means and confidence limits are back-transformed from log^g. Source: Johns and Moore 1986. 3-49a lA 00 3 o z u o o X T5 c CO CO C x; o -5 0) O U o M O a: m o in — T— O o O n o o — r- O ■n § u o u oa < H u < OS H X I Q i-i U < U i-i H U U < to o z w H ec til > I— I z o o jaddoo 6/5n 06 3-49b 00 ^ u .5 " .^ 5 • m 1 g Ci o Z N^ - in M 5h ^ ^ u o o X TJ C CO c O 0) u 3 o o > i. «> in 01 a: § u z I— t N UJ < H < H X U I a < u I— I H U] U < C/5 Q Z u OS H o: > 02 z o a u o 8 — r- o o N O O O — r- o o — T- o o 10 o o o o N 0UJ2 5/5n 3-49c Reclamation of Contaminated Lands Although several hundred acres of land in the Butte and Anaconda areas have been reclaimed by the Anaconda Minerals Company, a large number of acres of contaminated land remain in the upper reaches of the Clark Fork Basin. It is almost certain that reclamation of at least some of those acres will be attempted in the future. At present, the lack of perennial vegetation in many areas of the Deer Lodge Valley causes a number of problems, including wind erosion, increased surface runoff, increased recharge of the shallow ground water system, and possibly increased heavy metals loading to surface and ground water. If the quality and productivity of the vegetation in the upper Clark Fork Basin were improved, an increase in land quality and overall environmental quality in the region would result (USDA 1985a) . Much of the future reclamation efforts will likely be through the Super fund program, although projects using other sources of funding are currently in progress. Any major revegetation endeavors would have to be preceded by detailed trials and evaluations prior to large-scale application. A few such evaluations have been recently conducted, are on- going, or are in the planning stages. These and activities by AMC are summarized in the following sections. Spangler Ranch Study A study to identify reclamation techniques for heavy metals contaminated agricultural lands in Deer Lodge, Powell, and Silver Bow counties was initiated in 1984. The project was administered by the Headwaters RC&D and received financial support through a grant from DNRC. The project consisted of a forage-establishment phase and a hydrogeology phase. The two-year forage-establishment study was conducted by Schafer and Associates (1986) on the Spangler Ranch about six miles southeast of the Anaconda Smelter. The purpose of the study was to develop and test techniques for reestablishing forages on land contaminated by mining. The affected area, nearly devoid of vegetation, was once-productive dairy farm land but had been irrigated with tailings-laden water through the early 1900s (Schafer and Associates 1986) . A number of treatments were tested, including three different liming rates, several different forage species, and a variety of tillage methods. The results of these trials were: 3-50 Use of lime to neutralize soil acidity was ' necessary to allow plant establishment. Extensive sampling of a potential reclamation site was needed before the lime requirement could be predicted. Both the average and range in lime requirement should be characterized, and lime rates should be set to improve 85-95 percent of soils to a target pH of 6 to 6.5. In soils that were high in copper and zinc, the use of liming alone did not ensure adequate plant performance. Additional soil amendments, such as phosphorus and manure, might be required to further reduce the availability of copper and zinc to plants. Plant performance on the test plots was variable. Some plants may have done poorly partly because the first year of the study was hot and dry. However, promising results were obtained with a number of species, including crested wheatgrass, pubescent wheatgrass, basin wildrye, Russian wildrye, altai wildrye, yellow sweetclover, cicer milkvetch, and birdsfoot trefoil. None of the plants sampled appeared to accumulate metal levels that would be toxic to livestock. A moldboard plow/ chisel, plow/harrow tillage sequence gave the best results due to better seedbed preparation, better mixing of lime, and reduced competition from existing vegetation. The first phase of the hydrogeologic study was completed in 1986 (Osborne et al. 1986) and was discussed earlier in this chapter. The second phase is ongoing and is being conducted by the Montana Bureau of Mines and Geology. The objectives are: 1) to quantify the concentrations of trace elements in selected intervals of soil and unconsolidated deposits underlying the Spangler Ranch agricultural sites and 2) to identify the mechanisms and rates of trace element movement in the unsaturated zone and shallow aquifers on the sites. The study involves laboratory leaching column experiments and field site lysimeter sampling. The following observations were made at the conclusion of the first round of leaching column experiments (Wilson et al. 1988): • Of the elements tested, arsenic was most mobile in both amended and nonamended soils. 3-51 The lime -amended soil showed the smallest release of dissolved arsenic, whereas the lime-and-phos- phorus-amended soil showed the greatest release of dissolved arsenic. The field site lysimeters were successfully sampled until the end of August 1987, after which the soils became too dry to obtain samples. Data from these samplings indicate that field site results for arsenic during the first year did not completely parallel laboratory results. The lowest arsenic concentrations were found in lysimeter samples from the control (untreated) plot rather than from the lime- amended plot. For zinc and copper, the lowest dissolved concentrations were observed in the lime-amended soils. An additional season's results are needed to confirm or alter the field-site interpretations, which are based on a limited sampling in 1987. Streambank Tailings and Revegetation Study As part of the Silver Bow Creek Superfund site Phase II remedial investigation, the DHES has developed a program to address the streambank mine wastes disseminated over much of Silver Bow Creek and the upper Clark Fork. Typical remedial measures for such wastes include removal or capping; however, such measures may not be practical for sites such as Silver Bow Creek that involve large areas of contamination and large volumes of material. Therefore, the Streambank Tailings and Revegetation Study (STARS) was initiated in fall 1987 to investigate new and more innovative technologies to address streambank mine wastes (CH2M Hill 1987c) . STARS is divided into two phases: a laboratory/green- house phase to develop and test treatments at a bench scale and a field scale phase to demonstrate selected remedial alternatives. During Phase I, a variety of remedial measures are being tested to modify the tailings characteristics sufficiently to allow revegetation. Suitable soil amendments to raise soil pH and reduce plant-available metal levels are being developed, and plant species that can thrive in the amended environment will be selected. Criteria for charac- terizing streambank mine wastes based on their chemical and physical properties are being developed. The Phase I final report will include a preliminary design for innovative remedial alternatives for each waste type identified. Laboratory and greenhouse studies were completed in the fall of 1988. Phase II activities will include field implementation of the remedial measures designed in Phase I. 3-52 The response of treatment in reducing leachate quantity and abating metal movement to surface and ground water will also be evaluated (CH2M Hill 1987c) . Siting and construction of the field demonstration are ongoing and it is anticipated that the plots will be seeded in late fall 1988. If the fall planting season is missed, the plots will be seeded in the spring of 1989. The plots will be monitored through two field seasons, with a final Phase II report due sometime in 1991. Clark Fork Reclamation Demonstration Project In September 1986, a proposal for an upper Clark Fork floodplain reclamation demonstration project was submitted to the DNRC for funding under the Resource Indemnity Trust (RIT) Grants Program. The proposal was prepared and submitted by the Governor's Office Clark Fork Basin Project, the Head- waters RC&D, and the Deer Lodge County Conservation District. The purpose of the project was to evaluate the cost and effectiveness of a variety of reclamation techniques applied to an entire floodplain segment (streambanks, riparian area, and adjacent agricultural lands) of the upper Clark Fork. The project was approved for RIT funding in 1987; however, funds were not available until late 1988. It is anticipated that work will begin in 1989. Some preliminary work was conducted on the project in the fall of 1987. With help from a Deer Lodge/Powell County Soil Conservation Service (SCS) Soil Survey party, Schafer and Associates (1988) conducted a detailed survey of the study area under contract with the Governor's Office. The objectives of the investigation were to: • determine the source, extent, and severity of tailings contamination in the study area • determine where and under what conditions metals from streamside tailings may be entering the Clark Fork • identify potential low-cost remedial measures to reduce or eliminate the movement of contaminants into the river • propose specific candidate sites for a remedial demonstration. 3-53 An order 1 (ultra-detailed) soil survey was completed on a corridor bordering the Clark Fork reach from Warm Springs Ponds to just below Perkins Lane Bridge. A mapping unit legend was developed to delineate mine waste deposits from natural soils. Tailings deposits were further separated by depth, amount of vegetation, and soil texture. Mapping units were also separated according to the geomorphic setting, being either above the 100-year floodplain, in the 100-year floodplain, or roughly within the mean annual floodplain. Natural soils and tailings-affected units were classified using the Soil Taxonomy (Soil Survey Staff 1975) . A total of 18 map units were delineated on 1981, 1: 6, 000-scale aerial photographs . To determine the chemical and physical variability in the tailings deposits, two detailed soil investigation plots were located near the river at sites where tailings deposi- tion was extensive. Data from these sites were encoded and used to produce maps of tailings thickness, surface eleva- tion, and surface soil pH and electrical conductivity (EC) . It was found that soil pH levels were highest in the natural soil, with much lower pH found in tailings deposits. Tailings deposits less than 8 to 12 inches thick had higher pH levels than thicker tailings layers. Soil salinity tended to be higher in tailings than in natural soils, but this parameter differed less than pH. A streambank survey was conducted to assess the condition of the channel banks within the study area. The river bank condition was rated according to bank angle, percentage of protective cover, kind of cover (gravel, vegetation) , and depth of tailings. A two-man mapping team floated and/or waded to obtain the data. The bank angle was measured relative to the river, with a vertical bank equaling 90 degrees and an undercut bank less than 90 degrees. This was done to find areas where the river was undercutting and eroding its banks. The protective cover was ranked using a rating from one to four, with one being less than 25 percent cover, two between 25 and 49 percent, three between 50 and 79 percent, and four being greater than 80 percent cover. The classification and rating system of bank conditions was developed into a legend similar to the method described by Platts et al. (1983), and a map of the river bank mapping units was produced. The majority of the streambank within the study corridor was in good shape, with probably 10 percent or less in the very erosive category. Several remedial measures may be employed within the demonstration area. Contaminants would be removed from along the streambank, and willows would be used to improve bank stability. Mine waste removed from areas susceptible to erosion would be redeposited on-site in more stable 3-54 locations. Chemical amendments would be added to thick (more than eight inches) tailings deposits (point bars) to neutralize acidity and metals, and cover soil would be placed over them to function as a root-zone medium. Areas with less than 6-8 inches of mine waste would be either amended and reseeded or mixed through deep plowing. All areas would be seeded with a mixture of species adapted to the conditions on the site. Grazing restrictions would be employed to enhance the stability of crucial areas along the stream channel. Three possible study locations varying from six to ten acres have been identified. This reach of river has historical fishery and water quality data and is known to suffer a decline in fish numbers. The landowner supports the project. Access to the site is good due to the proximity of Perkins Lane Bridge and an abandoned railroad grade. Detailed soil information gathered from this project will be useful for project planning purposes. Anaconda Minerals Company Reclamation The Anaconda Minerals Company has undertaken several reclamation projects in the Butte-Anaconda area in the last three years. It has reclaimed several hundred acres using cover soil, crushed limerock, straw mulch, fertilizer, and grass seed. In Butte, AMC has reclaimed approximately 120 acres, including 67 individual mine dumps, portions of the Buffalo and Missoula drainages, all of the La Platta drainage, and the Sherman Ballfield-South Alice dump area. It has moved more than 150,000 tons of mine waste rock to the Berkeley Pit. AMC has also installed 300 feet of large-dimension pipe and constructed over a mile and a half of rock-and- filter-lined ditches to provide controlled drainage from Walkerville to the existing Butte-Silver Bow storm drain system. On Smelter Hill in Anaconda, AMC has reclaimed approx- imately 300 acres of land and developed three miles of ditches. It has placed an erosion-resistant cap over the old flue and moved hundreds of thousands of cubic yards of material to reduce the slopes and cover the substructures of demolished buildings prior to the reclamation work. At the Opportunity tailings ponds system, AMC has reduced the slopes of all dikes and dams, and all of the tailings have been covered with at least 30 tons per acre of crushed limerock to prevent blowing. 3-55 SURFACE WATER QUALITY Introduction Early 19th century explorers, fur traders, and missionaries described the Clark Fork as a clear and pristine waterway, teeming with life (Horstman 1984) . This vision of the Clark Fork faded into a memory with the advent of mining later in that century, as mining, milling, and smelting wastes were dumped directly into Silver Bow Creek and transported downstream. In 1872, James A. Garfield noted that "the beautiful river has been permanently ruined by the miners; and has been for three years as muddy as the Missouri. Before the discovery of gold, it was as clear and pure as any mountain stream could well be" (Horstman 1984) . The mining activities resulted in high concentrations of heavy metals and high sediment loading in the river, and as the basin became more developed, nutrient loading also increased. Those early days of neglect resulted in a river system that was virtually unusable and uninhabitable for fish and other aquatic species. However, as environmental awareness grew and ushered in the age of water quality standards and regulations, conditions in the river system began to slowly rejuvenate. Although it still has much room for improvement, the river has nonetheless staged a rather dramatic comeback. The following sections touch briefly on historical water quality (pre-1984) in the Clark Fork and then describe recent and current water quality conditions (1984 to present) in detail. This latter section focuses on heavy metals (particularly copper and zinc) and suspended sediments, as these are the parameters of greatest concern today. Other surface water quality problems, such as ammonia, dissolved oxygen (DO), elevated temperature, color, foam, etc., are discussed in less detail. Nutrients, an important issue in the basin, and their effects on algae growth are discussed in the section following surface water quality. Historical Surface Water Quality Problems One of the first comprehensive studies of water quality degradation in the Clark Fork drainage was conducted in the late 1950s by the Montana State Board of Health to obtain information necessary for the classification of streams and the establishment of water quality standards. This study (Spindler 1959) involved a comprehensive chemical and biological survey of the entire mainstem and major tribu- taries. After publication of that report, there was little activity on the river until the 1970s, when several studies 3-56 were performed to document the effectiveness of Anaconda Minerals Company's efforts to treat water in Silver Bow Creek. These earlier studies are discussed in the following sections. Silver Bow Creek Spindler (1959) documented grossly polluted conditions in Silver Bow Creek in 1957. He reported very high levels of copper, iron, and zinc; low dissolved oxygen levels; high turbidity; no pollution-sensitive macroinvertebrate species, and only one tolerant form. The first attempt to address the water quality problems in the headwaters had come in 1911 when the Anaconda Copper Company built a treatment pond near Warm Springs to settle out its industrial wastes. Two more treatment ponds were added in 1916 and between 1954 and 1959. With the addition of the third pond, this system became quite effective in settling metals out of the stream. Water quality in the Clark Fork improved below the ponds, as demonstrated by the following data from Spindler (1959) : Station Silver Bow Creek at Silver Bow Metals (ug/1)* Copper Zinc Arsenic 11,200 3,350 40 Silver Bow Creek above 4,200 settling ponds Clark Fork below settling ponds 10 3,660 400 30 trace * maximum of two samplings, summer 1957 However, Silver Bow Creek continued to receive raw mining and milling wastes, and by the mid-1960s, the accumulated solids in the ponds had begun to reduce the pond volume and, hence, the efficiency of the system. The Anaconda Company decided to construct new treatment facili- ties within the Butte Operations to replace the Warm Springs Ponds as the primary wastewater treatment system (Spindler 1976) . The new program included lime neutralization, flocculation, co-precipitation, settling, secondary polish- ing, and pH adjustment (Chadwick et al. 1986). 3-57 This new primary treatment facility was put into operation late in 1972. Although water quality began to improve, it was several years before there were signs of recovery in Silver Bow Creek. Gless (1973) conducted a biological study of Silver Bow Creek from 1972 to 1973 and found almost no invertebrates, which he attributed to a lack of suitable substrate and high heavy metals loads. Anaconda Company's self -monitoring turned up no macroinvertebrates in Silver Bow Creek until 1975 (Chadwick et al. 1986) . Diebold (1974) studied the physical and chemical properties of Silver Bow Creek water and bottom sediments from 1973 to 1974. He performed laboratory leaching studies and concluded that the sediments had a high metal adsorption capacity. The primary treatment system was refined in 1974 to increase the holding time prior to discharging wastewater (Chadwick et al. 1986) . A secondary treatment system installed in 1975 further improved water quality, as evidenced by decreased turbidity, TSS, and heavy metals concentrations. By late 1975, a variety of algae and macroinvertebrates were found in Silver Bow Creek (Spindler 1976) . Although water quality in Silver Bow Creek improved greatly over the days when the stream received untreated wastes, metal concentrations at levels potentially toxic to aquatic life were reported by various investigators (Beuerman and Gleason 1978; Peckham 1979; Botz and Karp 1979; Janik and Melancon 1982; and Hydrometrics 1983a). Most reported increased metals loads between Butte and Gregson that were attributable in part to the large tailings deposits (Colorado Tailings and Ramsay Flats) in the floodplain of Silver Bow Creek. Clark Fork Spindler (1959) made several observations regarding water quality conditions in the mainstem Clark Fork from his field work conducted in 1957. He found that, based on bottom fauna analysis, polluted water conditions existed in the Clark Fork from Warm Springs to the Bitterroot River. Evidence of conditions approaching gross pollution existed between Warm Springs and the Little Blackfoot River, below Garrison, between Missoula and the Bitterroot River, and below Plains. Among the problems documented were high coliform bacteria concentrations downstream of industrial waste discharges, municipal wastewater, and raw sewage discharges, which rendered the river unsafe for uses other than agricultural and industrial. The construction of Warm Springs Pond 3 resulted in improved water quality in the upper Clark Fork. For the 3-58 first time since the turn of the century, limited macroinver- tebrate and fish populations became established in a short reach immediately downstream of the ponds. However, despite the significant improvements, water quality as a whole was still marginal. In 1967, the Montana Water Pollution Control Council established water quality standards for Montana surface waters. These standards established beneficial uses to be protected, but did not specify numerical criteria for heavy metals and other contaminants (EPA 1972) . They did, however, require municipal and industrial dischargers to provide secondary treatment or the equivalent. In 1970, the EPA conducted a study (EPA 1972) for the DHES to determine the allowable maximum concentrations of heavy metals in the Clark Fork. Some of the results of the study, along with USGS data collected in the early 1970s, are presented in Table 3-14. The data indicate that water quality in the Clark Fork was quite poor as far downstream as Alberton during industrial spills, labor strikes, or high runoff periods. The EPA characterized the Clark Fork above Deer Lodge as severely polluted, as indicated by a deficient and nonbalanced population of benthic organisms and few fish. Waste discharges and spills from the Anaconda Company settling ponds were cited as the principal cause of the high concentrations of most metals and other constituents in the headwaters. TABLE 3 -14. MAXIMUM CONCENTRATIONS OF COPPER AND ZINC 1 IN MAINSTEM CLARK FORK, 1970-72 SAMPLING DATE ON PERIOD OF WHICH MAXIMUM MAXIMUM CONCENTRATIONS (t jg/l) AGENCY RECORD CONC. OCCURRED STATION TOTAL CU trI cu TOTAL Zn TR Zn EPA May-Oct. 1970 Oct. 21, 1970 Clark Fork at Warm Springs 1,360* 4,200* ... USGS July 71-June 72 Jan. 5, 1972 Clark Foek near Galen ... 120 ... 950 EPA Hay-Oct. 1970 July 14, 1970 Clark Fork at Dempsey 420* ... 960* ... USGS Oct. 70-June 71 Feb. 3, 1971 Clark Fork at Deer Lodge ... 210 ... 350 EPA Hay-Oct. 1970 July 14, 1970 Clark Fork at Deer Lodge 1,200* ... 4,700* ... USGS Oct. 70-June 71 Feb. 3, 1971 Clark Fork at Garrison ... 130 ... 250 EPA May-Oct. 1970 Cu low flow Zn high flow Clark Fork at Garrison 240 ... 340 ... USGS July 71-June 72 Cu July 24, 1971 Zn April 17, 1972 Clark Fork at Drunmiond .- - 20 ... 120 EPA May-Oct. 1970 Low flow Clark Fork at Drummond 90 ... 160 ... USGS Oct. 70-June 71 April 7, 1971 Clark Fork above Missoula ... 340 ... 540 USGS Oct. 70-June 71 April 7, 1971 Clark Fork near Alberton ... 240 ... 260 USGS Oct. 70-June 71 April 13, 1972 Clark Fork at Thompson Fall s — 20 ... 40 TR = Total Recoverable *Sainples collected during spills Sources: EPA 1972; Brosten and Jacobson 1985. 3-59 The EPA reported a more balanced and healthy biological system on the mainstem at and below Garrison and high quality water in streams tributary to the Clark Fork. Between 1973 and 1983, a variety of studies were conducted on the Clark Fork (Braico 1973; EPA 1974; Botz and Karp 1979; Janik and Melancon 1982; Hydrometrics 1983b). However, the best records of surface water quality for that decade are from the DHES-WQB station at Deer Lodge and the uses station below Missoula. The station at Deer Lodge was sampled by the WQB sporadically from 1974 through 1977 and monthly between 1978 and 1983. The WQB documented high total recoverable copper and zinc concentrations (up to 800 micrograms per liter [ug/1]) associated with spring runoff events, particularly between 1974 and 1976. Although peak concentrations were not as high in the 1977-83 period, many of the concentrations measured exceeded copper and zinc aquatic life toxicity criteria. Total phosphorus concentra- tions were often greater than 100 ug/1 and reached over 500 ug/1 on one occasion. uses data for part of the same period for the Clark Fork below Missoula document relatively low concentrations of total recoverable copper and zinc from 1978 through 1980, with strong peaks during runoff events in May 1981 and February 1982. Total phosphorus concentrations were generally below 100 ug/1, although they reached a peak value of 770 ug/1 in February 1982 (Brosten and Jacobson 1985) . Recent and Current Surface Water Quality Monitoring Programs The attention that has been focused on the Clark Fork system in the last few years has prompted a number of agencies to conduct monitoring programs or special projects in the basin. As a result, we now know a great deal about the quality of surface waters in the basin, and we should be able to make much more informed resource decisions. The Department of Fish, Wildlife, and Parks measured concentrations of total recoverable copper, iron, and zinc in water in the spring of 1984. Samples were taken weekly between early April and mid-July 1984 at eight mainstem locations and in six tributaries located above Milltown Dam. The data provide documentation of very high metal concentra- tions in the Clark Fork during a runoff event in May 1984 when Silver Bow Creek was diverted directly into the Clark Fork (Phillips 1985) . 3-60 The DFWP has also collected water quality data at various locations in the upper river in conjunction with bioassays conducted during 1986, 1987, and 1988 (Phillips et al. 1987) . The DHES-WQB and the USGS have collected the majority of surface water data in the basin. A significant amount of data has also been generated as part of the Silver Bow Creek Super fund Investigation. These recent and current programs are described in the following sections. The DHES-WQB has initiated a number of surface water monitoring programs on the Clark Fork in the last few years. Six stations in the upper Clark Fork have been sampled monthly since December 1982, with two more stations added in January 1984. In March 1984, the Water Quality Bureau began an extensive investigation (31 monitoring stations) of the lower Clark Fork to address public concerns over the general health of the lower river. Much of this concern was generated by the modification of the wastewater discharge permit for the paper mill near Missoula. In September 1985, the upper and lower Clark Fork monitoring programs were merged to form the Clark Fork Basin Study. Several moni- toring stations were added in the upper river, including two stations between the Little Blackfoot and Turah, to link the two monitoring sections. Some of the lower river monitoring stations were eliminated so that now a total of 32 fixed stations (Silver Bow Creek, Clark Fork, major tributaries, and wastewater discharges) are sampled in the Clark Fork Basin (Figure 3-14) . Monitoring is conducted monthly from August through March and twice monthly from April through July. Parameters monitored include: discharge; field pH and temperature; calcium; magnesium; total and volatile suspended sediment (VSS) ; alkalinity; total and dissolved algal nutrients; and total recoverable arsenic, copper, and zinc. Biological monitoring (periphyton, macroinvertebrates) and DO surveys are conducted once each summer. Dissolved metals may be added in the future. The project has been funded by EPA, the state general fund, and the RIT program since July 1986. An extension through June 1989 was approved by the 1987 Legislature. Results of WQB State Fiscal Year 1985-87 monitoring in the Clark Fork Basin are summarized in this report. Each of the three years was characterized by lower-than-normal streamflows. While FY 1986 conditions were not far below normal (and in fact included a major mid-winter flood) , FY 1985 and especially FY 1987 can be described as drought years. Consequently, the data collected during the period are not representative of average or above-average flow conditions. 3-61 CLARK FORK BASIN STUDY SAMPLING LOCATIONS 00 Sliver Bow Creek (SBC) above Butte WWTP 00.5 Butte WWTP discharge 01 SBC below Colorado Tailings 02 SBC at Miles Crossing near Ramsay 03 SBC above Warm Springs (AMC) treatment ponds 04 AMC Pond #2 discharge (Silver Bow Creek) 05 Mill-Willow Creek Bypass at mouth * 06 Warm Springs Creek at mouth 07 Clark Fork (CFR) below Warm Springs Creek 08 CFR near Dempsey 09 CFR at Deer Lodge 10 CFR above Little Blackfoot River 11 CFR at Gold Creek Bridge 12 CFRatBonita 13 CFRatTurah 14 Blackfoot River near mouth 15 CFR below Milltown Dam 16 CFR above Missoula WWTP 17 Missoula WWTP discharge 18 CFRatSchuffleld's 1 9 BItterroot River near mouth 20 CFR at Harper Bridge 21 Stone Container Corporation discharge 003 22 CFR at Huson 23 CFR at Alberton 24 CFR at Superior 25 CFR above Flathead River 26 Flathead River near mouth 27 CFR above Thompson Falls Reservoir 28 CFR below Thompson Falls Dam 29 CFR below Noxon Rapids Dam 30 CFR below Cabinet Gorge Dam Source: Ingman 1987 FIGURE 3-14. DHES-WQB SAMPLING STATIONS IN THE CLARK FORK BASIN 3-61a The FY 1986-87 data base is relatively complete and represents 14 to 17 samplings at most of the stations in the monitoring network. However, in FY 1985 nutrient and suspended sediment were monitored infrequently in the Clark Fork above Rock Creek (near Clinton) . As a result, discus- sions of nutrients and suspended sediments rely mostly on FY 1986-87 data. The USGS has been sampling periodically at six sites in the upper Clark Fork Basin since March 1985 (Figure 3-15) . Two of the sites are on the Clark Fork mainstem (at Deer Lodge and at Turah Bridge, near Bonner) and four sites are near the mouths of major tributaries between Deer Lodge and Milltown Reservoir (Little Blackfoot River, Flint Creek, Rock Creek, and Blackfoot River) . Field measurements include stream discharge, specific conductance, pH, temperature, bicarbonate and carbonate, and alkalinity. Laboratory analyses include hardness; selected dissolved, total, or total recoverable trace elements; and suspended sediment. The primary objective of the USGS sampling program is to characterize the geographic and hydrologic variation in trace element and suspended sediment concentrations. Geographically, sampling locations were selected to describe water quality conditions at the upper and lower end of the upper Clark Fork segment and in the major tributary basins entering this reach. Hydrologically, sampling was designed to cover a wide range of flow conditions to describe the variation in water quality with streamflow. However, because of limited sampling frequency and below-normal streamflows, efforts are made to sample during runoff events to document conditions when suspended constituent concentrations are likely to be at a maximum. In addition to periodic water quality sampling, the two Clark Fork stations at Deer Lodge and Turah Bridge are operated as daily sediment sampling stations to describe the suspended sediment transport characteristics in the upper basin. Funding for the periodic water quality sampling and daily sediment sampling stations has been provided by both state and federal sources since 1985. The EPA is funding the sampling during 1988. A sampling program was also conducted by the USGS from July 1986 to April 1987 to measure suspended sediment loads entering and leaving Milltown Reservoir during the Phase I emergency reconstruction of the Milltown Dam. As part of this effort, three daily sediment stations were operated, two upstream from the reservoir (Clark Fork at Turah Bridge and Blackfoot River near Bonner) and one downstream from the reservoir (Clark Fork above Missoula) (Figure 3-15) . Daily sediment sampling at these stations was resumed when Phase II 3-62 < OS o < u a: W CL a. 3 CO u H o z 1-J a. < en u w 3 . 1 CO 00 00 u OS q; 3 O 60 )— < C Cl. •H Xi E Q ■_( 01 u >^ 3 o CO 3-62a reconstruction began in June 1988. During the Phase I rehabilitation of the Milltown Dam, the Montana Power Company monitored water quality in the Clark Fork and Blackfoot River upstream and downstream from the dam from July 14, 1986, to April 4, 1987 (MPC 1987a). In the summer of 1988, the USGS (under a contract with EPA) installed a continuous streamflow gaging station at the Perkins Lane Bridge and a seasonal streamflow gaging station at the Stewart Street Bridge. The USGS is also conducting periodic water quality sampling at Perkins Lane Bridge under the same contract. The water quality data collected by the USGS in the upper Clark Fork Basin from March 1985 to September 1987 are published in two data reports (Lambing 1987, 1988). The data represent primarily low-to-medium flow conditions as a result of less than normal runoff during most of the sampling period. However, one high flow from snowmelt runoff was sampled from February 24 to 26, 1986, which gave some indica- tion of the increase in suspended trace element concentra- tions during times of peak sediment discharge. ) MultiTech (1987d) conducted a surface water and point source investigation of Silver Bow Creek and the upper Clark Fork as part of the Silver Bow Creek Phase I RI. The study area extended from the Weed Concentrator outfall in Butte to near Garrison, Montana. Phase I field work was conducted from November 1984 to September 1985, with additional surface water samples collected in 1986. Metals studied included arsenic, cadmium, copper, iron, lead, and zinc. In August 1988, the MBMG began a short-term monitoring program in the headwaters area for DHES-SHWB. The objective was to collect data during short-qjuration, high-intensity thunderstorm events. Continuous monitors were installed at four sites to measure physical water quality parameters, including pH, specific conductance (SC) , DO, and temperature. These monitors have in-situ, internal data loggers that were set to record data every 20 minutes. They were installed near the USGS streamflow gaging stations at the Colorado Tailings, the Stewart Street Bridge, the Perkins Lane Bridge, and in Warm Springs Creek at Warm Springs. Field checks of the water quality parameters were conducted 23 times to compare with data obtained from the continuous monitors. Monthly depth composite samples were also collected at these stations for analysis of other water quality parameters (metals) . Some of these samples were collected during storm events and others were baseline samples. 3-63 In addition to the continuous monitors, a flow-activated automatic sampler was installed in August at the Stewart Street Bridge. This sampler is triggered when increasing streamflow reaches a predetermined level and then collects water samples at predetermined time intervals. This sampler was to be rotated around the four sites, but because of low streamflows and lack of storms, it was kept at the Stewart Street Bridge through September. It was then moved to the Colorado Tailings location and operated through October. Samples were collected during six storm events (both rain and snow) at these sites. The automatic sampler was removed at the end of October 1988 and the continuous monitors were removed in the first week of November 1988. Data are being analyzed by MBMG and should be available by February or March 1989. Current Surface Water Quality Current surface water quality conditions in Silver Bow Creek, the Warm Springs Ponds, and the mainstem Clark Fork are discussed in the following sections. The discussion of metals, sediment, and nutrients draws primarily from Silver Bow Creek RI , DHES-WQB, and USG3 data. Much of the WQB data is presented in the form of box plots. These plots graphi- cally display the maximum, median, minimum, 25th percentile, and 75th percentile values as shown below. In cases where some of these percentile values are the same within a data set for a given station, percentile lines overlie each other. If all the values are the same, the plot is simply a horizontal line at that value, indicating either a small data set or no variation in measured values. ■Maximum -75th Percentile -50th Percentile (Median) -25th Percentile -Minimum In this discussion, water quality parameters are referred to both in terms of constituent concentration and constituent load. Concentration is the weight of a given constituent per unit volume of water, e.g., milligrams of phosphorus per liter. Load is the weight of a given 3-64 constituent transported by a stream or water discharge per unit of time, e.g., pounds of phosphorus per day. The key to the relationship between constituent concentrations and loads is the volume of water in the river. As the Clark Fork flows downstream, it is joined by numerous tributaries, and its volume becomes progressively larger. Each tributary contributes X number of pounds per day of material to the Clark Fork, which adds to the load of material carried by the river. However, the tributaries generally have lower concentrations of those materials than the Clark Fork, and their inflows help to reduce concentra- tions in the Clark Fork through dilution. This is how a tributary like the Bitterroot River can be a major source of nitrogen loading to the middle Clark Fork, while at the same time cause a reduction in nitrogen concentration in the middle Clark Fork. The WQB monitored water quality constituents and stream- flow at each of a number of mainstem locations along the Clark Fork. Measurements were taken once to twice per month from August to March and twice per month from April to July. Monitoring was carefully timed according to streamflow and other factors that would influence water quality. This increased the probability that the data were representative of the time interval (month or half month) . Monthly average constituent concentrations and streamflows were estimated by averaging the instantaneous measurements that were made during each month. Where USGS gaging stations corresponded with WQB sampling sites (most stations) , monthly average streamflows based on continuous measurement were provided by the USGS. These monthly average flows were used to replace the instantaneous average flows. Monthly constituent loads were then computed and summed to provide approximations of total annual loads at each monitoring location. Water quality criteria and federal drinking water standards discussed in this section are provided in Tables 3-15 and 3-16, respectively. Heavy Metals Copper and zinc are potentially the most hazardous metals in the Clark Fork system due to their toxic effects on aquatic life. Except at very high concentrations, the presence of copper and zinc does not preclude other water uses. Copper is more toxic than zinc and is a slightly ,^ , greater problem in the Clark Fork. Zinc concentrations, however, are typically higher than copper concentrations throughout the system. Synergistic effects of both copper and zinc (effects that are greater than the combined 3-65 TABLE 3-15. WATER QUALITY CRITERIA FOR KEY PARAMETERS Parameter Beneficial Uater Use Protected Criteria (Concentrations in ug/l except where noted) Reference Copper Zinc Arsenic Suspended sediment Freshwater aquatic life Freshwater aquatic life Freshwater aquatic life Freshwater fisheries Acute (1-hour ave. cone. )-18(HD)* Chronic (4-day ave. cone. )-12(HD) Acute (1-hour ave. cone. )- 120(HD) Chronic {4-day ave. cone. )- 1 10(HD) Acute (1-hour ave. cone.)-360 Chronic (4-day ave. cone. )- 190 High level of protection <25 mg/l Moderate level of protection 25-80 mg/l Low level of protection 80-400 mg/l Very low level of protection >400 mg/l EPA 1985a EPA 1987a EPA 1985a NAS-NAE 1973 * HD Hardness Dependent. 100 mg/l used TABLE 3-16. FEDERAL DRINKING UATER STANDARDS FOR PUBLIC WATER SUPPLIES Parameter Primary Standards Maximum Contaminant Levels for Inorganic Chemicals (ug/l) Secondary Standards Recommended Maximum Contaminant Levels (ug/l) Arsenic Cadmium Copper I ron Lead Zinc Nitrate as N Color PH SO 10 50 10,000 1,000 300 5,000 15 (color units) 6.5 - 8.5 (standard units) Sources: EPA 1986 a,b. 3-65a individual toxicities) are an important concern that has yet to be quantified for the Clark Fork. Arsenic is also present in the system, and while the federal drinking water standards are occasionally exceeded at some locations, aquatic life criteria are rarely surpassed. A variety of analytical techniques for heavy metals analysis is used by the agencies that monitor water quality in the basin. These are summarized in Table 3-17. Because some techniques are more rigorous than others and yield higher values, it is often difficult to make comparisons among data sets. The current EPA metals toxicity criteria for the protection of freshwater aquatic life give threshold levels in terms of total recoverable concentrations. Although the WQB monitors for total recoverable metals, it should be noted that the EPA and USGS total recoverable analysis method differs from the WQB total recoverable method in that a soft digestion is performed prior to sample analysis. This process releases a certain quantity of sediment-bound metals that may be present in the sample. The WQB method consists of field acidification of the sample followed by analysis. This method is comparable to the EPA acid-soluble method, which is compatible with nearly all available data concerning toxicity and bioaccumulation of metals by aquatic organisms. The EPA criteria are based on total recoverable concentra- tions instead of acid-soluble or other forms, because sediment-bound metals in a wastewater discharge can eventually become bioavailable in a receiving stream as the chemical and physical properties of the wastewater change upon mixing. The WQB total recoverable method is suitable for surface waters but could underestimate the toxicity potential of metals present in wastewaters. Silver Bow Creek. MultiTech (1987a) reported that the Metro Storm Drain (MSD) was the most severely contaminated part of its study area, which extended from the Weed Concentrator outfall in Butte to near Garrison, Montana. Total cadmium and zinc concentrations regularly exceeded federal drinking water standards. Other contaminants exceeded the standard less frequently. During a storm event in May 1985, all the measured total metal concentrations exceeded federal drinking water standards at most of the Silver Bow Creek (SBC) stations sampled. Aquatic life criteria for copper and zinc were regularly exceeded at most SBC stations. An organic contaminant of concern, penta- chlorophenol, or PCP, was detected at a site below the Montana Pole Treatment site and exceeded the drinking water lifetime health advisory for adults (0.22 milligrams per liter [mg/1]) on one occasion (MultiTech 1987a). Major 3-66 TABLE 3-17. ANALYTICAL TECHNIQUES USED FOR HEAVY METALS WATER QUALITY ANALYSIS State of Montana Total Recoverable 1. Acidify sample upon collection to a pH of <2. 2. Decant off at time of analysis (no filtration) Acid-Soluble 1. Acidify sample upon collection to a pH of <2. 2. Filter sample with .45u filter within 24 hours. 3. Analyze. EPA Dissolved 1. Filter sample with .45u filter at time of collection. 2. Acidify to pH of <2. 3. Analyze. 4. EPA and USGS Total Recoverable 1. Acidify sample at time of collection to a pH of <2 2. Digest in the laboratory using hydrochloric acid. 3. Filter sample. 4. Analyze. EPA Total 1. Acidify sample upon collection to a pH of <2. 2. Digest in the laboratory using hot nitric acid. 3. Analyze. Sources: USGS 1982; EPA 1983. 3-66a contaminant sources for the Silver Bow Creek study area identified by MultiTech (1987a) are summarized in Table 3-18, TABLE 3-18. SUMMARY OF CHARACTERIZED AND POTENTIAL SOURCES OF CONTAMINATION TO SILVER BOW CREEK Potential Source Type Contaminants Metro Storm Drain Point Source Missoula Gulch Point Source Browns Gulch Butte WWTP Montana Street to Colorado Tailings Mill-Willow Bypass Colorado Tailings to Silver Bow Siding Ramsay Flats to Opportunity Point Source Point Source Nonpoint Source (ground water inflow) Nonpoint Source (ground water inflow) Nonpoint Source ( re-entrainment) Nonpoint Source (re-entrainment) Cd,Cu,Fe,Zn,S04 Cd,Cu,Pb,Zn, (low flow) Cd,Cu,Pb,Zn,Fe, As,TSS (high flow) As,Fe,Pb,TSS (high flow) Total P, Orthophos- phate (Cd,S04,Zn during ground water pumping) As , Cd , Cu , SO4 , Zn Fe,S04,Zn Channel sediments Channel sediments Source: MultiTech 1987a. Water Quality Bureau FY 1985-87 investigations indicate that Silver Bow Creek from Butte to the Warm Springs treatment ponds is seriously polluted with copper and zinc on a year-round basis. The highest concentrations of both copper and zinc in the Clark Fork Basin occurred in this area. A large portion of the metals load is attenuated in 3-67 the Warm Springs Pond treatment system, but when Silver Bow Creek bypasses the ponds during high runoff events, it is clearly a significant source of metals to the mainstem Clark Fork. Aquatic life toxicity criteria for copper and zinc (EPA 1985a, 87a) were exceeded in all samples from Silver Bow Creek, and annual average concentrations were ten to more than 20 times the threshold levels. Arsenic concentrations were commonly an order of magnitude less than either copper or zinc. Aquatic life criteria for arsenic were not exceeded in Silver Bow Creek or the mainstem Clark Fork during FY 1985-87 WQB sampling. Figure 3-16 shows FY 1985-87 total recoverable copper concentrations at stations 1-3 above the Warm Springs Ponds and at the Pond 2 discharge (station 4) . Stations 1-3 had very high concentrations with the median values about ten times higher than the chronic copper criteria for aquatic life. Station 4 values illustrate the dramatic decrease in copper concentrations due to attenuation by the Warm Springs Ponds, with a median value right at the chronic copper criterion. Warm Springs Ponds. As mentioned previously, the Warm Springs Ponds were constructed by the Anaconda Company in an attempt to limit the downstream effects of mining. A number of investigations have addressed the pond system and its effect on the water quality of the Clark Fork, including: Casne et al. 1975; Botz and Karp 1979; Hydrometrics 1983c; and others. However, these studies do not reflect current conditions, and very few of them collected samples from enough stations to identify contaminant sources or to complete a mass balance analysis of the pond system (MultiTech 1987a) . Data on the Warm Springs Ponds were collected for the Phase I RI Superfund investigation from November 1984 to September 1985. Additional, but limited surface water quality data were collected above and below the pond system in 1986. Field data collected included pH, temperature, conductivity, and flow (where appropriate) . Water and bottom sediment samples were analyzed for major cations, major anions, and selected trace elements. Meteorological data were collected and surveys of the pond bottoms were performed to aid in volumetric calculations. The Warm Springs Ponds generally act as a sink for sediment, total metals, dissolved metals, and nutrients. However, the ponds are not 100 percent efficient in trapping metals delivered by Silver Bow Creek and the Opportunity 3-68 5.000 g 1.000 a. 3 o 100 10 + Chronic Toxicity Criteria for Cu (EPA 1985a) (criteria vary based on water hardness) 1 STATIONS CLARK FORK BASIN STUDY SAMPLING LOCATIONS I SBC baloo Coiorado Tallinqi 3 SBC AC Sll*s Croasuiq ii««r KmmMtrf 3 sac «tx>«* Wan Spcmqa (ACS) traacaanc 4 ACa Tont 12 dl>char9« (SUvar Bov Craak) (See Figure 3-14 for station locations) Source: DHES-WQB FY 85-87 data. FIGURE 3-16. TOTAL RECOVERABLE COPPER CONCENTRATIONS IN SILVER BOW CREEK 3-68a Ponds discharges and can be considered a source of contamina- tion to the Clark Fork. The metals-removal efficiencies of the pond system during the Phase I RI study period exhibited seasonal variation. In the summer months, the ponds showed high metals-removal efficiencies, presumably due to low input rates and higher pH. During the period of June 1 to September 15, 1985, the removal efficiencies for total copper and total zinc were 97 percent and 96 percent, respectively. The drop in pH that occurred during the winter months and possibly other factors, such as channeling, may have allowed more dissolved cadmium, copper, and zinc to pass through the ponds without being precipitated, resulting in lower metals- removal efficiencies. Because the initial remedial investigation was under- taken during a period of drought and low streamflows, the influence of typically high spring runoff inflows to the pond system was not thoroughly evaluated. However, higher flows during the spring lowered the pond's efficiency due to higher contaminant loads and reduced residence times. Solid phases of copper, iron, and zinc, as well as arsenic and lead, were released in large quantities during this period. It appears that the hydrologic regime and algae populations (which influence pH and bioaccumulation of metals) are the most important mechanisms governing the contaminant load the ponds deliver to the Clark Fork (MultiTech 1987a) . Phase II RI surface water investigations at the Warm Springs Ponds focused on the collection of surface water samples at key locations within the area at regular intervals throughout a 2 4 -hour period. - These diurnal samplings were conducted in September 1987 and in January, April, and July 1988. The objective of the samplings was to determine the efficiency of the pond system in removing metals from Silver Bow Creek through a 24-hour period on a seasonal basis. Field parameters measured included pH, EC, DO, and tempera- ture. Three forms of the metal contaminants (total, acid- extractable, and dissolved) were analyzed to determine the bioavailability of metals travelling through the system and to better define the behavior of metals constituents over a 24-hour time interval. A data report on the diurnal samplings is expected to be released in early 1989. Water Quality Bureau monitoring data show that the Warm Springs treatment ponds are extremely effective at decreasing metals loads, concentrations, and toxicity in Silver Bow Creek. On the average, treatment provided by the ponds decreased annual Silver Bow Creek copper loads nearly 12- fold and zinc loads about 5.5-fold during the 1985-87 period. Metals concentrations in the 'creek, after passing through the pond system, were an order of magnitude less. From 1985 to 87, copper toxicity criteria were exceeded slightly more than 3-69 half the time in Silver Bow Creek downstream of the ponds, and annual average values were not much higher than the criteria. Thus, copper criteria exceedences tended to be frequent but slight. Zinc toxicity criteria were not exceeded in FY 85 or FY 87 and were only infrequently exceeded in FY 86. The worst water quality occurs in winter due to lower pH and decreased efficiency of the treatment ponds caused by channeling, ice cover, and colder water temperatures. The Pond 2 discharge was the largest contributor of contaminant loads to the Clark Fork during the Phase I RI and significantly degraded water quality with sulfate, copper, zinc, iron, and lead. This may have been due in part to the low-flow conditions that occurred in 1985. The Mill-Willow Bypass discharge also contributed elevated concentrations of sulfate, copper, zinc, iron, and cadmium (MultiTech 1987a) . This has also been documented by WQB sampling, which shows that metal concentrations in the bypass (when Silver Bow Creek is not bypassing) are highest during snowmelt runoff and after heavy rains. Presumably, the tailings deposits in the bypass are the source of these metals. During FY 1985-87 WQB sampling, the bypass had the highest arsenic concentra-r tions of the stations monitored, and the federal drinking water standard was exceeded periodically. However, federal drinking water standards for arsenic, cadmium, copper, iron, lead, and zinc generally were not exceeded during the Phase I RI, neither in discharges from the Warm Springs Ponds to the upper Clark Fork, nor within the ponds. The four-day (chronic) aquatic life criteria for cadmium, copper, lead, and zinc, and the one-hour (acute) aquatic life criteria for zinc were exceeded occasionally throughout the ponds. The acute aquatic life criteria for copper were usually exceeded within the pond system, but were not exceeded in discharges to the upper Clark Fork. Waters of the Mill-Willow Bypas^ exhibited chronic aquatic life toxicity with respect to copper and zinc concentrations and acute aquatic life toxicity with respect to copper- concentrations. Silver Bow Creek and the Opportunity Ponds surface discharges are the principal sources of contaminants for the pond system (CH2M Hill 1987d) . Upper Clark Fork. Some general observations of the geographic and hydrologic variations in trace element concentrations can be made from USGS data collected in the upper river (Figures 3-17, 3-18, and 3-19). Differences in height between the dissolved and total or total recoverable bars on the graphs represent the concentration of trace elements transported in suspension. 3-70 (9 O (O CM 00 y3in y3d st^vaooyoiiN ni 'NoiivyiN30Noo oiN3sav 00 Cl, W CO o H 00 z^ ON ■^ »— je' X O u o OS J O t3 ^ Q 7> U* '^ o V V to 0 z 7^ o l-l ^ < K^ ^ O H O Z •^, © o z <3> O, o 1, -^ z < Q U P ■<:. 3 0 r~ =^c T f*1 \>' U t oc 3 ^ o •6 b 3-70a CD O 'V- CJ> % CD 5 ^ o % 'fe V»' 0 ^ o o o in o o a mm y3d siNvyooyom ni 'NoiivyiNBONOo Hiddoo % in 00 ON a u Qd OS Ci] a. Qu o u U] _) < OS w > o u bJ H o Q 2 < Q > o 173 C/3 O t/3 z o (-< H < ac: H Z o 00 ON > t3> O z ca o s ij "^ H Z (X ^ » < w f-l CO w ^ Q O l^i W O 0) '> S H p -o 00 ^ m 3-70b o o o 00 o to o o mill Hid smuoohom ni 'NouvaiNioNoo oniz O H in 00 ON • — s u « V Ol) 7^ M •^ u z Jk^ (-* O N O <3> O ►J f. -a^ ^ > o o % u OS -J < O O > a < > -J c eft t3 to »— 1 •<, a %, b. '^ o \y v* en CD z 7^ o i-H c^ < *u 0£ o Hf^ o ZOO *^, W ff- o — ffi o. z <5> O O06 z s < u C£> > c a. P ) -o o> ;^ 1 ^ ro \>' W ^o r "^ t3 bu 3-70c The median concentrations of total arsenic were not significantly higher than the dissolved phase at most sites (Figure 3-17) , which indicates that much of the arsenic was dissolved in the waters during most flows. The highest median concentration of total arsenic among the six stations was 17 ug/1 at Deer Lodge, which represents a 5 ug/1 difference between the median dissolved and total phases. In contrast, a greater proportion of copper was present in the suspended fraction (Figure 3-18) , which illustrates the greater affinity of copper to the sediments. The highest median concentration of copper also occurred at Deer Lodge, with a total recoverable value of 59 ug/1. Similarly, zinc also is transported primarily in suspension (Figure 3-19) . As with arsenic and copper, the median concentration of zinc was highest at Deer Lodge, with a total recoverable value of 80 ug/1. Samples collected during the February 1986 snowmelt represented the maximum concentrations measured by the USGS from 1985 to 1987. Total or total recoverable concentrations of arsenic, copper, and zinc during this event were substan- tially higher than median values. Arsenic concentrations during the February snowmelt were highest at Deer Lodge, with a total arsenic concentration of 130 ug/1, compared with a median of 17 ug/1. The maximum concentration of total recoverable copper was 630 ug/1 at Deer Lodge, compared with a median of 59 ug/1, which represents more than a tenfold increase during runoff. More than 95 percent of the copper at Deer Lodge was transported in the suspended phase. Maximum zinc concentrations were also measured in the mainstem, but the highest total recoverable value of 1,100 ug/1 occurred at Turah Bridge. ' The total recoverable zinc concentration at Deer Lodge was 770 ug/1. Arsenic, copper, and zinc concentrations in the tributaries during this period were only slightly to moderately higher than median con- centrations. A general observation from the median and maximum measured concentrations is that the sampling station farthest upstream, Clark Fork at Deer Lodge, typically has the highest concentrations, presumably due to its proximity to the major headwater tailings sources. Flint Creek also has relatively high trace element concentrations, probably as a result of historical and current small-to-moderate-scale mining in its basin. Lower trace element concentrations are typical of the Little Blackfoot River and Rock Creek. These tributaries aid in diluting the concentrations of trace elements in the Clark Fork mainstem, which has generally lower concentra- tions downstream at Turah Bridge compared with Deer Lodge. 3-71 The Blackfoot River also has low trace element concentra- tions, despite some abandoned mine areas in its upper basin. Because of their large flow contributions and relatively low trace element concentrations, Rock Creek and the Blackfoot River improve the water quality of the mainstem. Water Quality Bureau data indicate that water quality varies considerably within different sections of the upper river reach. Water quality is much improved below Warm Springs Creek through a direct dilution of metals concentra- tions and as a result of increased water hardness and alkalinity that buffer the effects of metals. Warm Springs Creek drains a limestone formation that contributes to its high hardness and moderate alkalinity. Unfortunately, Warm Springs Creek is severely dewatered for irrigation and it is frequently nearly dry in the months of July and August. Metals concentrations in the Clark Fork tend to decrease from its point of origin at Warm Springs to Dempsey, presumably as a result of dilution from cleaner tributaries. The copper criteria (Figure 3-20) were exceeded less than half the time, and exceedences that did occur were usually slight. Zinc criteria were rarely exceeded. From Dempsey to the Little Blackfoot River, water quality progressively deteriorates, especially during winter and spring months. Metals concentrations and frequency of exceedences of the aquatic life criteria tend to increase, despite the entry of additional clean-water tributaries. The copper criteria were exceeded up to half the time during the monitoring period in the Clark Fork above the Little Blackfoot River, with some measurements exceeding the criteria several-fold. Despite an increase in zinc concentrations, criteria were infrequently exceeded. Average annual copper loads (Figure 3-21) increased by as much as 6.5 times, and zinc loads (Figure 3-22) increased by more than three times in the Clark Fork from Warm Springs to some 15 or more miles below Deer Lodge. Metals sources are streamside tailings deposits and possibly inputs from contaminated ground water. The rate of increase in metals loading seems to be consistent progressing downstream in the reach from Warm Springs Creek to Deer Lodge. However, from Deer Lodge to the Little Blackfoot River, a major increase in loading occurs. This may correspond to the presence of a major ground water recharge zone and the presence of localized tailings deposits in the river floodplain. Conditions generally improve in the Clark Fork from Garrison downstream to the Blackfoot River as the contribu- tions of clean water from major tributaries such as the Little Blackfoot River and Rock Creek dilute metals con- centrations and metals sources become less significant or are 3-72 T — r Trr T-i — r II I I I I 1 — r u o -rr I fs M.S c ■ jc E li a i o i ^ * o > ^ Si 1 Ss — •> oO c S » tC — i> S — — » ^ « « O n ID A 'S CC OC E IE (C E 2 u. u. u. u. u. u. uu u u u u u i2 S 2 SIee cog* « « o Q ' ." " 5 ra ! c e 5. o o o "O X •) C ~ C o CO )-> 03 o Jtl§.| 7 a. 0) > £ n 3 3 > Q Q Q fC 0 ID C E u. u. O O E E U. U. o o 0053 £ £ O ■ t- 1- r o • J S 8 o ° £ S £ a> o • a ^ A ^ E E E E u. u. u. u. 0000 I 01 3 01 01 CA J / 1 1 1 fT >-!' 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The Blackfoot River joins the Clark Fork just above the Milltown Dam, and its clean water further dilutes metals concentrations in the middle Clark Fork segment. However, in the Clark Fork just below Milltown Dam, these benefits are sometimes masked. Elevated metals levels periodically occur in association with operational drawdowns of Milltown Reservoir that result in the loss of metal-bearing sediments from the reservoir. More recently, short-term increases in metals levels below the dam have been associated with reconstruction of the dam's aged spillway, which was severely damaged during the major runoff of February 1986. The occurrence of sediment -metal events resulting from drawdowns will be reduced by the completion of the Milltown Rehabilitation Project. The installation of a radial gate and fixed wheel panels will allow the control of runoff up to 28,000 cfs without drawing down the reservoir. A drawdown will be required only if streamflow exceeds 28,000 cfs, which is an event that is expected to occur on the average of about every 14 years. These high flows will cause flow control gates to open to accommodate the increased water quantity. A drawdown of the reservoir is necessary to reset the gates once the high flows recede. The Montana Power Company believes, based on past experience, that such a drawdown will cause less sediment loading than previously occurred because such high flows (greater than 28,000 cfs) will have removed much of the susceptible sediment from the reservoir. River monitoring by the Montana Power Company revealed a brief increase in zinc concentrations in March 1987 before the onset of the runoff period. Concentrations of 1,72 0 ug/1 and 1,120 ug/1 acid-soluble zinc were measured at Turah on March 5 and 6, 1987 (MPC 1987a). River flow at Turah increased 50 percent from 787 cfs on March 3 to 1,180 cfs on March 5 after being stable (609-836 cfs) since January 1. Total suspended sediment increased from 39.7 mg/1 on March 4 to 88.8 mg/1 and 88.9 mg/1 on March 5 and 6 at Turah. Acid- soluble copper was less markedly elevated to 50 ug/1 on both days — up from less than 10 ug/1 on March 2, 1987. Middle Clark Fork. Water Quality Bureau data indicate that metals concentrations in the middle Clark Fork are generally much lower than those in the upper Clark Fork (Figure 3-20) . This is likely due to fairly large volumes of clean dilution water provided by the Bitterroot and St. Regis rivers and increasing distance from metals sources. Exceedences of copper criteria were generally infrequent, slight, and short-lived in this reach. Zinc criteria were exceeded only once in the three-year monitoring period (in February 1986) . 3-73 Monitoring by MPC in early March 1987 downstream from Milltown Dam and the confluence of the Blackfoot River showed moderate concentrations of acid-soluble zinc. River values on March 5 through 9 were 370, 220, 410, 980, and 50 ug/1, respectively. These findings indicate that a water quality event that may control young fish survival may be triggered by the first rapid increase in river flow after the stable flow period of winter. Additional monitoring needs to be performed during this time of year to determine if early snowmelt events occur regularly and if they are an important element in the Clark Fork fishery problems. Lower Clark Fork. The Flathead River more than doubles the volume of the Clark Fork, on the average. The result is a dramatic improvement in the water quality of the Clark Fork below the confluence. During the WQB monitoring period, copper criteria were rarely exceeded in samples from the lower river section and have not been documented below Thompson Falls. As shown in Figure 3-20, copper concentra- tions were stable and quite low at all four stations. Exceedences of zinc criteria have not been documented in the lower river. Suspended Sediment The amount of sediment in a river is important because of its potential effect on beneficial uses of the water. A large volume of sediment in a system can adversely affect aquatic life and interfere with water treatment and irriga- tion. Other pollutants, such as nutrients and metals, can be adsorbed onto sediment particles and transported by them into and through aquatic systems. Suspended sediment transport in running waters is difficult to quantify accurately, especially in a river system as complex and as large as the Clark Fork watershed. Suspended sediment concentrations and loads in the Clark Fork system are strongly influenced by variations in streamflows and intensity of runoff events. Each of the three years monitored was characterized by lower than normal runoff, on the whole. FY 85 and 87 were particularly low streamflow years, and suspended sediment production, transport, and severity of problems were generally low. Conversely, the rapid snowmelt event of February 1986 created unusually high mid-winter streamflows and excessive sediment concentrations. A large percentage of the estimated annual suspended sediment load was transported during this relatively short-duration event. Total annual suspended sediment loads and mean concentrations in FY 86 were well above FY 85 or 87 values, due primarily to the February snowmelt event. 3-74 The USGS uses cross-sectional depth-integration techniques to sample suspended sediments during both high and low streamflows. The WQB uses the Equal Width Increment (EWI) depth-integration technique. However, most of the WQB monitoring stations located below Garrison are too deep to wade, as are some of the upper stations during runoff conditions. In those instances, samples are depth-integrated to the limit of wadeability, and as a result, only a portion of the channel cross-section is sampled. In some cases, suspended sediment samples are grab-sampled, but only when streamflows are low and sediment concentrations negligible. The emphasis of the WQB Clark Fork water quality assessment has been comparisons with aquatic life criteria because those standards are usually more conservative than the criteria established to protect other water uses. However, it is a difficult proposition to establish aquatic life criteria for suspended sediment concentrations, because impacts are a function of duration of exposure as well as concentration. For example, most Montana streams carry appreciable suspended sediment concentrations during the usually short period of sprin'g runoff. Resident aquatic life forms are adapted to these annual events and are able to tolerate them. The same conditions sustained over a longer period of time could significantly degrade the aquatic habitat. Because the periodic sampling programs are limited in their ability to measure the duration of suspended sediment concentrations, the WQB instantaneous data are compared to simple criteria that are not based on duration of exposure. The National Academy of Sciences-National Academy of Engineering (1973) has published the following suspended sediment guidelines for the maintenance of freshwater fisheries. The frequency of distribution of measured values among the various categories is the basis for the WQB assessments in this report. Water normally containing suspended sediment concen- trations of: <25 mg/1 High level of protection; no harmful effects on fisheries. 25-80 mg/1 Moderate level of protection; good or moderate fisheries. 80-400 mg/1 Low level of protection; unlikely to support good fisheries. >400 mg/1 Very low level of protection; only poor fisheries. 3-75 USGS suspended sediment data jfor the upper river and WQB data for the entire drainage are summarized below. Silver Bow Creek. Water Quality Bureau data indicate that Silver Bow Creek has a severe inorganic suspended sediment problem. Concentrations were highly variable in FY 85-87 (Figure 3-23) , and for its size, sediment production was high, presumably as a result of the preponderance of unvegetated mine tailings in the floodplain. The suspended sediment criterion to maintain a high level of protection for freshwater fisheries was exceeded in 11 to 64 percent of the samples, depending on the year and the monitoring location. Various stations fell in the low level of protection category in up to 11 percent of the samples. Suspended sediment concentrations, loads, and problem severity generally increased from Butte downstream to above the Warm Springs Ponds. The Butte WWTP discharge was responsible for an increase in organic suspended sediment in Silver Bow Creek for several miles below the outfall. However, organic concentrations were only a fraction of the total suspended sediment concentrations. Warm Springs Ponds. The Warm Springs Ponds caused major reductions in Silver Bow Creek's suspended sediment con- centrations through their function as large settling basins. Estimated annual total suspended sediment loads in Silver Bow Creek in FY 86 and 87 were decreased fourfold to sixfold from above and below the ponds, and up to 2,000 tons of material were trapped in one year. From the standpoint of fisheries protection. Silver Bow Creek suspended sediment concentra- tions below the ponds were consistently good. Upper Clark Fork. Median suspended sediment concentra- tions for March 1985 to September 1987 at the six USGS sampling stations were low, ranging from 8 mg/1 in the Blackfoot River to 36 mg/1 in Flint Creek. These values indicate that the quantities of sediment transported during most flows of 1985-87 were minor. Considerably higher concentrations can occur during high-flow conditions, with the highest values measured in the Clark Fork mainstem during the February 1986 snowmelt runoff (1,390 mg/1 at Deer Lodge and 1,370 mg/1 at Turah Bridge). The large differences in concentration between median and runoff conditions indicate that the amount of suspended materials transported is highly variable, with short-duration events possibly representing a significant portion of the annual load. 3-76 500 1^ bJ °- 100 w < O 3 10 r bJ O Z o u (0 Source: DHES-WQB FY 85-87 data. 2 3 STATIONS CLARK FORK BASIN STUDY SAMPLING LOCATIONS 1 SBC baiow Coiocado Tailinqa 2 SBC ac MXlvs Crossing naar RajMsay 3 SBC above Want Spcinqa (AOl) traaMenc ponda 4 ^CH Pond 12 discharg* (Silv*c Bo» Cmk) (See Figure 3-14 for station locations) FIGURE 3-23. TOTAL SUSPENDED SEDIMENT CONCENTRATIONS IN SILVER BOW CRF.EK 3-76a Figure 3-24 depicts the range of suspended sediment con- centrations in the Clark Fork during the WQB monitoring period. There were general increases in concentrations and reduced fisheries protection in the upper Clark Fork from the headwaters downstream to monitoring station 12, the Clark Fork at Bonita. The plots of total and volatile suspended sediment load (Figures 3-25 and 3-26) point to the stream reaches between monitoring stations 9 and 10 and 11 and 12 as possibly containing significant sediment sources in the upper Clark Fork, especially during FY 86. The worst overall reach in the upper Clark Fork from the standpoint of fisheries protection was from station 10 to station 12. Suspended sediment concentrations fell in the moderate to low levels of fisheries protection categories in 27 to 55 percent of the samples. The presence of streamside tailings deposits and unstable streambanks throughout the upper Clark Fork are the probable causes. Rock Creek, located between monitoring stations 12 and 13, is a large tributary that normally carries low concentra- tions of suspended sediment. Clark Fork median suspended sediment concentrations downstream of the Rock Creek confluence were measurably decreased (Figure 3-24) at all times, except during the February 1986 flood. Concentra- tions were also significantly more favorable from the standpoint of fisheries protection. Downstream from station 13, the Blackfoot River joins the Clark Fork. This large stream equals the Clark Fork in size, and its suspended sediment concentrations average a quarter to half those in the Clark Fork above the Blackfoot. Its inflow, plus the Milltown Reservoir which is a large sediment trap, decrease Clark Fork sediment concentrations. However, during high-flow events and during past operational drawdowns and construction activities, the settled sediments in the reservoir were mobilized and transported downstream. The reservoir is a significant sediment source in those instances. Organic suspended sediment concentrations were generally low throughout the upper Clark Fork and averaged a small fraction of the total suspended sediment concentration. The Deer Lodge sewage discharge appeared to cause measurable though small increases in Clark Fork organic suspended sediment concentrations for several miles downstream of the discharge. 3-77 II I I I I i — r h I I CD •O r» 00 I in 00 b C I w u ac a 4) U U 3 O CO I u a c E ceo I ™ j; •> D Q ' " " -2 §1 • u. It 3 •-^ , o o " C3 •> « cc - ! g-o-c • : k E o i : o o >< ^ . 1- 1- Z O I ; » * * > o ° ° 5 1 ^ V «> V 1 a ^ ^ A : C IT C C . u. u. u. u. > o u u u I CO (U u 3 = o. 8 E5 c lltow Issou eld's rBrld or t <0 SS= ^§ 5 > a> 3 ir « a S > C «> 3 3 £ O U) X X U) » A _ _ _ _ A a CO « cB a cc oc IT ir c cc U. U. U. U. 11. 11. f ^ ■>« ^ ♦- »- W W Ol o CO oo CM 1^ CM in CM CM CM CM O CM CD t I 5 ° > o O o ™ E "^ = • _ — » »o c 5 ■5 «> > .n o 3 O □ O '^ O )- u: _ .a o - - „ « a O IB « 'S (c E ce ce s 2 u. u. u. u. u. u u u u u u o o o "I'll' I " I ' ' I I' I ' I I I L CO CM CO (0 ^ CO o> tic2 Cl- W I c < Li H Q W w Q a W o. CO O" ►J < H O H I ro CO o o SSI ^^Ml ''3d suiej6!||!|/\| 3-77a I \ \ \ \ \ \ \ \ I CQ I M •j3 X Q 01 u u a o w o 5) Cf) >- I CO In o "0 !-!_ / ^ \^ 3) CM U. O CO M ! - r>- ^ u ••V Y— VM u. u 0 -* ?0 1 T— cn Li. O u M Ll T— ^m» 0) 1- 0) 'I CO U o Li CJ Ll: _! ^ < u >> CA o z .J a. CO I z o o (d CO < CQ CO u H H CO Of o &<: < u u X H o o o n o CO o CO C\l o M o CM O O O CO O CO o o c o so 3 CO ^^ '"^ ^^ ^^ W«f >mJ (spuDsnoMj.) CM I td 3-77b CO •o 00 00 >- m CQ C I w u Q U 3 O i\ \ \ \ \ \ \ \ \ \i K \ ^s \ ^v ^. \ \ \ \ k \ \ ! ;^ CI CD V c ■1 I 91 I \ I K I in o 1 I 'O L_ o "1 CvJ U. o CO f\ 1 Li. o r» CM - ' o lO I.N ^', O !-T CSi iJL ^-N (? CO fj c o S'* •r^ U- U CJ cd o o C) a r;T c o 0 ••^ 4J Rt ■••^ 4J C CO 03 ^M Li. 7- Ui f") o ,rs ~ IM n T— -;!■ 1..^ r n 0 2 M lU u 3 M 60 U. U. o 0) ^ (U <— tn iiJ o ^~ u. iJ a g C) a. u a 1. CO II .• % t i; a < w >< 10 z .J s < I z o a u CA CO u H H CO u B£ O :^ OS < u u s H H z Id a u CO o Id Q Z Cd CU CO =3 CO Cd >J H < .J O > tb o CO o < o .J <: 3 z z < 3-77c \0 CM I en Id oc 3 O Middle Clark Fork. Suspended sediment concentrations in the middle Clark Fork from Missoula to the Flathead River (Figure 3-24) , can be described as generally decreasing in a downstream direction as a result of additional dilution from cleaner incoming tributaries, such as the Bitterroot River. Concentrations normally fall within the range that would afford a high level of protection to freshwater fisheries. Although Bitterroot River suspended sediment concentra- tions are lower than the mainstem, suspended sediment load plots (Figures 3-25 and 3-26) indicate that the Bitterroot River is the most significant source of sediment loading to the middle Clark Fork. Both the Missoula WWTP and Stone Container Corporation wastewater discharges contributed sizeable, largely organic suspended sediment loads to the middle Clark Fork. However, their influences on river concentrations and load were not measurable. Lower Clark Fork. Suspended sediment concentrations in the lower Clark Fork are shown in Figure 3-24. The Flathead River more than doubles the volume of the Clark Fork and routinely carries a lower suspended sediment concentration than the Clark Fork. As a result, suspended sediment concentrations measured in the Clark Fork downstream of the Flathead are reduced and nearly always fall within the highest category for fisheries protection. Farther down- stream, the Noxon Rapids Reservoir acts as a settling basin and is responsible for an even more significant reduction in Clark Fork suspended sediment concentration. The last reservoir in the system. Cabinet Gorge, has no apparent effect, presumably because most of the settleable solids have already been trapped upstream. In general, the lower Clark Fork can be described as excellent from the standpoint of suspended sediment concentrations,' largely as a result of dilution by the Flathead and the influences of the reser- voirs. Suspended sediment load plots point to the Flathead River as the only significant additional source of sediment to the lower Clark Fork. The reservoirs are responsible for reducing Clark Fork suspended sediment loads to less than those carried by the Clark Fork above the Flathead River. Other Water Quality Parameters c A number of parameters or conditions other than metals and sediment cause degradation of surface water quality in the Clark Fork, including ammonia, elevated temperature, dissolved oxygen, toxins, foam, and color. These are discussed in the following sections. 3-78 Ammonia. Ammonia is a form of nitrogen that is frequently associated with wastewater discharges. Ammonia or its degradation products are readily available for algal uptake and can contribute to nutrient enrichment problems . However, the primary concern with ammonia is that it can be extremely toxic to aquatic life under certain conditions of stream pH and temperature (EPA chronic ammonia toxicity criterion varies depending on pH and temperature) . The potential for ammonia toxicity downstream of wastewater dis- charges in the Clark Fork Basin has been closely monitored in the past and will require continued scrutiny. The Butte WWTP effluent is a source of ammonia to Silver Bow Creek. During WQB FY 85-87 sampling, the EPA chronic toxicity criterion for salmonid species (trout) was exceeded in one-third to two-thirds of the samples during the monitoring period for several miles below the outfall. Ammonia toxicity was not documented at any of the upper or lower Clark Fork stations during the monitoring period. The effluent from the Missoula WWTP is the largest source of ammonia in the middle river. Ammonia toxicity was not documented below the wastewater mixing zone during FY 85-87 WQB sampling. However, because of high levels of ammonia in the discharge and documented exceedences of the ammonia criterion within the mixing zone, further evaluation is being done by WWTP staff. The Frenchtown Mill wastewater also contains relatively high levels of ammonia. To date, exceedences of the criteria have not been documented. However, installation of the color-removal facilities has necessitated daily ammonia monitoring because wastewater dilution rates are lower when color-treated wastewater is being discharged. Temperature and Dissolved Oxygen. Stream temperature and concentration of dissolved oxygen affect the survival of aquatic life, particularly salmonids. If a fish is exposed to increased temperatures, more energy is required for basic metabolism, and less energy is available for food acquisi- tion, growth, and reproduction. Stream temperature is affected by many factors, including streamflow, air tempera- ture, exposure to sunlight, the ratio of surface area to volume, ground water inflow, and topography (Braico 1973) . Trout generally prefer temperatures between 52 °F and 64° F, while long-term exposure to temperatures above 75° F may be lethal . The amount of dissolved oxygen in streams is an important measure of water quality. Sufficient levels of oxygen are necessary to support a healthy and diverse community of organisms, including fish, aquatic insects, 3-79 other macroinvertebrates, and plants. Severe depletions of dissolved oxygen can cause fish and insect kills. Chronic- ally low levels can cause a decrease in diversity and quality of aquatic life (DHES 1985) . Montana Water Quality Standards (DHES 1988a) for most of the Clark Fork do not permit induced reductions of DO below 7 mg/1. Between Warm Springs Creek and Cottonwood Creek, DO concentrations cannot fall below 6 mg/1 from June 2 to September 30 or below 7 mg/1 between October 1 and June 1. The variables that affect dissolved oxygen levels include water temperature, biological activity such as photosynthesis and respiration, oxidation of inorganic compounds, decomposition of organic matter, and reoxygenation from water turbulence. These variables, along with diurnal and seasonal variations, interact in complex ways to determine instream dissolved oxygen concentration (DHES 1985) . Algae and other aquatic plants produce oxygen in sunlight and consume oxygen during nighttime respiration; therefore, very productive streams may have severe nighttime sags in DO (Braico 1973) . Although temperature and DO data for the Clark Fork are limited, several studies have been completed by the WQB. The first was done in August 1973, by Braico, who measured DO and temperatures at frequent intervals during a 24-hour period (called "diel" monitoring) at 12 stations along the Clark Fork and at single sampling sites on Rock Creek (near Clinton) , the Blackfoot River, and the Bitterroot River. The author reported the following results: • The highest temperature was measured in the Clark Fork just above the Rock Creek confluence where a maximum temperature of 76' F was recorded. Temperatures reached 72° F on the mainstem at Garrison, Drummond, and Turah. • Maximum temperatures in Rock Creek, the Blackfoot River, and the Bitterroot River were 68° F, 70° F, and 74° F, respectively. • At stations below the Bitterroot confluence, where the Clark Fork becomes quite large, stream temperatures were least affected by diurnal variations in air temperature. • The lowest DO concentrations of 5.9 and 5.2 mg/1 were observed in the Clark Fork at Deer Lodge and the Rock Creek Bridge, respectively. Conditions were critical at the latter station when high temperatures (above 68° F) and low DO levels coincided for over five hours. 3-80 DO concentrations were generally below saturation at all other stations except during periods of maximum photosynthesis. However, minimum values did not drop below 6 mg/1 at any of these stations, Braico attributed the results of the study to a combination of factors, including extremely low streamflow (less than half of normal) , loss of shade-producing bank vegetation due to highway construction, warm weather during the study, and heavy algal populations. Knudson and Hill (1978) summarized past data and collected new information on inutrients, dissolved oxygen, and algal accrual in the upper Clark Fork during 1976 and 1977. They concluded that summertime nutrient concentrations were elevated just below Deer Lodge and Missoula but were relatively low in other locations. Among the tributaries, only the Bitterroot had elevated nutrient levels. Lowest dissolved oxygen levels were recorded in late July and early August near Deer Lodge and Bonita. In 1984 and 1985, the WQB conducted a number of water quality studies in the Clark Fork between Turah and the Idaho border, partly in response to the controversy surrounding the discharge permit issued to the Champion International mill (now Stone Container Corp.). Five sampling runs provided ambient water quality data on DO concentrations. Because sampling was done at all hours of the day, the diurnal variability of DO may have masked the affects of deoxygenation caused by organic decomposition, making changes in DO difficult to interpret. However, the DO data suggested that much of the oxygen demand from the Champion discharge was satisfied within the mixing zone from the Champion outfall to Huson. The effects of instream dilution on the wastewater would diminish the oxygen demand to nearly unmeasurable levels (DHES 1985) . Diel DO monitoring runs were also conducted in August 1984 and 1985 to determine daily oxygen maximums and minimums at sites above and below the Champion mill. Results of this monitoring did not indicate a problem with DO levels in the Clark Fork. However, one run was conducted when the waste- water discharge was highly diluted, and the other was done during a period of no wastewater discharge. The data therefore represent only a narrow range of conditions (DHES 1985) . Self-monitoring data from Champion (a requirement of its permit) for the period of January 1984 to September 1985, revealed DO concentrations below 7 mg/1 on 12 days. No waste was discharged on nine of those days (DHES 1985) . 3-81 A study conducted in the summer of 1986 in the Clark Fork near the Missoula WWTP and Stone Container Corporation by Kerr (1987) involved two 24-hour diel surveys (July 8-9 and August 5-6) . Temperature and DO were measured at regular intervals at six stations on the Clark Fork. The objective was to determine whether wastewater discharges from the WWTP and Stone Container Corporation had a measurable effect on DO concentrations in the Clark Fork. The first survey was conducted during a period of high wastewater discharge, while the second occurred during a period of low wastewater discharge. Average DO concentrations varied considerably by site and survey. During low wastewater discharge, DO tended to increase in a downstream direction; during high wastewater discharge, it tended to decrease in a downstream direction. The largest change between any two consecutive sites during high wastewater discharge occurred between Shuffields and Harper Bridge and Huson and Alberton. The theoretical net oxygen loss during high wastewater discharge relative to low wastewater discharge was greatest at Alberton. Because the flow of the Clark Fork and weather conditions during the two surveys were quite different, the estimated losses of dissolved oxygen during high wastewater discharge could not necessarily be attributed to the volume of wastewater discharged by Stone Container. A diurnal DO survey was also conducted by the WQB in the upper and middle Clark Fork from July 29 to July 30, 1987. In the upper river, the lowest DO levels (about 70 percent of saturation) of the day occurred between midnight and two a.m. Watson (1988a) concluded that with current loading and algae levels, the upper river is at high risk for DO levels below the state standard of 7 ppm when nighttime water temperatures rise above 16° to 18° C and flows tall below 1,000 cfs at Turah and below 200 cfs at Deer Lodge. In the middle river, the lowest DO levels (about 80-90 percent of saturation) were observed between four and six a.m. Watson (1988b) concluded that the middle river would be at high risk for DO levels below the state standard when predawn temperatures rise above 18.5° C, and would be at risk at even lower temperatures in extremely low-flow years. Color and Foam. Wastewater discharges to surface water can cause increases in river color, particularly under low flow conditions. Kraft pulping processes generate wastewater that contains compounds that are known as foaming agents. Both increased color and foam are potential aesthetics problems in the Clark Fork (DHES 1985) . 3-82 Aesthetics monitoring (color, foam, sludge deposits, slime growth, odor, etc.) was conducted in the Clark Fork near Missoula during the 1984-85 WQB investigation. Results of analyses for river color indicated a general compliance with Champion's allowable five-color unit increase stipulated in its discharge permit. Color was the single most important factor controlling the rate at which Champion could discharge wastewater to the river. Although it reported occasional violations of the color standard. Champion considered it a high priority to reduce the volume and color of its effluent (DHES 1985) . Stone Container Corporation, which acquired the mill in 1986, installed a color-removal plant at the facility in February 1988. The technology, developed by the corporation, reduces color of the effluent by about 85 percent. This will allow the mill to meet color standards if it discharges during low-flow conditions. The chemical process also reduces the total suspended solids and nutrients (Stone Container Corp. 1988) . The new plant is operated seasonally only, due to the high cost of the additional treatment. During the 1984-85 WQB aesthetics reconnaissance, con- siderable quantities of surface foam were observed on the Clark Fork above and below Champion's discharge, in the Bitterroot River near its mouth, and in the Clark Fork from St. Regis to the confluence of the Flathead River. Foam occurs naturally in surface water, especially in streams draining forested regions, due to the presence of dissolved organic substances. Wood processing industries often increase the occurrence of foam because of wood-derived organic substances in their wastewater effluent. This problem was especially bad in the backwater areas below Champion's discharge in the fall and early spring. Steps were being taken to reduce foaming agents in Champion's effluent (DHES 1985) . Toxins. Substances in this category include organics such as PCP, PCB, oil and grease, and organic resin acids. PCP and PCB are of particular concern in the headwaters area. Silver Bow Creek has received waste oil containing PCP in the vicinity of the Montana Pole Superfund site (discussed earlier in this chapter) , and PCB is a potential contaminant from the Butte urban area (MultiTech 1987a) . During the Phase I Superfund studies for the Silver Bow Creek site, selected stations were monitored for PCP, PCB, and oil and grease. MultiTech (1987a) reported detectable concentrations of PCP at the monitoring station below the Montana Pole and Treatment site. 3-83 stone Container Corporation's wastewater contains organic resin acids that are potentially toxic. However, acute or chronic toxicity problems in the Clark Fork are unlikely, because its discharge permit stipulates a minimum river water to waste dilution ratio of 200:1 (if color- treated wastewater is discharged, the minimum dilution is 100:1) . Chronic bioassay tests on rainbow trout and Ceriodaphnia were conducted from May 31, 1985, to June 12, 1985, at the Champion mill site by EPA (Nimmo et al. 1985) . A 30-day flow-through bioassay on the rainbow trout (button-up stage) and a seven-day daphnid life-cycle test were conducted using a series of wastewater dilutions. Mortality of fish in both series of dilution waters and waste was extremely low and there was no evidence of reduced growth, indicating that the test dilutions were not chronically toxic to trout. The daphnids survived and reproduced in ambient water from nine locations on the Clark Fork and no indication of toxicity was found at any of the stations. On the whole, little is known about the sources, fate, and transport of organic substances in the Clark Fork Basin, as most monitoring efforts have focused on inorganic pollutants. Further investigation of these potentially toxic organics is probably warranted. EUTROPHICATION AND NUTRIENTS Excessive Algal Growth Algae and other aquatic plants are natural components of most aquatic environments. Individual species have different habitat requirements, but in geneifal, their abundance is con- trolled by environmental factors such as available light, temperature, and nutrients. Nutrient availability, especi- ally nitrogen and phosphorus, often limits algae growth and abundance. In the presence of nutrient enrichment, such as domestic wastewater effluents, algae growth can be excessive and a nuisance to other beneficial uses. Excessive algae growth can also modify existing water quality by depleting oxygen, modifying pH and alkalinity, imparting taste and odor, and releasing toxic substances. Algae can also remove toxins from the water column. The process of nutrient enrichment and accelerated biological productivity is called eutrophication. In undisturbed watersheds, eutrophication is a natural aging process. Where nutrient enrichment is accelerated by human activity, "cultural eutrophication" results. 3-84 Evidence of excessive algae growth in the upper Clark Fork basin has been reported since 1974 (Casne et al. 1975). Aerial surveys in 1973-74 showed dense growths of algae occurring between Deer Lodge and the mouth of the Blackfoot River. These growths were attributed in part to insufficient streamflows during the spring months to scour the previous year's algae growth. Very heavy growths of algae have occurred again during the summers of 1984 to 1988, also associated with periods of below-normal spring runoff. Several studies have been conducted in recent years to describe and quantify algae growths in the river and to define the factors contributing to them. Bahls (1987) has described the species composition and species diversity for composite algae samples taken in 1986 at 28 stations located between Silver Bow Creek and the Idaho border. Cladophora sp. was the most consistently abundant green algae with peak occurrences in the reaches from Gold Creek to Missoula and from Superior to the confluence of the Flathead River. Excessive algae growths did not occur in Silver Bow Creek and the Clark Fork above Deer Lodge, presumably due to metal toxicity. Diatoms were the dominant algae at the Turah and Harper Bridge stations. These sites were characterized by low species diversity and a very small percentage of pollution-tolerant species. In 1987, EPA (1987b) charac- terized the abundance of algae attached to natural and artificial substrates in the upper and lower river. Chlorophyll and biomass were especially high in the upper river stations. Increased algae growth occurred below the municipal wastewater treatment plants and below the Champion Inter- national discharge. Algal biomass and chlorophyll decreased downstream from Champion's mill to the town of Plains (Ingman 1985) . Nuisance quantities of algae have not been reported in the lower Clark Fork reservoirs. Water level fluctuations and relatively rapid flushing rates in the reservoirs probably prevent the establishment of nuisance-level algae blooms or rooted aquatic macrophytes. Algae and macrophytes are a major concern in Lake Pend Oreille, Idaho. In recent years, residents and recreation- ists have reported an increase in littoral zone (near-shore) algae and macrophytes (rooted aquatic plants) . A 1986 study of periphyton growth in Lake Pend Oreille suggests that eutrophication of the lake is accelerating (Falter and Kann 1987) . 3-85 Analysis of Lake Pend Oreille waters has indicated relatively low nutrient concentrations in the open water areas but significantly greater evidence of eutrophication in developed and confined bays. Relatively little informa- tion is available regarding nutrient sources in Lake Pend Oreille. The Clark Fork, which contributes 90 percent or more of the annual inflow of water to Lake Pend Oreille, is recognized as an important source of nutrients. Less is known about the contribution of nutrients from other tributaries and from near-shore developed zones. Nutrient Concentrations and Loading Of the many nutrients required by algae and other aquatic plants, nitrogen and phosphorus are the two elements usually in the shortest supply in natural waters. This means that the growth of algae is often controlled by the con- centration of nitrogen or phosphorus, or both, in the water column. The EPA (1986c) has established criteria values for total inorganic nitrogen and total phosphorus that should not be exceeded in order to prevent excessive developments of attached algae in rivers and to prevent eutrophication in lakes that are fed by rivers. These values are 1,000 ug/1 for nitrogen and 50 ug/1 for phosphorus. The criteria may not apply equally well in all situations, and they do not account for other limitations to algal growth. WQB data demonstrate that the major sources of nutrients in the Clark Fork Basin are municipal and industrial wastewater discharges. During low-flow years, there is less river water available to dilute the wastewater. This is especially problematic for municipal dischargers, whose discharge rates are relatively constant from year to year. It is less important for some industrial facilities, such as the Stone Container Corporation kraft mill, because their allowable discharges are largely limited by river flow. The following summary of FY 85-87 WQB data on river nutrient concentrations and loads may very well represent a near worst-case scenario because of the low streamflow conditions that prevailed during the monitoring period. The generally higher nutrient loading in 1986 probably reflects a greater contribution from nonpoint sources. Silver Bow Creek Silver Bow Creek from Butte to the Warm Springs treatment ponds suffered from serious nutrient pollution problems on a year-round basis during FY 86-87. Measured concentrations of total phosphorus (Figure 3-27) and total 3-86 5,000 UJ UJ OL in < K O O u 1.000 r o K I- Z UJ o o o 100 r 10 - - 1 1 1 .^ E 1 1 : * i 1 ~ : 1 - • 1 ■ "" « . Phosphorus Criterion (EPA 1986c) - 2 3 STATIONS CLARK FORK BASIN STUDY SAMPLING LOCATIONS 1 SBC b«lov Colorado Tallliugs 2 SBC at nilas Croaalnq naar Ranaay 3 SBC abova Wana Spclnqa (AOI) tnauane ponda 4 ACH Pond 12 diacharqa (Silvar Bow Craak) (See Figure 3-14 for station locations) Source: DHES-WQB FY 85-87 data. FIGURE 3-27. TOTAL PHOSPHORUS CONCENTRATIONS IN SILVER BOW CREEK 3-86a inorganic nitrogen in Silver Bow Creek were an order of magnitude higher than any other stream monitoring station in the Clark Fork Basin. The EPA nitrogen (1,000 ug/1) and phosphorous (50 ug/1) criteria were routinely exceeded by a large margin — up to 32 times for phosphorus and up to four times for nitrogen — at most monitoring locations on the creek. The highest nutrient concentrations in Silver Bow Creek occurred at monitoring station 1, Silver Bow Creek below the Colorado Tailings. The station is located a short distance downstream of the Butte municipal wastewater discharge, which is the principal source of nutrients in the creek. During periods of low streamflow, more than half the Silver Bow Creek flow consists of sewage effluent. From monitoring station 1 downstream to the Warm Springs Ponds, nutrient concentrations (Figure 3-27) and loads declined somewhat, presumably as a result of dilution from cleaner tributaries or ground water inflows, or both, and probably to a lesser extent from biological uptake. However, concentrations remained sufficiently high to categorize the stream as grossly polluted. Silver Bow Creek does not harbor extensive developments of algae despite its excessive nutrient concentrations. Algal bioassays conducted several years ago for DHES (Greene et al. 1986) indicated that the potential for algal growth in Silver Bow Creek was limited by toxic metals, most likely copper. Copper is phytotoxic at relatively low concentrations and is widely used as an algicide, e.g., copper sulfate. Warm Springs Ponds The Warm Springs Ponds were very effective at decreasing Silver Bow Creek phosphorus concentrations (Figure 3-27, monitoring station 3 versus 4) and loads during FY 86-87. Reductions in both nitrogen and phosphorus concentrations and loads were comparable and averaged about 3 . 5-fold less in the pond outlet as compared with Silver Bow Creek above the ponds. Biological assimilation, denitrification, and settling of suspended solids with adsorbed nutrients were presumably the responsible factors. The ponds effectively reduced nitrogen concentrations to levels below the EPA criterion, on the average. Only infrequent, small-scale exceedences of the nitrogen criterion in the pond discharge were documented in FY 86, and no exceedences were measured in FY 87. Although phosphorus concentrations were significantly reduced, they rarely fell below the problem level. Measurements of total phosphorus in the pond discharge exceeded the EPA criterion in 80 to 90 3-87 percent of the samples in FY 86-87, with mean concentrations averaging nearly three times the threshold value. Upper Clark Fork Measured total phosphorus concentrations and estimated annual phosphorus loads for the Clark Fork from its head- waters below Warm Springs Creek (station 7) to below Milltown Dam (station 15) are presented in Figures 3-28 and 3-29, respectively. Estimated annual loads for total inorganic nitrogen are given in Figure 3-30. Nutrient concentrations in Warm Springs Creek and in the Mill-Willow Bypass were significantly lower than those in Silver Bow Creek. Each of these tributaries helped to reduce the nutrient concentrations in the mainstem Clark Fork at its headwaters. Nutrient concentrations in the upper Clark Fork mainstem, in general, decrease below incoming clean tributar- ies and increase below municipal wastewater discharges. In Figure 3-28, notable increases in median total phosphorus concentrations were observed between monitoring stations 9 and 10 and between stations 11 and 12. The primary point sources of phosphorus in those reaches are the Deer Lodge, Philipsburg (via Flint Creek) , and Drummond wastewater discharges. The ground water system is also a possible source of phosphorus. In 30 water samples collected from 1985 to 87 from 28 wells in the area between Deer Lodge and Drummond, most concentrations of dissolved phosphorus were less than 100 ug/1, and the maximum concentration was 300 ug/1 (USGS unpublished data) . The phosphorus load plot (Figure 3-29) confirms that these reaches contain significant phosphorus sources. However, the amount of ground water inflow in this area has not been quantified. Comparing the measured phosphorus concentrations with the EPA criterion indicates that concentrations in the upper Clark Fork frequently exceeded the threshold value, but not by a large margin. The phosphorus criterion was exceeded in 60 to nearly 80 percent of the samples below the Blackfoot River during the FY 85-87 monitoring period. Average concentrations ranged from 1.5 to 0.7 times the criterion. The highest frequency of exceedence of the phosphorus criterion anywhere in the mainstem Clark Fork during the FY 85-86 period consistently occurred at monitoring station 10, below the Deer Lodge sewage outfall. This area corresponds roughly to the uppermost extent of the Cladophora algal blooms. Rock Creek marks the downstream extent of the most serious Cladophora blooms. Cladophora is further reduced below the Blackfoot River confluence. 3-88 I I I I C9 T3 r» 00 I in 00 >< Uu CO O" 3 I CO u X a 01 o u 3 O '-0 1 1 1 ; I I r II I I I I I — r II ; I I I I — r tnh 0) u a M "COS* « « o " • « IE C •I n 3 9 > > X X (A O O ^ .. _ x> x> « « c a o a: c IT a: c Ul u. u. u. u. UUU U U li. " !i §'5. jO •> IE 7 E o £ £ a K K z o s i s o o o ft a> « H Si o tC IC IE u. u. u. w (O 00 o> T- < a. Mi. > >• IS •a « u. w « n (A c i « • ., - • or J * " " 5 u. u. o u u £ S 11 lis UJ > Q. O t- C O - 5 i i = I o C 5 » t, 3 -^ m )- £ o (0 O - - » £ » C (D « ^ a « IE IE (C IX CC IE U. u. U. U. U. IL o o o o o o 1 1 ' I J_J L U-L. I I I 1 1 I _l L . mo ^ t 1 s < U H in CO CM O) s 3-8 8 a (0 c o CO o o c o /- 'H _2 to -'J t. r, O o — u 3 60 < u CO z )-< J s < CO I z o o u CO < W u H H CO OS o < U U H CO =) o a. CO o x a* .J < H o H b O CO a < o < 3 Z Z < (-iO»/C/sUO^) pDO-| CM I CO U 3 3-88b a Or V in I to U- CO t V I k1 r\ '^ ^ \ "^- N ^i o 8 o o o o n o CM 3 O I J05"\/5UC'4 I pOO" 5 ^ n — 0) u ■s 60 0) I I o o w to < CQ «0 u yN M (0 H C O to • H u U n xd :«: f\i u «e o b. eo 0 c US ^^ o -K h. ^-< ••-1 < ."> V 4J J * r\ Q O u y~ (0 u St m U U H bJ O OS H U I— I Z < u K O z < H O H U, O (A O < o >J .J < Z Z < 1w 3-88c Nitrogen concentrations and loads showed less sig- nificant fluctuations below wastewater discharges and incoming tributaries. The EPA criterion for nitrogen was not exceeded at any time in the mainstem upper Clark Fork during the monitoring period. Middle Clark Fork Nutrient concentrations in the middle Clark Fork are variable as a result of dilution from incoming clean water tributaries and the influences of several major sources of nutrients. Figure 3-28 indicates a significant change in Clark Fork total phosphorus concentrations from station 16 to station 18. These monitoring locations bracket the Missoula municipal wastewater treatment plant discharge, which contributes a significant phosphorus load to the river — about 50 tons per year (Figure 3-29) . The wastewater discharge contributes an even more significant nitrogen load to the river, averaging more than 100 tons per year (Figure 3-30) . Exceedences of the EPA nitrogen criterion were not documented during the monitoring period in the middle Clark Fork. The frequency of exceedence of the phosphorus criterion, however, was doubled or tripled from above to below the Missoula wastewater discharge. Frequencies ranged from 8 to 18 percent in the Clark Fork above the discharge to 25 to 50 percent below for the FY 85-87 monitoring period. The Bitterroot River joins the Clark Fork a short distance below the Missoula wastewater discharge. Its inflow is responsible for significant reductions in Clark Fork phosphorus concentrations and in the frequency with which the phosphorus criterion is exceeded. On the other hand, Figure 3-30 indicates that the Bitterroot River (bracketed by stations 18 and 20) contributes a significant nitrogen load to the Clark Fork — about 75 to 85 tons per year. Some field research indicates that the lower Bitterroot River receives a considerable volume of nitrogen-rich ground water inflow from the Missoula area. The presumed source of much of this nitrogen is septic drainfield leachate (Kicklighter 1987) . The second most significant source of nutrients to the middle Clark Fork is Stone Container Corporation's Frenchtown kraft mill. The facility, which has been in operation since 1957, manufactures bleached pulp and unbleached kraft linerboard. The process produces about 16.5 million gallons per day (MGD) of treated wastewater that is stored in ponds and either infiltrated into the shallow ground water or discharged directly to the Clark Fork according to stringent permit limitations. Environmental impact statements were prepared on the facility in 1974 and 1985 (DHES 1974, 1985). 3-89 The effects of the Stone wastewater discharge on nutrient concentrations in the Clark Fork are less striking than the Missoula WWTP discharge, in part due to the additional dilution water provided by the Bitterroot River. Phosphorus and nitrogen concentrations (see Figure 3-28 for phosphorus) were marginally higher from above to below the Stone Container discharge (bracketed by stations 20 and 22) , and the frequency of exceedence of the phosphorous criterion increased only slightly in FY 85-87. The nitrogen criterion was never exceeded in samples from above or below the plant in FY 85-87. Stone Container's current wastewater discharge permit specifies that it shall attempt to reduce nutrient concentrations and loading in its effluent to pre-1983 levels to meet nondegradation standards. If Stone Container is unable to meet those reductions by the end of 1991, a formal review will be conducted and the Montana Board of Health will make a final determination of appropriate loading limits for the facility. Limits will be designed to protect current and anticipated beneficial uses. One way to accomplish this goal is to minimize nutrient additions in the wastewater treatment process, and the FY 85- 87 data indicate that this approach is in fact reducing nutrient concentrations. Mean total phosphorus and total inorganic nitrogen concentrations were reduced by nearly half from FY 85 to FY 87. Reductions in nutrient loading are more difficult to assess because of the low streamflows during the monitoring period and because the mill's allowable wastewater discharge rates depend on streamflow. However, the FY 1987- estimated phosphorus and nitrogen loads from the facility were a third and a quarter, respectively, of the loads discharged in FY 85. The FY 87 phosphorus and nitrogen contributions to the Clark Fork from Stone Container are estimated to be about ten tons per year each. Clearly, the facility has made progress in its efforts to reduce nutrient discharges. From the Stone Container mill to the Flathead River confluence, nitrogen and phosphorous concentrations decline as numerous small-to-medium-sized tributaries provide additional dilution water and as biological uptake occurs. Nitrogen and phosphorus loads remain roughly constant or decline slightly, indicating a lack of significant nutrient sources in this reach of river. The phosphorus criterion was exceeded in 13 to 36 percent of the samples for the FY 85-87 period from below Stone to the Flathead River. Exceedences were less frequent with increasing distance downstream of the two point source discharges in the middle river. 3-90 Lower Clark Fork Routinely low nutrient concentrations in the Flathead River are responsible for an average 40 to 50 percent reduction in nitrogen and phosphorus concentrations in the lower Clark Fork. Concentrations of total phosphorus (Figure 3-28) and total inorganic nitrogen gradually decline toward the Idaho border, and many measurements are at or near the analytical detection limits. Throughout the reach, the total phosphorus criterion is only infrequently exceeded (in 15 percent of the samples in FY 86; never exceeded in FY 85 or FY 87) , and the nitrogen criteria are never approached. Figures 3-29 and 3-30 indicate that the Flathead River (bracketed by stations 25 and 27) contributes significantly to the nutrient load of the lower Clark Fork despite its inherently low nutrient concentrations. The plots also show that Noxon Rapids (bracketed by stations 28 and 29) and Cabinet Gorge (bracketed by stations 29 and 30) reservoirs act as sinks for phosphorus and reduce the Clark Fork load by approximately the amount contributed by the Flathead. The reservoirs apparently do not influence Clark Fork nitrogen loads. Aquatic Macrophyte Problems Dense growths of rooted aquatic plants (macrophytes) can affect lakes and streams in the same manner as excessive algae growths. Aquatic macrophytes are usually found in shallow zones and they derive nutrients from the bottom sediments. The Pend Oreille River in the state of Washington below the outlet of Lake Pend Oreille is plagued by extensive growths of Eurasian water milfoil (myriophyllum spicatum) . Growths have become so extensive that recreation, navigation, water supplies, and water quality are affected (WATER 1987) . The Eurasian milfoil problem is affecting Washington water but it is a potential threat to Lake Pend Oreille and the lower Clark Fork Basin of Montana. The plant is easily transported to new locations by boaters, fishermen, or other recreationists . Additional Monitoring Efforts Recent monitoring programs have improved our knowledge of nutrients and algae in the basin. However, our knowledge of these issues is insufficient for regulatory decisions. Monitoring efforts must be sustained to identify long-term trends, and fundamental questions must be answered about the 3-91 sources and fate of nutrients. Congress amended the Clean Water Act in 1987 to provide for a comprehensive assessment of pollution problems in the Clark Fork-Lake Pend Oreille Basin. An interagency committee consisting of representatives from Montana, Idaho, Washington, and EPA Regions VIII and X has outlined a plan to expand studies of nutrients and eutrophication in the basin. Details of these plans are provided in Chapter 5. NONPOINT SOURCE POLLUTION Introduction Nonpoint source pollution (NPS) of surface and ground water is derived from activities such as agriculture, silviculture, mining, construction, land disposal, hydro- modification, and others. The sources are diffuse, and contamination usually results from overland runoff, percolat- ion, precipitation, or atmospheric deposition rather than from a discharge at a specific, single location (EPA 1987c) . Nonpoint source pollution is a major problem in the Clark Fork Basin, both in the tributaries and along the mainstem. The basin has a multitude of pollution sources because its economic base is rooted in agriculture, timber harvesting, mining, and hydropower production. However, because nonpoint sources of pollution are diffuse and can originate from large land areas, identifying and quantifying their effects are difficult. Effective control of NPS remains one of the most challenging issues facing resource managers in the Clark Fork Basins General information regarding nonpoint source pollution is provided in Table 3-19. Sediments resulting from erosion are typically the most widespread nonpoint pollutant. In many areas, agricultural practices are the most common cause of water quality problems from nonpoint sources (EPA 1985b) . Oftentimes, multiple activities in a watershed con- tribute the same nonpoint pollutant, resulting in cumulative effects on water bodies. Control programs are complicated by the variety of pollution sources and multiple ownership patterns that exist in a given watershed. Best Management Practices (BMPs) are important tools in the prevention and control of nonpoint source pollution. BMPs are methods, measures, procedures, or practices used to control or reduce nonpoint source pollution. BMPs can be structural or nonstructural controls or operations and 3-92 TABLE 3-19. SOURCES AND EFFECTS OF NONPOINT SOURCE POLLUTANTS Pol lutant/ Cause of Impairment Activity/Source Potential Receptors Effects Sediments agricultural practices rivers, reservoirs, forest practices lakes mining construction hydromodi f i cat i on urban runoff • Adversely affect spawning and rearing capacity for trout when deposited on stream bottoms. • Interfere with water treatment and irrigation. • Can carry nutrients, toxins, and pathogens. Nutrients/Ferti I izer agricultural practices forest practices land disposal urban runoff mining construction hydromodi f icat ion rivers, reservoirs, lakes, ground water • Can cause excessive nuisance algae and macrophyte growth. • Excess nitrate in drinking water can be harmful to infants. Toxins (primarily metals) mining Pesticides rivers, reservoirs lakes, ground water agricultural practices rivers, reservoirs, forest practices lakes, ground water • Exert stress on aquatic ecosystems (can cause chronic or acute toxicity). • Can cause acute and chronic toxicity to fish and other aquatic organisms. • Some accumulate in fish tissues; affect food chain. Pathogens agricultural practices land disposal marinas and boats rivers, reservoirs, lakes, ground water • Can be a potential source of disease. Sal ini ty agricultural practices rivers, reservoirs mining lakes, ground water • Excess salts impair water for drinking, irrigation, stock watering, and other uses. Acidi ty mining rivers, reservoirs, lakes, ground water • Can cause saline seeps. Modifies availability of nutrients, metals, and various pollutants. • Can cause toxicity. 3-92a TABLE 3-19 (CONT.). SOURCES AND EFFECTS OF NONPOINT SOURCE POLLUTANTS Pollutant/ Cause of Impairment Activity/Source Potential Receptors Effects Physical habitat alteration agricultural practices rivers, reservoirs, forest practices lakes construction mining land disposal hydromodif ication • Reduces available habitat for fish & Mildl ife. • Reduces biological production. • Can modify hydrologicat cycle. Petroleum products marinas and boats reservoirs, lakes, construction, mining rivers Cause toxicity to aquatic organisms. Temperature agricultural practices rivers, reservoirs, hydromodif ication lakes • Elevated stream tem- peratures can impair aquatic life. its: De^atering •tridutturat practices rivers • Eliminates aquatic habitat. • Causes elevated stream temperatures. .tHl ^.. X-jX, 3-92b maintenance procedures. They can be applied before, during, or after pollution-producing activities. BMPs use the land in the wisest possible way, whether it be for growing crops or grazing cattle, building highways or cutting trees. BMPs are the coordinated, judicious timing of activities and use of vegetation and materials as components of a total land management system. Categories and subcategories of nonpoint source pollution are listed in Table 3-20. A brief discussion of the major categories is followed by a summary of specific nonpoint problems and programs in the Clark Fork Basin. Agriculture Agricultural activities can result in the addition of sediments, nutrients, pesticides, pathogens, salts, and other pollutants to natural waters. Among these activities are irrigation, poor feedlot and pasture management (overgraz- ing) , trampling and erosion of streambanks by livestock, poor row-crop practices, improper pesticide application, altera- tion of streambanks and channels, and improperly designed irrigation return flows. Irrigation withdrawals can cause dewatering, which may result in elevated temperatures that adversely affect aquatic life. Silviculture Silvicultural practices are another important source of nonpoint pollutants to streams. Because logging activities typically occur in headwater areas, the waters that are affected are usually of very high quality. Silviculture activities that can cause nonpoint pollution include road construction, harvesting operations, use of chemicals (fertilizers, insecticides, and herbicides) , removal of trees, and preparation of sites for revegetation. Sediment is the major pollutant by volume. Debris from forest operations can contribute organic matter to surface water bodies, and removal of vegetation that shades water bodies can lead to elevated water temperatures (EPA 1985b) . Clear- cutting can significantly increase water yield, and a substantial increase in runoff may result in channel degrada- tion and increased turbidity and sediment loading. 3-93 TABLE 3-20. CATEGORIES AND SUBCATEGORIES OF NONPOINT SOURCE POLLUTION Agriculture Nonirrigated crop production Irrigated crop production Specialty crop production (e.g., truck farming and orchards) Pasture land (grazing) Feedlots (all types) Aquaculture Animal holding/management areas Rangeland (grazing) Streambank erosion Resource Ex traction/Expl oration/Development Surface mining Subsurface raining Placer mining Dredge mining Petroleum activities Sme 1 1 i ng Mill tailings Streambank erosion Land Disposal (runof f/leachate from permitted areas) Si Iviculture Forest management (harvesting, reforestation, residue management) Road construction/maintenance Construction H i ghway/ road/br i dge Land development Streambank erosion Urban Runoff Storm seuers Combined sewers Surface runoff Streambank erosion Sludge Wastewater Landf i Us Industrial land treatment On-site wastewater systems (septic tanks, etc.) Hazardous waste Hydromodi f i cat i on Channel izat ion Dredging Dam construction/operation ■.«..- Flow regulation/modification Streambank erosion Removal of riparian vegetation Bridge construction Streambank modi fi cat ion/destabi I izat ion Other Atmospheric deposition Waste storage/storage tank leaks Highway maintenance and runoff Spi Us Natural Source: DHES 1988c. 3-94 Construction Construction activities are not a major nonpoint source of pollution but can cause severe localized problems in some instances. Sediment is the major pollutant, and erosion rates from construction sites are generally 10 to 2 0 times higher than those on agricultural lands (EPA 1985b) . Other potential pollutants from construction activities are nutrients from fertilizers, pesticides, petroleum products and other construction chemicals, and solid wastes. Urban Runoff Runoff from urban areas can cause significant water quality impacts to local surface and ground water resources. Sediments and debris are the primary pollutants, but metals, nutrients, and pathogens from animal wastes are also sometimes present. Septic tanks can contribute nutrients and pathogens to ground water (EPA 1985b) . Resource Extraction. Exploration, and Development Nonpoint source pollution from mining activities can cause severe water quality impacts to receiving streams. The most serious NPS pollutants associated with mining are metals, acid-producing materials, sediments, and radioactive materials. Many of the pollutants generated at active mines are considered to be point sources that are regulated under the Montana Pollutant Discharge Elimination System (MPDES) and National Pollutant Discharge Elimination System (NPDES) permit programs. Runoff of sediment from haul roads and drainage and leachates from waste piles can be NPS problems at active mine sites. However, the mining industry in Montana is subject to water quality regulations, and nonpoint problems are dealt with through monitoring and compliance. At inactive mine sites and mine waste disposal areas, drainage and leachates containing acid, metals, sediment, and salts can seriously affect surface and ground water systems (EPA 1985b) . Land Disposal Land disposal systems such as landfills, septic tanks, storage tanks, wastewater treatment areas, and hazardous waste sites can result in the release of toxins, pathogens, and nutrients to local surface and ground water systems. 3-95 Hydromodif ication Sedimentation is the biggest NPS problem associated with hydromodif ication projects due to dredging, dam and bridge construction, flow regulation, and erosion from streambanks that are disturbed. NPS Problems in the Clark Fork Basin The most pervasive nonpoint source problem in the basin is contamination of surface and ground water by metals derived from runoff and leachate from floodplain mine wastes and waste disposal areas. Another major problem is sedimen- tation. A number of activities contribute to this problem, including intensive grazing and agriculture, silviculture, mineral exploration and development, construction activities and hydromodif ication. The severity of NPS problems varies somewhat in different parts of the basin due to diverse geology, soil types, moisture regimes, and land management practices. Upper Clark Fork Basin Specific nonpoint source pollution problems in the upper Clark Fork Basin are provided in Table 3-21. Prevailing problems in the upper basin are sediments, flow and habitat alterations, salts, pathogens and nutrients from agricultural activities; sediments, metals, acid, and habitat alteration from active and historic mines; and sediments, organic compounds, and habitat alteration from silviculture prac- tices. The most serious NPS problem in the headwaters and upper river reach is probably erosion of heavy metals-contaminated sediments into the system. Large waste disposal areas (such as the Colorado Tailings) and floodplain mine wastes are major sources of metals during snowmelt runoff and thunder- storms. The principal problem metals in the upper basin are arsenic, copper, cadmium, lead, and zinc. Middle and Lower Clark Fork Basin Specific nonpoint source pollution problems in the lower and middle portions of the basin are provided in Table 3-22. This section of the basin has some of the same NPS problems as the upper basin, except that there are fewer inactive mine waste sources. Other problems include elevated stream temperatures due to dewatering; nutrients and other 3-96 o ■»*, — V *- u — 1. U 3 •> O a ■» ..X < •o » o " o m — « ^ C lb — o V M » < I. o o o. < o i-6 OH OS td Cm ex. U H CO X u .J oa o H .J O U — ' e o o c — J3 3 U 0 O •^ w u c — u — m m %- ■ c M w ja o _^ t. ^ lU •» b. B £ ■ 3 u 3 c u M « ■D > M V o 3 X c « u J3 u o 3 — o « 3 *^ 0 « CA £ e ■^ M v> ^ s C c w s V O 0 u •> 0 k ^ — 3 u .» 3 *-• *^ M 3 M t> u u ^ » V .^ U ■ 3 3 .^ U • 3 t. u i. U 3 u k u 3 ** «-> •*- U 3 Arf L. 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V) • (A o c e 0 V a V O) b u V ** t. *^ M 3 « c O u X 0 (A 3 lA 3 • 3 X C 0 C o b u •V m o ae If b 3 V t- ** 3 ** 9 3 *•» 3 ** u O -- w u w w CI u w c O) 3 ^ 3 *^ ^ u (D 3 3 tl U 3 u 3 3 u b 3 U 0 *^ •^ W 4-* U U 3 4^ U to ■ > •^ « •*• w. 0 X > u lA C 0 < c 0 u c o u D < < M V se e 0 Ul b < (A C O *4 u « m • m 0 ♦* t. V b ** •*• c A' *>> ^ c o «l ■w ..rf «rf ^ • B < < M « < < ^ b u 4-» « w W « 4-1 M ■ ^ m ^ 3 M •^ ** c •^ *^ C C .»» c C ** ■c c ^ -^ 3 « ■ «* U « 4> 1) L. V f u m V u tt « 0 *J ■ tl AJ m •^ «> m •^ «> M ■ tl G 4.* & JO •D o J3 T3 ^ U X u U ^ A •o u T» 03 « l» « C V 3 n V 3 « c « t> • V z tA ca X (A Z CO «n X ffi lA X «A la 4A X ■ m w t. V « « t. jtf ^-t *« m « lA -1 3 «- <^ c o O 3 O m ^■ 1^ »rv — M •■ to lA w M t. V *t o ^ %- •f u t. ac < 0 0 u u • > m II u » «i u «l « 3 O u b II ^ b > ae ^ jC u •^ u c b _# U c U a a a u .^ 0 o t> -^ V «> o > X kb m *' 0 c K c f ** a « *D •^ •^ — > a ^ ^ ■ 3 C n «A 4A a. 4A 3 lA 0 b M It 0 •o v c 0) 4J « (U Vj J= 4J II T3 H (U •» 2 > • (U 0) u CO II eo II u 00 CO ON •V ^ » •V 0) :: DC < u ct: u a, (X, H CO Q :d H CO u i-i < 3 3 O CO o CO 3 m w OS D U 3-1 10a reservoir sediment ground water. The lowest concentrations were found in the northern portion of the study area, reflecting high-quality recharge water from the Blackfoot River (Woessner et al. 1984). The authors concluded that the distribution of metals in the ground water and ground water flow patterns proved that reservoir sediments were a likely source of contaminants to the alluvial ground water system. The sediments contain very high concentrations of heavy metals that are extremely enriched above natural levels and rival many severely contaminated sediment systems. Because the reservoir contains approximately 120 million cubic feet of sediment, it represents a huge source of metals to the surface and ground water systems (Woessner et al. 1984) . In January 1987, the Montana Power Company installed three monitoring wells within ten feet of each other on the containment side of Milltown Dam. The wells were completed in three different lithologic units at depths of 45, 30, and 15 feet (Hydrometrics 1987) . The wells were sampled in February and March of 1987. Results of these water analyses are summarized in Table 3-28. TABLE 3-28. RESULTS OF MFC SAMPLING OF MONITORING WELLS AT MILLTOWN DAM (FEB. - MARCH 1987)^ Well Total Recoverable 15A (45-) 15B (30M 15Cfl5n Metals (ppb) (ppb) (ppb) Arsenic <5 to 22 '■<5 to 58 42 to 102 Cadmium <1 to 4 <1 to 1 <1 to 7 Copper <10 to 210 <10 to 70 <10 to 180 Lead <10 to 150 <10 to 40 <10 to 80 Zinc 10 to 600 <10 to 200 <10 to 1570 ^ Range of values from three samplings. Source: Montana Power Company 1987b. Some of these values are quite high relative to drinking water standards and aquatic life toxicity criteria and provide further evidence of the effect of contaminated sediments on the ground water system in this area. 3-111 Missoula Area Aquifers in the Missoula area were discussed briefly in Chapter 1. The most productive of these, the Missoula Aquifer, is the major source of qround water in the Missoula Valley and the sole source of drinking water for area residents. Recent chemical data for the Missoula Valley Aquifer are available from the Mountain Water Company and the Missoula Aquifer Study, which is being conducted in cooperation with the Missoula City-County Health Department (MCCHD) and the University of Montana. Data from 1984 to 1986 indicated no violations of State of Montana primary drinking water standards, with many of the trace metals below detection limits. The Missoula Valley Aquifer Study did show some coliform bacteria contamination, although Mountain Water Company monthly samples showed no such contamination. Small community water supplies are sampled once every five years for chemical parameters, and data from 3 3 such supplies indicate no exceedence of Montana primary or secondary standards (Missoula City-County Health Department 1987) . Maintaining the high quality of the Missoula Aquifer is of the utmost importance, as it supplies individual wells, two municipal water systems, over 30 small community systems, and several large industrial users (including Stone Container Corporation) . The MCCHD submitted a petition to EPA in December 1987 for a sole source aquifer designation for the Missoula Aquifer to ensure a reliable high quality source of water for current and future users. The EPA granted the petition in June 1988. Much of the Missoula Aquifer is overlain by thin, coarse soils, and depth to ground water is generally shallow. Natural attenuation of contaminants by adsorption, neutral- ization, ion exchange, biodegradation, and other processes is limited; therefore, the aquifer is quite susceptible to contamination. Potential sources of direct contamination identified by the MCCHD are listed below. Yellowstone Pipeline (high-pressure gasoline pipeline) Milltown Reservoir sediments Pesticides from the Missoula County Weed Control Program Browning-Ferris municipal waste landfill and historic landfills Burlington Northern Railroad diesel refueling site Sewage disposal seepage pits Underground fuel and chemical storage tanks Urban storm water Septic systems Industrial waste ponds 3-112 Burlington Northern Railroad and Interstate 90 trans- portation corridors (transportation of hazardous materials and wastes) Because the Clark Fork provides 46 percent of the total recharge to the Missoula Aquifer, surface water quality of the Clark Fork is obviously very important. Upstream activities in the streamflow source area are of major concern, although there is a decreasing gradient of potential impact to the aquifer from surface water contamination in the upstream direction (MCCHD 1987) . The petitioners have defined the project review area as the designated area and the portion of the streamflow source area within a 15-mile radius of Missoula. This represents the area where major development projects would likely have the greatest effect on the quality of the Missoula Aquifer. Lower Clark Fork Basin Little information has been published on ground water quantity or quality in the Clark Fork drainage basin between Huson and the Montana-Idaho border. The lack of knowledge regarding the ground water resources in the lower drainage basin suggests that it might be prudent to conduct at least a reconnaissance ground water study of the area, particularly in light of the potential mining development in this portion of the basin. Recommendations for ground water studies are outlined in Chapter 5. FISHERIES, RECREATION, AND AESTHETICS Effects of Surface Water Quality Degradation In the mainstem Clark Fork, trout populations appear to be affected by a variety of water quality factors, including dewatering, elevated temperatures, excessive nutrients, and siltation. However, the major factor suppressing trout populations appears to be metals. Recruitment of brown trout to the mainstem Clark Fork above Milltown Dam is limited primarily to tributaries and perhaps the river itself in the Warm Springs area. Among the tributaries currently known to support major spawning runs from the river are Warm Springs, Gold, and Rock creeks, and the Little Blackfoot River. The contribution from Flint Creek is currently unknown but will be assessed in the future . 3-113 All tributary flows are probably significant in improving water quality but increases in trout abundance appear to be significant only below the mouth of Rock Creek. Fish kills have been observed frequently in the upper Clark Fork over the last several years. State agencies have documented kills that occurred on August 9, 1983; August 1, 1984; June 18, 1987; July 3, 1987; and May 27, 1988. All five kills were associated with thunderstorms and are believed to be a result of metals entering the river due to rainfall on streamside mine tailings. Although documentation has been more thorough for some kills than for others, it has included photographs of red water immediately after storms, water samples indicating that a slug of metals entered the stream during the storm, high concentrations of metals (particularly copper) in the gills of fish that were killed, extremely high concentrations of metals in pools of water adjacent to the stream, and other subjective evidence pointing to the conclusion that the fish were killed by metals (Department of Fish, Wildlife and Parks files) . In response to concerns that tailings present in the Mill-Willow Bypass have been the origin of several fish kills, the Anaconda Minerals Company is currently modifying the bypass to divert water from the upper portions of the bypass into the Warm Springs Ponds during summer. This change is expected to isolate some of the more immediate sources of metals from the upper river but will not entirely eliminate the possibility of tailings entering the river during thunderstorms. High concentrations of metals are also present in the river during spring runoff. No documentation shows that metals present in the river during spring runoff kill adult trout. However, metals present during runoff events are believed to chronically stress populations and may cause acute toxicity, especially to sensitive, early life stages. Such occurrences could easily go unnoticed. Many biologists also believe that the absence of rainbow trout from much of the upper river is due to their lower tolerance to metals than brown trout. Several investigators have evaluated the toxicity of river water in the Clark Fork drainage (Table 3-29) . Bionomics (1979) tested the toxicity of water discharged from Warm Springs Pond 2 to early life stages of rainbow trout (eggs and fry) and to Daphnia middendorf f iana. which is a native daphnid, or water flea. water, but all fry, including those exposed to dilutions of 50 and 7 5 percent pond water, experienced reduced growth. Copper and zinc concentrations in a 50 percent dilution of pond 2 water averaged 25 and 65 ug/1, respectively. Additionally, Daphnia 3-114 u §1 ll as o oo CO r^ h* a> o> f-H <— I ^-^ o 3 •^ 'g o o •H •H CO OQ 1 8 H- O U-i •H <«-( CO o fx Be I o N 3 !>• ■M *— ^ ■H 1^ rH K s IB • CO □ •JJ U1 §• ^1 dO V •^ ^ 1 cd s ■«)• 0 o 3 i £ ? (N s Oi S 8 K g3 « R s « £ i. M I Q f 8. S3 U 1 I I ^ ^ "I § § t ■«-' s & *j r~ 3 b IT. « (3 -I S I 2 £ (N £ » S oo £ in >< CO IS 3-1 14a ft a i 1 1 C 3 'Sf m a) a: o n r to O 0) tJ -§ (0 ^ n X H! £ g* w to ^ .2 IV cS ^ o> r^ f-H 13 ^-- j^ § N 1 ^1 ^ T3 5 5 1 m >^ M C u rfi» O s 8 R ^ I •9 1 o< c o 0) -H (N 1 s 5 ^ «j o> o U (71 ■!-> C » '^ O Li Dl. S 0) 1/1 t>i g CO JC n -^ o o O4 c 0) f-H £ ^ 2 3-1 14b middendorff iana reproduction was significantly impaired by exposure to 100 percent pond water but not by exposure to 50 percent pond water (Bionomics 1979) . Copper and zinc concentrations in 100 percent pond water were 3 3 and 77 ug/1, respectively. Identical tests with Daphnia magna produced a similar result (Bionomics 1978) ; numbers of young per female were reduced by exposure to 27 ug Cu/1 and 31 ug Zn/1 (measured as total recoverable) . Janik and Melancon (1982) , during a site-specific water quality assessment of Silver Bow Creek and the upper Clark Fork, completed a few bioassay tests with Daphnia and bluegill. In these tests, Daphnia were not adversely affected by Clark Fork water nor was ventilation rate in bluegill. However, bluegill in Clark Fork water showed evidence of acetylcholinesterase inhibition. Total and dissolved copper and zinc concentrations during the survey averaged 30 and 22 ug/1 of copper and 101 and 91 ug/1 of zinc. The report did not include specific information on metals concentrations that were present in the bioassay water. Parrish and Rodriguez (1986) tested the chronic toxicity of Clark Fork water in the Deer Lodge vicinity to early life stages of rainbow trout, including separate tests using green eggs, eyed eggs, and fingerlings. Tests were conducted in May and early June 1985 to coincide with runoff; however, unusually dry spring conditions resulted in lower-than-normal streamflows and concomitantly low metals concentrations. Percentage mortality of both eyed eggs and fingerlings was higher in 100 percent Clark Fork water than in various dilutions, but results were not conclusive. During the test, acid-soluble copper concentrations ranged from 10 to 78 ug/1. For the water hardnesses that were present, EPA chronic and acute criteria for copper were calculated to be approximately 20 and 31 ug/1, respectively. Most of the mortality occurred during the last week of the tests, when copper concentrations exceeded the acute criteria (weekly average concentration reached 78 ug Cu/1) . Phillips et al. (1987) conducted in situ tests with finger ling rainbow trout in the Clark Fork drainage from mid- April until late July 1986. Fish were held in the river at seven locations between Anaconda and Clinton, including a control site in Racetrack Creek. Over the course of the test, nearly 90 percent mortality occurred in Silver Bow Creek, where acid-soluble copper averaged about 200 ug/1 and acid-soluble zinc 400 ug/1. Cumulative mortality at mainstem sites included 25 percent at Warm Springs, 15 percent at Deer Lodge, 7 percent at Gold Creek, and 21 percent at Bearmouth (Table 3-30) . Only 3 percent mortality occurred below the confluence with Rock Creek (Clinton) . No mortality 3-115 i-H i3 PJ CM rH iH rH I I I I I I I 00 Jt O vO ^ O O (M vO « Oi C rH r~ •*i •* 00 r~- in in PI « 00 t»j i~~ -* in o evi CM rt c-0 o CM oo CM CM 3 rH O O « r-t rH O O ft o iH Cvi CM r-l r^ 00 o /— s ^^ ^^ ^^ ^^ ^^ r-i ^_^ ^^ /— * o m o m CO m ^— ^ J- o y^ ^~^ /— > ^-^ in r^ O^ en lO CM O J- o> CO 00 r^ ^ o ■H r^ vO rH rH CM •-< C-1 c^ -* vO in L-> CO CO -* in Jr (^ ■4- <^ 1 CM 1 1 1 1 J- 1 CM ^»-' in in in oo O -^ in in m CM CM CM 00 CJ< 00 in rH rH r^ O^ CO c<^ CO f^^ O ^— * ^"^ ''^ '"^ ■'"^ O CM o o o o o fH in in in CO J- CM I I I I I I I in o O O m m in <> 00 in ■* m 00 rH CM C^l rH rH ^^ 60 «i f-t d 01 Jll o u •H u 6C S 5 4J a, o ^ 3 c c t/i hJ u 5 o 0 4J t) g iH rH (5 e 4-1 4J 4J o eU n IB j ^ (S U u U U IH u o a O O o i X >: 9) > 13 u (B is 13 13 0) 4-> IB 4J HI 5 O 0) ^ & •rl 0) (A Oi ? V4 (1) 0) 3 0) U vt 0) o uh il 01 in 60 a> •o 4J O -n iJ VI 0) <1) c •H 0) C« rH o u c/i o o u o u 0) u kl 3 o 3-n5a occurred at the control site in Racetrack Creek. Mortality in Silver Bow Creek and in the Clark Fork at Warm Springs, Deer Lodge, and Bearmouth was statistically higher than at the control site. Copper and zinc concentrations present during the test are summarized in Table 3-30. Additional bioassays were conducted during May and June of 1987 (Phillips and Hill, unpublished data) , including tests of both rainbow and trout fingerling and swim-up-stage fry. Test sites were the same as those used during 1986. Tests began on May 4 and were completed by July 1. The test vessels were eguipped with an automatic feeding system that provided hatchery food to the fry four times per day. Fry were less tolerant than fingerling during these tests. Rates of mortality for fry were: Warm Springs (18 percent) , Gold Creek (36 percent) , Bearmouth (55 percent) , and Silver Bow Creek (92 percent) . Mortality at the latter three sites was significantly higher than the 8 percent observed at the control site and the 10 percent observed at Clinton (down- stream of Rock Creek) . A pair-wise multiple comparison technique was employed using Bonferroni adjusted confidence intervals. Rates of mortality for fingerling were: Warm Springs (7 percent) , Bearmouth (12 percent) , Gold Creek (24 percent) , and Silver Bow Creek (88 percent) . Mortality at the control site was only 2 percent. Mortality at both Gold Creek and Silver Bow Creek was statistically higher than the control . The Warm Springs bioassay location is on the east side of the river and is in the plume of Pond 2 discharge water. During both the 1986 and 1987 bioassays, maximum and average zinc concentrations were higher at this site than at downstream sites. High metals concentrations below the ponds occurred during periods of high winds .-that stirred up particulate materials in the Warm Springs Ponds. Unlike resident fish in this vicinity of the river, the bioassay fish were unable to seek refuge from the higher metals concentrations by moving into water originating from either Warm Springs Creek or the Mill-Willow Bypass. Such movements may allow resident fish to escape high concentrations of metals. In summary, the instream bioassays indicate that early life stages of rainbow trout are adversely affected in Silver Bow Creek and in the mainstem Clark Fork. Statistically significant mortality has been documented from Warm Springs to near Bearmouth. This occurred even during years when metals concentrations were relatively low because of modest runoff. Tributaries that contribute good-quality water to the river may provide potential refuges from high metals concentrations, but the extent to which these are utilized by resident fish has not been documented. Use of refuges may 3-116 partially explain why trout densities are sustained im- mediately downstream of the Warm Springs Ponds. It is difficult in a natural environment such as the Clark Fork to gauge the conditions that fish and other aquatic organisms are exposed to because metals concentra- tions may fluctuate greatly over short intervals of time. For example, even frequent sampling such as that conducted by Phillips and Hill (three times per week) may not describe conditions that are present during short, intense thunder- storms. In any case, various authors have documented that Silver Bow Creek and Clark Fork waters are sometimes toxic to some invertebrates and early life stages of fish. Toxic responses have been observed when metals concentrations were as low as 20-50 ug Cu/1 and 30-80 ug Zn/1 and when water hardnesses ranged from approximately 100-200 mg/1 (as CaC03) . At water hardnesses of 100 and 200 mg/1, federal criteria documents recommend that metals concentrations should not exceed 12 and 21 ug Cu/1 and 37 and 66 ug Zn/1 to prevent occurrence of chronic toxicity. Toxicity information for the Clark Fork indicates that these criteria are not overly protective and at times may provide only a very narrow margin of safety. Some preliminary metal speciation work has been done by researchers at the University of Montana. They hypothesized that because trout populations in the upper Clark Fork decline downstream from the sources of metals near Butte and Anaconda, water chemistry changes might result in a greater prevalence of toxic metal species downstream. To test this hypothesis, the researchers applied several approaches to modelling metal speciation to water chemistry data from the upper Clark Fork (Caciari and Watson, in review) . These approaches ranged from a simple model developed by the EPA's Western Fish Toxicology Station (WFTS) at Corvallis, Oregon, which predicts the percentage of free copper from alkalinity and pH, to a complex multiequation equilibrium model (MINTEQ) . The different modeling approaches predicted a similar amount of free copper, but the MINTEQ model predicted much higher levels of copper hydroxide and lower amounts of copper carbonate than the other approaches. None of the approaches showed any substantial downstream trend in metal speciation, largely because there was no substantial downstream trend in pH or alkalinity. Seasonal trends cannot be discerned based on one year of data. Because the simple WFTS model is in good agreement with more complex models, it should be applied to the Clark Fork's past and future data sets to determine if seasonal or longer-term trends emerge. 3-117 Reduced water quality has a significant effect on recreation and aesthetics. Excessive algae growth, suspended solids, and color are water quality conditions that directly affect aesthetic quality. Residents of the Clark Fork Basin have complained that foam, scum, algae growth, and sediments have increased in the middle and lower segments of the river. Idaho residents have complained of algae and bacterial scums, especially in near-shore areas surrounding docks and beaches. These physical and visual impacts of reduced water quality are important but they are seldom quantified or measured directly. Often these problems are the indirect result of other, more basic water quality conditions. Effects from Existing Hydropower Development Historically, the Clark Fork was a major spawning ground for fish migrating out of Lake Pend Oreille, Idaho. Some historical records suggest that fish may have travelled as far upstream as Missoula, a distance of 211 miles from Lake Pend Oreille (Malouf 1974) . The three dams on the lower Clark Fork modified the habitat and blocked access to spawning grounds for fish migrating out of the lake. The Thompson Falls Dam, constructed in 1916, blocked migrations for all but the lower 70 miles of river, and the Cabinet Gorge Dam, constructed in 1953, eliminated the remaining fishery for migratory westslope cutthroat trout, kokanee salmon, and bull trout (a fish ladder was constructed at the Thompson Falls Dam, but information regarding its usefulness is lacking) . Each of the lower river reservoirs is a run-of-the-river impoundment, constructed for the primary purpose of hydro- electric power production. The operations of the power plants, including drawdowns and the physical characteristics of the reservoirs, combine to create adverse conditions for fish production. The relatively rapid water exchange, or flushing rate, in each reservoir limits the plankton production needed to sustain greater fish populations. Fish food availability (aquatic insects and other benthic organisms) are also severely affected by water level fluctuations and reservoir drawdowns. Spawning beds within the reservoir and access to tributary spawning areas may be severely diminished depending on the timing of reservoir drawdowns and the onset of spawning. Testing has also shown that large numbers of fish species predisposed to migrate (i.e. rainbow) are flushed downstream during spring runoff. During the period of 1953 to 1963, large numbers of trout and kokanee salmon were stocked in Cabinet Gorge Reservoir, but a self-sustaining fishery was not established. Since 1963, fish stocking in Cabinet Gorge has been suspended 3-118 except for some limited plants of catchable-size rainbow trout and plants of brovm trout eggs in Elk Creek, a tributary to the reservoir. The egg plants are a new attempt to establish a self-sustaining brown trout population. More attention has been focused on Noxon Rapids Reservoir in recent years, because a successful fishery in Noxon will have a positive influence on the Cabinet Gorge Reservoir fishery. Like Cabinet Gorge, early attempts to establish a fishery at Noxon Reservoir were successful, but relied on annual stocking. Populations of brown trout, bull trout, lake whitefish, and perch are found in each reservoir, but their numbers or quality have been insufficient to maintain an acceptable fishery. In 1986, a new operation plan for Noxon Rapids Reservoir was put in effect by the Washington Water Power Company. Prepared through joint efforts of WWP, the Montana Department of Fish, Wildlife and Parks, and the Northwest Power Planning Council, the plan reduces the extent and frequency of reservoir drawdowns, especially at critical times of the year. The four major points of the agreement are as follows: 1. Maximum drawdown is limited to ten feet, except in the second and succeeding years of a critical water period, as defined by the Pacific Northwest Coordination Agreement, drafting may reach 36 feet, but only on a pro-rata basis with all other reservoirs in the coordinated system. 2. By May 15 each year the reservoir will be operated within four feet of full pool until September 30 to protect most in-reservoir fish spawning activities, reduce effects of drawdown on aquatic plant and animal communities, and assure recreational access during major use months. 3. The rate of drafting will be limited to two feet per day and ten feet per week to reduce bank erosion. 4. WWP reserves the right to deviate from the opera- tional criteria in the event of an emergency, such as project maintenance, system power failures, or an extended period of weather extremes. In addition to this agreement, WWP is continuing to support the state's effort to establish fish populations in the Cabinet Gorge and Noxon Rapids reservoirs. A full-time WWP biologist is currently studying the effects of the new operating criteria at DFWP's direction. Also, a three-year 3-119 pilot fisheries development program funded by WWP and DFWP was recently extended by two years. Test netting in Cabinet Gorge Reservoir indicates lake whitefish, largemouth bass, yellow perch, and brown trout populations are possibly increasing. Evidence of brown trout spawning in reservoir tributaries has also increased during the past seven years. Sampling of fish populations in Noxon Rapids Reservoir show fairly stable results from 1960 through 1982, followed by a marked increase in 1987. The increase was largely suckers and yellow perch, but brown trout populations show some signs of increase. Improved habitat resulting from the new reservoir operations policy is expected to result in increased fish numbers and improved growth rates. Large drawdowns of the lower river reservoirs seriously affect aesthetic quality and recreational opportunity. As reservoirs are drawn down, large areas of mudflats are exposed to wind and water erosion. Not only do these areas have low aesthetic qualities, but access to the water for fishing, boating, and swimming is restricted. A new threat of hydropower impacts on fish and wildlife resources began in 1978 with the passage of the federal Public Utilities Regulatory Policies Act (PURPA) . This act stimulated a flurry of proposals for small-scale hydropower projects on tributary streams throughout western Montana. Resource managers were concerned that hydropower facilities constructed in some stream reaches would seriously affect important fish habitat and spawning areas, block fish movements, alter water quality, and modify wildlife habitat (Zackheim 1984). -: An important action was taken in August 1988 when the Northwest Power Planning Council adopted a proposal to designate certain stream reaches in western Montana to be protected from future hydroelectric power development. Stream areas with critical fish and wildlife habitat or value are designated as protected areas. The NWPPCs action became effective on September 14, 1988 through the amendment of the Columbia River Basin Fish and Wildlife Program (NWPPC 1987) to include the protected area designations. Many stream reaches within the Clark Fork Basin have been designated as "protected areas". Additional information on the specific protected areas is available from the NWPPC offices in Helena, Montana, or Portland, Oregon. 3-120 The designation of protected areas is a major step by the NWPPC to rebuild fish and wildlife populations that have been damaged by hydroelectric power development. Although the NWPPC does not license hydropower facilities, the Federal Energy Regulatory Commission, which grants licenses to non- federal hydropower projects, must take the NWPPC 's designa- tions into account in their decision-making. Effects from Irrigation Projects This section discusses the effects of irrigation on the fisheries, recreation, and aesthetics of the Clark Fork. The discussion addresses large irrigation storage projects as well as smaller, individual projects and uses of water for irrigation purposes. Large Storage Projects Nevada Creek Reservoir. The Nevada Creek Reservoir is located on Nevada Creek ten miles southeast of Helmville in the upper Blackfoot River drainage. The project supplies water to irrigate approximately 13,000 acres of hay land. The full storage capacity is used for irrigation. Nevada Lake provides mediocre fishing for rainbow trout that are stocked annually. Because of the extreme annual irrigation drawdown, little if any natural reproduction occurs. Limited amounts of both summer and winter fishing currently occur. Any improvement in fishing quality under the current operation and use of the stored water is unlikely. The lake waters are usually turbid, and the extreme drawdowns by late summer are aesthetically unpleas- ing. The reservoir does have the potential to produce a decent fishery if water level fluctuations could be mini- mized. Nevada Creek flows through private ranchland along its entire length below the dam and is used to convey water from the reservoir. A large state ditch, the Douglas Canal, distributes a major share of the water. The North Canal and other private ditches take out additional water. Nevada Creek has good physical habitat in some areas, but the trout fishery is limited by low flows during the winter months when the dam gates are shut down. Also, siltation in the stream bottom limits spawning potential. A limited brown and rainbow trout fishery occurs, mostly of c local nature. The DFWP is currently studying the stream in cooperation with the Nevada Creek water users to determine 3-121 minimum flows required below the dam. Low flows reduce the otherwise reasonably good aesthetic qualities of the stream. Flint Creek Project (East Fork Reservoir) . The Flint Creek Project is located on the East Fork of Rock Creek 20 miles southwest of Philipsburg in Granite County. East Fork Reservoir is a somewhat isolated lake, receiving only moderate recreational use. The fishery consists primarily of rainbow trout stocked annually. However, there is a small bull trout population that reproduces naturally in the East Fork above the reservoir. These fish do occur in the fisherman's catch. Fluctuation in water level limits fishery production, and the aesthetics are not good during late season drawdowns. It is, however, a rather scenic lake at full pool. The project diverts water from the Rock Creek drainage. Without the project, this water would be available for the main Rock Creek "Blue Ribbon" trout fishery. The impacts of this loss of flow on Rock Creek have not been quantified. Flint Creek receives some benefit from irrigation return flows. Leaky delivery canals in the Flint Creek Valley also contribute East Fork water to Flint Creek. However, the return flows are reused along Flint Creek. Flint Creek suffers from dewatering, siltation from streambank erosion, and higher-than-desirable water temperatures in the lower reaches . The fishery in Flint Creek is composed primarily of rainbow and brook trout in the upper reach and mostly brown trout below Maxville. It is a popular fishery but has limitations due to the environmental Qonsequences of land uses and irrigation. The stream flows through a scenic agricultural valley. Low flows due to irrigation withdrawals reduce the aesthetic qualities in some reaches. The DFWP has applied for an instream flow reservation in Flint Creek from the dam on Georgetown Lake to the mouth. However, this alone will only preseirve the status quo of the current low-flow conditions. Painted Rocks Lake. Painted Rocks Lake is located on the west fork of the Bitterroot River about 30 miles south of Darby in Ravalli County. Stored water purchased by the DFWP is used to improve low streamflows in the Bitterroot River. Extensive irrigation in this major river valley depletes natural flows and in most years causes the stream to go nearly dry at Bell Crossing near Stevensville. 3-122 since its original purchase in 1958, the DFWP has released water from the reservoir for instream purposes. However, it was unusual for those releases to reach dewatered downstream areas because the water was diverted by the irrigators along the way. In 1985, 1986, and 1987, the DFWP reached an agreement with the irrigators that would allow a major portion of the released water to reach Bell Crossing. A water commissioner was appointed by the court to monitor and enforce diversions of water. This was a satisfactory program during those low- water years, but the agreement was not fully implemented due to summer rains that increased streamflows (see the agreement between the irrigators and the DFWP on the following page) . Painted Rocks Lake contains primarily westslope cutthroat trout and is a limited fishery maintained by stocking. Rainbow and brook trout occur in fewer numbers. There is, however, considerable other recreational use of the lake, such as boating, camping, waterskiing, and swimming. These activities become limited as the pool level drops. In low-water years, there is sometimes no pool at all in late fall and winter. When it appears the lake will not contain adequate water during a low-water year, it is DFWP policy to not stock fish during that year. The reservoir lies in a very pleasing scenic mountain area and is an extremely aesthetic spot when the water level is adequate. The Bitterroot River flows 80 miles from the junction of the east and west forks to its confluence with the Clark Fork at Missoula. It is a very popular fishery for rainbow and brown trout as well as mountain whitefish during the winter. Other species include westslope cutthroat, brook trout, and bull trout. It is a floatable stream when flows are adequate, and local guides provide some services to fisher- men. The stream flows through the beautiful Bitterroot Valley and is a major aesthetic attraction along with the high mountains and riparian lowlands. Dewatering is the principal problem that must be con- tinuously monitored. DFWP has filed a claim for instream flows at the request of the Ravalli County Fish and Wildlife Association under Section 85-2-223 of Senate Bill 76. The claim is currently pending in the Water Court. 3-123 Draft Water Exchange Proposal on the Bitterroot River May, 1988 The Department of Fish, Wildlife and Parks wishes to extend to those who irrigate from the Bitterroot River a water exchange proposal similar to the agreement of 1987. The exchange consists of: 1. A quantity of water up to 3,000 acre-feet would be made available by DFWP, early in the irrigation season, for irrigation use at any flow rate from Painted Rocks Reservoir. 2. DFWP could request participating irrigators to reduce irrigation diversion to maintain instreara flows of A02 cfs (16,080 inches) at Bell Crossing after September 15. 3. DFWP would keep flow records at Bell Crossing and monitor reservoir releases. 4. DFWP would pay costs associated with the river commissioner to protect water purchased for instream flow. In years when irrigators also buy water costs for the commissioner would be shared. In return, irrigators would agree to the following: 1. Pay DNRC to have the dam gates opened and closed when water is released for irrigation. 2. Sign the petition for the appointment of a river commissioner in years when the DFWP needs one to deliver stored water to Bell Crossing. 3. A water commissioner would deliver sufficient water to provide a flow of not less than 100 cfs (ApOO inches) at Bell Crossing. 4. Fall shutdown of irrigation ditches will be done in a manner to stimulate fish movement out of canals back to the river. One person would be appointed to represent the department and one person to represent the irrigators in matters concerning the management of Painted Rocks water. At a minimum, holders of 15 percent of the water right must be party to this agreement. 3- 1 2 3a Georgetown Lake. Georgetown Lake is located on the North Fork of Flint Creek in Granite and Deer Lodge counties about 18 miles west of Anaconda. Under an old decreed water right, a minimum of 30 cfs is released from the dam for irrigation in the Flint Creek Valley. The irrigators in the valley have been trying to obtain additional water from the project but have been unsuccessful. MPC has filed a FERC application to abandon use of the project for hydropower purposes. Granite County has agreed to receive the project from MPC if FERC approves, and it is requesting a new license from FERC. Georgetown Lake is a very important recreational lake. It lies in a high elevation scenic area and is one of the most heavily fished lakes in the state. Numerous species of fish have been stocked over the years, including rainbow, westslope cutthroat, and brown trout, grayling, and coho and kokanee salmon. The lake currently contains primarily rainbow trout, brook trout, and kokanee salmon. Depending on what happens with MFC's application to FERC, historical water use could be altered. If irrigation interests gain control of the water supply, changes could occur in lake levels as well as flows in both Flint Creek and Warm Springs Creek. The State of Montana is currently not interested in assuming responsibility for the old dam. Extensive repairs are needed to maintain and improve the power production system. However, state agencies and local residents are interested in preventing any degradation to the lake's fishery and recreational values. Montana Resources, Inc., which bought the Butte mining properties from AMC in 1985, holds extensive water rights in the Warm Springs Creek drainage. AMC used this water for copper refining in Butte. The Butte operation under MRI is smaller and does not require the former quantities of water. There is some indication (and concern) that some of these water rights may be sold. If this occurs, there may be impacts to irrigation interests as well as to instream flows in Flint Creek and Warm Springs Creek. Some of the Warm Springs Creek water was temporarily stored in Georgetown Lake prior to being pumped back over into Warm Springs Creek for transfer via pipeline to Butte. 3-124 Lower Willow Creek Reservoir. Lower Willow Creek Reservoir near Hall provides water to lands in the lower Willow Creek and lower Flint Creek valleys. The reservoir has a limited westslope cutthroat fishery, and fishery potential is poor because of extreme reservoir drawdown and poor water quality. Willow Creek above the reservoir contains a genetically pure strain of westslope cutthroat trout, a "Species of Special Concern" in Montana. The Granite County Conservation District has applied for a water reservation to construct another dam upstream from the present reservoir to provide supplemental water for lower Willow Creek and Flint Creek. This new storage facility is not expected to have a significant adverse impact on Clark Fork streamflows but would eliminate local cutthroat stream fishing in the portion of Willow Creek inundated by the new reservoir. Lake Como. Lake Como is located on Rock Creek in Ravalli County between Hamilton and Darby. The project is located on the east slope of the scenic Bitterroot Mountains and supplies water for irrigators in the Bitterroot Irriga- tion District. The aesthetic qualities are excellent when the reservoir is full, or nearly so, but decrease with increased drawdowns. With sufficient water, recreational uses include fishing, boating, waterskiing, and swimming. It provides a limited fishery for rainbow and westslope cutthroat trout. The project affects flows into Rock Creek below the dam. A canal one mile below the reservoir diverts the flows released and dries up Rock Creek during the irrigation season. There is adequate flow in most of the stream below the dam only during spring runoff when the project spills. Therefore, the stream provides only a limited rainbow trout fishery, even though the aesthetic qualities of the area are otherwise quite good. Other Irrigation Projects According to the Montana Registry of Dams, published in 1968 by the old Montana Water Resources Board, there are 80 dams with reservoirs holding 50 AF or more water in the Clark Fork Basin. These include the large projects previously discussed. Most are privately owned, and many of them lie in the Selway-Bitterroot, Anaconda-Pintlar, and Flint Creek mountain ranges. Table 3-31 lists the number of dams by county and the number used for irrigation. There are also numerous smaller reservoirs (less than 50 AF) throughout the basin used for irrigation, stock water, and fish and wildlife. 3-125 TABLE 3-31, INVENTORY OF DAMS BY COUNTY WITH 50 AF OR MORE CAPACITY IN THE CLARK FORK BASIN County No . Dams No. Used for Irrigation Deer Lodge 3 Granite 15 Mineral 0 Missoula 17 Powell 16 Ravalli 23 Sanders 6 1 14 0 11 11 23 2 Total 80 67 Source: Montana Water Resources Board 1968. Ravalli County has the highest number of small storage projects, which were constructed many years ago. Most lie on the west side of the Bitterroot Valley. Almost all of them utilize existing high mountain lakes in the Selway-Bitterroot Mountains. Dams were built on the outlets to store addition- al water for late-season irrigation use. The impacts of these small projects is not completely known. Many of the mountain lakes provide fishing for persons who hike into them, as many are in roadless and wilderness areas. Dams at some lakes have been breached for safety reasons, creating water too shallow for fishery production. Other dams are still in place but unused, and the higher water levels of those lakes produce better fisheries. Lakes with adequate depth provide moderate fishing opportunities for various trout species. There is minimal natural reproduction in inlet and outlet streams in some lakes, and most are maintained by periodic stocking. These lakes are extremely aesthetic, but drawdowns detract from this pleasantness in some cases. Because the projects store snowmelt and the stored water is released after spring runoff, there is probably a beneficial effect on the flow of tributary streams in late season, at least up to the first point of diversion. However, most of these tributaries are partially or totally dewatered by the time they reach the Bitterroot River. Return flows from use of the stored water may help hold up flows in the lower Bitterroot. 3-126 other Water Uses Other water users in the Clark Fork Basin also cause individual as well as cumulative impacts on streamflows. In the upper basin, the main Clark Fork and most of its tribu- taries are affected by irrigation diversions. Warm Springs Creek, the Little Blackfoot River, and Flint Creek are major tributaries with fisheries affected by diversions. Portions of the Clark Fork above Deer Lodge suffer from extreme dewatering, as do most of the smaller tributaries, such as Lost, Rock, Dempsey, and Racetrack creeks. These streams all provide fishing for trout, but their potential is limited by reduced flows for irrigation. The Clark Fork downstream of Drummond shows the effects of dewatering to a lesser extent than upstream reaches (tributaries excluded) because there is less irrigated land downstream of Drummond relative to the water supply. Hence, the effects of dewatering are less apparent. The dewatering problems occur in July and August in most years but begin earlier or last longer in dry years. Nearly all diversions are for agricultural use. Dewatered streams occur because of the cumulative effects of both old and new water rights. Many rights have priority dates before the turn of the century. Since 1973, when Montana implemented the new water law, water users have had to apply for and be issued a permit to appropriate water. Practically all permits in the basin are issued with few conditions that will help the dewatering problem. The effects of dewatering streams with fish populations are all generally the same — loss of physical habitat, higher water temperatures, lower food production, and decreased dissolved oxygen. The extent of these impacts depends on the degree of dewatering and the local conditions within the stream, the most severe being actual loss of a fish popula- tion when a stream stops flowing. Fishing opportunities are reduced, aesthetic qualities are poorer, and floating (where the stream is large enough) becomes difficult or impossible when insufficient flows occur, resulting in fewer recreational opportunities. Instream flows are a partial solution to the dewatering problem. However, because instream flow rights cannot affect senior diversionary water rights, they only preserve the status quo of stream depletion. The rights do not prevent dewatering, but can reduce future demands on the streams once they are acquired. Rewatering of streams that have severe flow problems can only be accomplished through new 3-127 strategies, such as purchasing and leasing senior water rights, building new storage projects, and conserving water to free up additional water for instream uses. Some of these strategies will require new legislation, but if they can be implemented, they will help improve the stream fisheries as well as their recreational and aesthetic values. 3-128 CHAPTER 4 FUTURE WATER NEEDS AND ACTIVITIES The Clark Fork Basin is blessed with an abundant natural resource base that supports the forest products industry, mining, hydropower, agriculture and ranching, recreation, and many other uses. However, because these interests often compete for land and water, careful and informed resource management decisions must be made, particularly with regard to future development in the basin. This chapter describes real and potential future water needs in the basin and examines the question of how much water is available for future development. One issue currently in the forefront is that of instream flow. Maintaining enough water in the Clark Fork at all times to protect aquatic resources, water quality, public water supplies, and hydropower needs is of vital concern. Another issue is the resurgence of mining in the basin, touched off by the current favorable market price of gold. Such a boom could place more water demands on the Clark Fork and its tributaries, not only for the mines themselves, but also for the towns that may grow as a result of mining activity. These issues and others are discussed below. WATER RESERVATIONS Introduction As discussed in Chapter 2, Montana's 1973 Water Use Act allows public entities, such as conservation districts, municipalities, counties, and state and federal agencies to reserve water for future uses. These include diversionary and consumptive uses as well as instream flows for the protection of fish, wildlife, and water quality. Some of these public entities may seek water reservations to satisfy future demands for water in the Clark Fork Basin. Potential consumptive and instream flow needs in the basin are discussed below. Consumptive Water Needs Potential future consumptive water needs in the Clark Fork Basin include water for domestic and municipal supplies, waste disposal, agricultural uses such as stock watering and irrigation, and for industry (such as mining) . At this writing, none of the communities in the basin has filed plans to expand either its municipal water supply system or its 4-1 waste disposal system. However, if growth should occur in some areas of the basin, additional surface and ground water demands could be placed on the Clark Fork system. Potential future irrigation and mining water needs are discussed separately following the sections on instream flow needs. Instream Flow Reservation Needs in the Basin In addition to the flows already requested by DFWP in the upper river (above Milltown Dam) , the DFWP has developed the following tentative list of streams and stream reaches within the Clark Fork Basin that need instream flow reserva- tions for protection of fisheries resources: River Mile 150. .4 1 157. , IL 162. .5R Montana - Idaho Border Elk Creek (tributary to Cabinet Gorge Reservoir) Bull River (tributary to Cabinet Gorge) 9.7L East Fork Bull River 25. 9L South Fork Bull River 26. 3R North Fork Bull River 167. OL Pilgrim Creek (tributary to Cabinet Gorge) 168. 7R Rock Creek (tributary to Cabinet Gorge) 175. 7R Marten Creek (tributary to Noxon Rapids Reservoir) 9.5R South Fork Marten Creek 185. 9R Vermilion River (tributary to Noxon Rapids) 2 07.5L Prospect Creek 2 . 6L Clear Creek 212. 7L Cherry Creek (tributary to Thompson Falls Reser- voir) 214. 6R Thompson River (tributary to Thompson Falls Reservoir) 6.9R West Fork Thompson River 15. 7R Fishtrap Creek 17. 9L Little Thompson River 245. OR Flathead River (probably will not include river or tributaries below Kerr Dam, because all are on the Indian Reservation) 249. 3R Seigel Creek 265. 9 L Tamarack Creek 270. 7L St. Regis River 1.6R Little Joe Creek 4.5R Two Mile Creek 8 . 2R Ward Creek 13. OL Twelve Mile Creek 18. 7L Big Creek 30. 2L Randolph Creek 286. 6L Cedar Creek 289. 6L Trout Creek 4-2 305. OL Fish Creek 8.6L West Fork Fish Creek 8.7L South Fork Fish Creek 319.7L Petty Creek 325. IR Ninemile Creek 328. 2R Sixroile Creek River Mile 334. IR Mill Creek 350. 5L Bitterroot River and major tributaries that are unspecified at this time. 358.2R Rattlesnake Creek Rock Creek tributaries: unspecified at this time — above Mi 11 town Dam Blackfoot River tributaries: unspecified at this time — above Milltown Dam In addition, the mainstem Clark Fork from Milltown Dam to the Idaho-Montana line (excluding the reservoirs) will be divided into reaches for the reservation request. To date, no community in the Clark Fork Basin has applied to reserve instream flows for future municipal needs. Forest Service Instream Flow Needs The U.S. Forest Service has the authority and respon- sibility to regulate occupancy and use of national forest lands, to prevent environmental degradation, and to protect national forest resources. When a project is proposed in a national forest that requires the use of water, instream flow needs are made a condition of occupancy and use of national forest land. To be approved by the U.S. Forest Service, all construction projects in the national forest must provide for achieving and/or maintaining the stability of channel systems (16 use 551) . Also, projects must minimize damage to scenic and aesthetic values and fish and wildlife habitat and otherwise protect the environment. 4-3 IRRIGATION The Water Resources Division of the DNRC uses a land classification system to determine the suitability of land for irrigated agriculture. The system separates arable lands into three classes based on soil type and climate. Class 1 represents land with the highest potential productivity; Class 2 lands are of intermediate potential; and Class 3 represents irrigable lands of the lowest value. Table 4-1 lists the arable acres in each class for seven subbasins of : the Clark Fork drainage. TABLE 4-1. ESTIMATED ARABLE LAND IN SUBBASINS OF THE CLARK FORK Subbasin Land Class 1 2 3 (acres) (acres) (acres) Total Arable Acres Upper Clark Fork Flint-Rock Creeks Blackfoot Middle Clark Fork Bitterroot Flathead Lower Clark Fork 950 27,531 48,722 4,386 6,471 12,419 44,754 7.186 160,752 45,893 121,614 51,442 60,807 180,065 111.666 210,424 45,893 126,000 57,913 73,226 252,350 118.852 Total 28,481 123,938 732,239 884,658 Source: DNRC Land Classification System Database. These figures represent the upper limit of irrigation development imposed by soil, topographic, and climatic factors. The number of potentially irrigable acres is reduced when economic factors, such as water delivery costs, are considered. For example, Elliott (1986) estimated that only about 13,300 acres could actually be irrigated profitably in the upper Clark Fork, which is approximately 6 percent of the arable acreage shown in Table 4-1 for that subbasin. Further study is required to determine if economic factors would have the same effect on other parts of the Clark Fork Basin. Water availability is another major constraint on future irrigation development in the basin. The DNRC (1988a) evaluated the irrigable lands identified by Elliott (1986) and found that water was not available throughout much of the 4-4 irrigation season for lands that would have been supplied from tributary flow. Water availability considerations further pared the number of acres of irrigable lands in the upper Clark Fork to about 8,400. MINING A number of companies have recently submitted plans to DSL to mine gold, silver, and copper in various tributaries of the Clark Fork. These proposed projects must be closely scrutinized to ensure that environmental degradation is minimized and that water quality is not further impaired. Some of the larger operations propose to utilize a cyanide heap leach process to recover gold from the ore deposit. In this process, crushed ore is placed on a leach pad and sprayed with a dilute cyanide solution to dissolve the gold and silver values in the ore. This solution percolates down through the ore and collects on the pad liner. The gold-and- silver-bearing solution is pumped to a process plant for removal of the gold and silver. The solution is then pumped back onto the ore pile, and the process is repeated until recovery of metals from the ore falls below acceptable economic levels (Sunshine Mining Company 1988) . Because the cyanide heap leach process has the potential to cause environmental problems, new mine plans proposing to use it will be reviewed very closely. Comprehensive water monitor- ing programs for leach pad facilities will be necessary to ensure protection of the water resources. New mines proposed in the Clark Fork Basin are discussed briefly in the following sections. More detailed information can be obtained through the DSL, the agency responsible for administering the state's hard rock mining rules and regulations. New Butte Mining. Inc. In October 1987, Butte Mining Pic (London) purchased two major mining claim blocks on the Butte Hill from Montana Mining Properties, Inc. New Butte Mining, Inc. (NBMI) , was formed as the operating company for Butte Mining Pic and will actively mine these two claim blocks and a third that was purchased later. NBMI plans to develop new and old under- ground workings along multiple vein systems in the Butte Hill for silver, lead, zinc, and gold. Extensive surface and subsurface exploration activities have begun to verify grades, tonnages, and metallurgical processing data. 4-5 The conceptual operating plan, submitted to DSL in August 1988, calls for new construction and/or modification of the Weed Concentrator in Butte to separately process the underground ore. The Weed Concentrator is currently operated by Montana Resources, Inc. (MRI) . Tailings would be mixed with MRI's tailings and pumped to the existing Yankee Doodle Tailings Pond. The mine would produce 1,500 tons of ore per day and operate two shifts per day, five days per week. The concentrator circuit would operate 24 hours per day, seven days per week. The estimated total work force would be about 200 people (New Butte Mining, Inc. 1988) . As part of it's operating application, NBMI has completed an environmental baseline study and anticipates few environmental problems. The rising ground water in the Butte mines is currently 800 feet below NBMI's operations and should not approach its' levels because of the elevation of the workings on the hill, under the city of Walkerville. NBMI estimates that there are enough base and precious metals left in the Butte district to provide employment opportunities and profit potential for many years to come, depending on the price of these metals and environmental and operational considerations. NBMI plans to submit an application to DSL for a full-scale mining permit in December 1988 and hopes to begin mining by mid-1989. Pegasus Gold Corporation The Pegasus Gold Corporation submitted an application in February 1988 to mine gold and silver in the German Gulch drainage, located about 18 miles southeast of Anaconda and 18 miles southwest of Butte. Pegasus acquired the property from Montoro, which withdrew its application after encountering difficulties during the permitting process. Pegasus Gold is a Canadian corporation with headquarters in Spokane, Washington. Pegasus also owns the Montana Tunnels and Zortman/Landusky projects. DSL issued a mine permit to Pegasus in July 1988. The development and construction phase was completed in early fall and mining commenced in October. The mine plan for the project calls for open pit mining methods with a cyanide heap leach facility on the Beals Hill saddle (7,600 feet). The operating permit boundary encompasses 1,182 acres. The ore deposit contains low-grade gold, silver, and various other elements. The ore will be crushed to one-half inch, and no fine tailings will be generated. The heap leach facility has two clay liners and a 40 ml/PVC liner to prevent ground water contamination. There will be cyanide destruction capability on site (Pegasus Gold Corporation 1988) . 4-6 Activities near German Creek will be limited to a road and a freshwater pipeline. The operation will require 1.0 cfs from the creek, which is about 15 percent of low flow. Although there is some moisture perched in the subsoil, the site as a whole is fairly dry (Pegasus' most productive well yields only eight gpm) . The expected life of the mine is ten years, but the area has not been completely explored. The total resource is 11.8 million tons of ore, with 8.7 million tons of mineable reserve. Average annual gold and silver production are expected to be 33,000 and 25,000 troy ounces, respectively. The operation would be seasonal (March to October or Novem- ber) and would employ approximately 65 people. Every attempt would be made to hire locally and to use local suppliers. Extensive baseline environmental data were collected by Montoro, and Pegasus has collected additional data on ground water, cultural resources, wildlife, and air quality that are included in the permit application. Cable Mountain Mine. Inc. Cable Mountain Mine, Inc. , submitted an application to the Montana Department of State Lands in February 1988 for a placer gold mine about 12 miles west of Anaconda. The mine is in the Cable Creek area of the Flint Creek Range, near the historic Cable Mine. The mine permit boundary encloses about 94 acres with a disturbance area of about 51 acres (Cable Mountain Mine, Inc. 1988) . The company received a permit from DSL in July 1988. It is currently in the development phase and recently submitted amendments to the mine plan. The operation will employ 13 people to mine and process approximately 1.8 million tons of gold-bearing sand and gravel over a three-year mine life, and to reprocess about 18,000 tons of existing stamp mill tailings. The design mining rate is 3,000 cubic yards/day, and the operation will utilize standard hydraulic/gravity separation methods for placer gold recovery. Coarse waste rock will be placed on a waste dump or backfilled in the pit. Fine tailings material will be routed to a settling pond. About 2,000 gpm of process water will be required to operate the plant. This water would be derived from pit inflow, adit discharge, and if needed, dewatering wells (Cable Mountain Mine, Inc. 1988) . The mine site and historically disturbed areas will be reclaimed to provide erosion control and stabilization. All disturbed areas will be recontoured, regraded, and planted with trees and shrubs. The final open cut will be left as a small lake. 4-7 Sunshine Mining Company The Sunshine Mining Company of Kellogg, Idaho, submitted an application in January 1988 to mine gold and silver at the Big Blackfoot Mine three miles west of Lincoln. The proposed mine area is located on private lands controlled by Sunshine Mining and on portions of federal land (Helena National Forest) . The application is still in the completeness review stage. The Forest Service has recently decided that an EIS will be required, while the DSL is proceeding with a prelimi- nary environmental review (PER) before deciding whether an EIS will be necessary. The project site is in the southwest portion of Lincoln Gulch, which is tributary to the Blackfoot River. The mine pit would be directly north and west of the Blackfoot River, and the ore processing facility would be in the basin of an intermittent drainage that flows east to Lincoln Gulch. The operation would utilize standard open pit mining methods, ■' ■ including topsoil salvage, ripping and blasting of rock, and a truck-shovel operation for loading and hauling. The open pit would be developed in four sections, with the first two sections of the pit backfilled with waste rock and overburden from the last two sections. Waste and overburden from the first section of the pit (about 660,000 tons) would be placed in a waste rock dump, which would be revegetated along with the backfilled portion of the pit during the life of the mine (Sunshine Mining Co. 1988) . The proposed operation would produce approximately 2 . 3 million tons of ore. The ore would be transported to a crusher, located at the leach pad facility about 1.5 miles from the Blackfoot River, where it would be crushed to three- inch minus. The leach pad would be a total containment facility with a double liner system and a net precipitation storage pond. A specialized water monitoring program for the leach pad facility would be maintained during the operational and post-operational phases of the project. Reclamation of this facility would include a procedure to neutralize the residual cyanide in the ore pile. The project would require approximately 60 gpm of water, which would be derived from two wells and the precipitation pond. After the first year, most of the water would come from the pond. Potable water would be obtained from on-site wells. The operation would employ a maximum of 55 people. The project is expected to have a seven-year life; however, if the leaching process proved economical beyond year seven, it might be extended. 4-8 The primary aim of the reclamation plan for this project is reforestation. All disturbed areas would be revegetated with tree seedlings and bunch grasses. Montana Mining and Timber Company The Montana Mining and Timber Company (MMTC) submitted an application for a gold placer operation on Gold Creek to the Department of State Lands and the U.S. Forest Service in February 1988. A mine permit was issued by DSL in August 1988. The mine area is located along the upper reaches of Gold Creek on both patented land and land administered by the Deer Lodge National Forest. The mine area includes the Pineau and Master mines, both of which are previously disturbed, unreclaimed placer mines (Montana Mining and Timber Company 1988) . The total mine area for the proposed Gold Creek project is about 244 acres, with a disturbance area of 109 acres. Approximately 1.2 million to 1.5 million tons of gravel will be processed at a rate of 3,000 to 4,000 tons/day. The life of the mine is expected to be two years, with year-round operations requiring a work force of 39 people. The company will use standard hydraulic/gravity separation methods for processing at the Master Mine Camp. Separators and a thickener tank system will be used to remove suspended sediment from the tail water. The sediment will be slurried to a sediment burial site in the Master Mine area, dewatered, and buried. Runoff catchment ditches and sediment control ponds will be constructed downgradient of each mine block for erosion control. Mining will be restricted to within 100 to 200 feet of the south and middle forks of Gold Creek, and all settling ponds will be located out of the 100- year floodplains. Channel diversion or dewatering are not expected to occur (Montana Mining and Timber Company 1988) . Water requirements for the project will be about 50 gpm, which will be supplied by two wells currently in use on the site. If needed, additional water can be obtained from the Middle Fork of Gold Creek under an existing water right. Baseline surface water, vegetation, soils, and meteoro- logical data collected for this project are included in the application. The mine site will be reclaimed to provide erosion control and stabilization and to return the disturbed areas to wildlife habitat. Trees and shrubs will be planted for cover diversity. 4-9 Mark V Mines. Inc. Mark V Mines, Inc., submitted an application to the DSL and the U.S. Forest Service in September 1988 to mine gold in the Williams Gulch drainage of Rock Creek. The proposed underground mine, called the Bagdad Gold Project, is located about 25 miles west of Philipsburg in the Lolo National Forest (MSB, Inc. 1988). Mark V proposes to extract the ore using standard small- scale underground methods. Milling-grade material would be removed from the mine and stockpiled, to be transported periodically to a custom mill in Philipsburg. Waste rock would be used for underground backfilling. While there is currently an access road within the Lolo National Forest, the plan calls for a new access road primarily within the Deer Lodge National Forest. This new road is proposed to avoid potential sedimentation in Williams Gulch, reduce traffic on Rock Creek Road, and reduce the effects of increased traffic on private landowners along Rock Creek (MSE, Inc. 1988) . Approximately 90,000 tons of ore reserves have been identified by exploratory drilling, and geologically indicated reserves are estimated at one million tons. Mark V hopes to begin production in early spring 1989, with a minimum projected mine life of ten years. The optimum level work force would be 25 to 30 people, producing 150 to 200 tons per day (MSE, Inc. 1988) . The maximum probable water discharge from the mine is 80-100 gpm. This mine water would be treated in several steps prior to discharge to a drainage ditch next to the access road. Because of the mine's proximity to the sensitive resource values of Rock Creek and the potential for public controversy surrounding the proposed Bagdad Project, the U.S. Forest Service has decided to prepare an environmental impact statement for the site, which is expected to be completed by January 1989. DSL is proceeding with a PER. American Eagle Mining Company The American Eagle Mining Company has been operating a placer gold mine in Quartz Gulch of Rock Creek since 1987. This mine, located about 20 miles west of Philipsburg, currently operates under the small miner's exclusion (less than five acres' disturbance, fewer than 36,500 tons of material per year). In January 1988, the company submitted an application to DSL and the U.S. Forest Service to expand its operation to 41 acres. The application was found to be 4-10 deficient and incomplete by DSL, and at this writing the company has not resubmitted its application. In March 1988, the DHES-Water Quality Bureau filed suit against the American Eagle Mining Company for violating the Montana Water Quality Act. In September 1987, the company discharged wastewater from its placer wash ponds without a permit. In October 1987, multiple impoundment structure failures resulted in the deposition of significant quantities of sediment in the drainage below the mine site. The DHES- WQB has sought an injunction against further mining activity until water quality violations are permanently corrected and environmental damage repaired, and it opposes the issuance of an operating permit until these problems are resolved. ASARCO. Inc. ASARCO has proposed to construct a 10,000 ton/day mine and mill complex to develop its silver-copper ore deposits under the Cabinet Mountains Wilderness. The project site is located on Kaniksu National Forest land, which is admini- stered by the Kootenai National Forest in Sanders County, on the west fork of Rock Creek approximately six miles northeast of Noxon. The ore body would be accessed through development adits with portals located outside the wilderness boundary. The underground mining would be a large-scale, mechanized, room-and-pillar operation. The ore would be crushed and ground at the ore processing complex to liberate metal- bearing sulfides. A flotation process would then be used to remove the sulfides. The copper-silver ore concentrate (about 51,000 tons/year) would be trucked to Noxon for rail shipment to a smelter (ASARCO, Inc. 1987) . The water requirement for the mill would be approxi- mately 3,000 gpm, which would be derived from mine water drainage, freshwater wells, wastewater from sewage treatment, plant site runoff, thickener overflow, and reclaimed water from the tailings impoundment. Domestic water needs are expected to be about 3 0 gpm. Tailings generated during the operation would be slurried in a pipeline to an impoundment area located mostly on private lands with portions on federal land. The impound- ment area would be continuously expanded, covering approxi- mately 376 acres during the projected life of the mine. The utility corridor containing the tailings pipelines, water pipelines, power lines, and telephone lines would generally parallel USFS Road No. 150, which would be partly relocated and upgraded to a two-lane road. ASARCO has proposed reclamation objectives and developed a plan to rehabilitate all areas disturbed during mine construction, operation, and closure. 4-11 Construction and development of the mine and processing complex would require about three years. The maximum estimated mine life at full production is 30 years, with a total production of 3.6 million tons of ore per year. Full production employment is estimated at 305 to 355 people. ASARCO originally submitted its mine permit application to the U.S. Forest Service and the DSL in May 1987. These agencies responded with a list of deficiencies, and ASARCO submitted its responses to the deficiencies in December 1987. The state and U.S. Forest Service are continuing with their completeness review. In January 1988, a public scoping meeting was held to discuss the project proposal, the environmental analysis process, and the numerous environ- mental issues that have been raised regarding this project. The major issues of concern are threatened and endangered species, wilderness, the stability of the tailings impound- ment, and water cpaality. U.S. Borax The United States Borax and Chemical Corporation (U.S. Borax) submitted a conceptual plan for a silver-copper mine in the Cabinet Mountains to the Department of State Lands and the Kootenai National Forest in January 1988. The mineral deposit is located 10 miles northeast of Noxon and 22 miles south of Libby. Mineral exploration in the upper Rock Creek drainage began in 1977, and acquisition of mining claims started in 1981. The mining claims were originally con- trolled by Pacific Coast Mines, Inc., Jascan Resources, Inc., and Atlantic Goldfields, Inc. This association formed the-, Montana Silver Venture, of which U.S. Borax was the desig- nated operator. The operation was pvrrchased by Noranda, Inc., in October 1988. The mining claims are located on federal lands in the Kaniksu National Forest. The project area is located in both Lincoln and Sanders counties. The company is considering a number of location alternatives for the evaluation adit, production adits, processing plant, tailings disposal, and ancillary facilities. Additional engineering, environmental, and economic evaluations are required before the preferred alternatives can be selected. The major decision of whether to develop the mine in the Rock Creek drainage basin or to develop it from the east side of the Cabinet Mountains on either Libby Creek or Ramsay Creek has not been made. Either scenario would involve developing the mineral deposit under the Cabinet Mountains Wilderness. The mining operation would involve excavating and crushing the ore underground, transporting it to the surface 4-12 plant for further crushing and grinding, and processing the copper-silver concentrate by flotation. Tailings generated from the process would be thickened and piped to a tailings disposal area. Water from the tailings disposal pond would be recycled to the process plant. The approximately 1,800 gpm of water that would be needed to slurry the tailings at 50 percent solids would be collected from the underground excavations. Potable water requirements are estimated to be about 100 gpm. The geologic ore reserve is over 100 million tons with an average grade of 2.1 ounces of silver/ton and 0.8 percent copper. The ore production rate is expected to be about 10,000 tons/day and 3.5 million tons annually. The next phase of development would include a decline into the deposit to provide data for defining the overall mine plan. This is expected to take 2 to 3 years and employ 35 to 50 people. The construction phase for the mine and processing plant would also require 2 to 3 years and employ 300 to 4 00 people. The projected mine life is 20 years, and 300 to 350 people would be employed in the production phase (U.S. Borax 1988) . U.S. Borax will have to obtain an operating permit subject to joint review by both the Montana Department of State Lands and the U.S. Forest Service. The company has described a program to develop the necessary environmental baseline data for the permit applications in the conceptual plan. Based on the agencies' approved plan of study, U.S. Borax is proceeding with the collection of environmental baseline data for the project area. Baseline data collection and the EIS process may take up to three years. FOREST PRODUCTS Economic forecasters indicate that the forest products industry will continue to be the backbone of western Montana's economy. While the rapid growth of the 1970s is not likely to be repeated, sustained production is expected. Many factors can influence the industry and its future, such as changes in the U.S. housing industry, adequacy of timber supply, future energy costs, and competition with other timber-producing areas (Keegan and Polzin 1987) . Timber harvest during the past decade has relied heavily on timber from private lands. Most projections indicate that private timber sources will be very limited or depleted during the next decade. At the same time, the demand for lumber and wood products is expected to increase dramati- cally. 4-13 The diminished private timber supply is expected to result in new demands for harvest in national forests. The U.S. Forest Service has completed forest plans for each of the national forests in the Clark Fork Basin. The plans show the average harvest in the past and indicate the number of acres available for timber management in the future (Table 4- 2) . Actual harvest in national forests in the future will be increasingly managed to meet the Forest Service's multiple- use criteria and to provide sustained yields of wood products. As timber supplies diminish and demands increase, forest management efforts will be intensified. TABLE 4-2. TIMBER MANAGEMENT IN NATIONAL FORESTS OF THE CLARK FORK BASIN Average Annual Suitable National Total Area^ Harvest (millions Timber Forest (millions of acres) of board feet)i: facres)-^. Deer Lodge Bitterroot Lolo Kootenai Flathead Helena 1.3 1.6 2.2 2.1 2.3 0.975 60.0 594,771 28.0 589,000 98.5 1,402,000 173.0 1,800,000 101.3 835,747 16.8 488,000 1 2 3 Areas include parts of drainage not in Clark Fork Basin. Based on average harvest over variable time periods. Estimated acres suitable for producing commercial timber. In some instances may include areas that are designated as wilderness. Sources: USDA 1985b, c; 1986a, b; 1987a, b. WATER AVAILABLE FOR FUTURE DEVELOPMENT The following sections describe water available for future development in the Clark Fork Basin. The first section addresses those issues associated with surface water, the second with ground water, and the third with water exchanges. The probability of new federal irrigation projects is discussed last. 4-14 Surface Water There are a number of issues that affect the avail- ability of surface water for new uses in the Clark Fork Basin. These issues include the number and magnitude of existing rights and the extent of the aboriginal fishing and cultural water rights claimed by the Confederated Salish and Kootenai Tribes of the Flathead Reservation. The water rights of the tribes is an important issue that should be analyzed beyond this report. The concerns related to existing water rights and claims include those claims submitted as part of the statewide adjudications and the large hydropower water rights that use most of the flows of the Clark Fork Basin. However, it should be noted that the larger water users have not objected to new uses of water, and it has not yet been established that their water rights would be adversely affected by these new uses. These issues are elaborated in the following sections. Hydropower Water Rights A number of large run-of-the-river power facilities are located in the Clark Fork Basin. They include the Milltown, Kerr, and Thompson Falls hydropower facilities, which are owned and operated by the Montana Power Company, and Noxon Rapids and Cabinet Gorge, which are controlled by the Washington Water Power Company. The WWP claimed 35,000 cfs through the statewide adjudications and received a provi- sional permit in 1976 from the DNRC for an additional 15,000 cfs for the Noxon Rapids facility. Analyses conducted by Fitz (1980) and Holnbeck (1988) suggest that water available to upstream users for future upstream development is severely limited because of Noxon Rapids. Based on data from the period 1961-1986, if WWP is certified to have a 50,000 cfs water right, then no water is available for appropriation to upstream users in eight years out of ten. On an average basis, approximately 5,900 cfs would be available for future use between May 25 and June 17 in five years out of ten. In three years out of ten, an average of approximately 21,000 cfs is available between May 25 and June 17. The long-term average flow of the Clark Fork below Noxon Rapids is 21,020 cfs (USGS 1987), which is considerably less than the 50,000 cfs capacity of the turbines at the Noxon Rapids facility. But by virtue of the appropriation doctrine, the rights must reflect the actual maximum use at any given time. Additional data are illu- strated in Table 4-3 and Figure 4-1. 4-15 TABLE 4-3. TIME PERIODS WHEN FLOWS EXCEED 50,000 CFS, CLARK FORK BELOW NOXON RAPIDS 1961-79 1961-86 Average starting date May 22 May 25 Average ending date June 17 June 17 Maximum number consecutive days 65 65 Minimum number consecutive days 0 0 Average consecutive days 24 22 Average total days 30 28 (consecutive plus intermittent) Source: Holnbeck 1988. The DNRC's policy is that before issuing any new provisional permits, the applicant must show that water is physically available in the specific source of supply requested. The burden is also on the applicant to show that the rights of prior appropriators will not be adversely affected if the new provisional permit is granted. However, absent any objections, DNRC does not require such proof. In the winter of 1987, the DNRC contacted WWP, MPC, BOR, and Montana State University (MSU) and proposed a cooperative study to assess the direction and magnitude of changes in hydropower generation that have likely occurred or could occur under different irrigation scenarios. The study began in summer 1988 and will be completed by late 1988-early 1989. The study should help ascertain whether the basin should be closed and no new provisional permits granted, whether a block of water can still be developed before basin closure is initiated, or whether some other action, such as a negotiated reallocation of WWP's rights, is more appropriate. There may be little or no water available for appropri- ation from the Clark Fork drainage upstream of Noxon Rapids. This includes the Flathead River drainage basin and the Clark Fork mainstem and its tributaries (e.g., Bitterroot and Blackfoot rivers, Rock Creek) . Even if water is available for appropriation upstream of Noxon Rapids, it may not be available in specific tributaries where it may be most needed. The water supply, existing water rights, and public interest values must be analyzed within each subbasin to ascertain whether water may be appropriated for future beneficial uses. 4-16 vD 00 s < Q m I— I < O X o s o u OS o ai < u as O < OS O O OS Q z O 1—1 H < OS Q W OS 1=1 4-16a Existing Water Rights Water rights in the Clark Fork Basin are of two categories — those perfected after July 1973 and those in place prior to that date. Water developments after 1973 were subject to permitting requirements that provided a means of assuring a reasonable correspondence between water rights and actual use. Pre-1973 water rights were not officially recorded with any degree of accuracy. The statewide adjudication program was created to recognize and confirm pre-1973 water rights in Montana, based on claims of actual water use submitted by right-holders. Table 4-4 compares the water supply characteristics of Clark Fork subbasins with the acres, volume, and flow of irrigation claims filed for pre-1973 uses. These data are compared with calculated actual water demand for acreage under irrigation facilities in 1980. One reason that the number of acres associated with adjudication claims is greater than the DNRC's estimate of actual acreage in use is that the same irrigated acreage has been claimed under more than one water right. For example, water from two or more sources may be claimed to irrigate the same ground. However, the differences that remain between claims for pre-1973 uses and reasonable estimates of present use and available water likely reflect a substantial inflation of many claims. If the acreages and flows claimed are not verified and revised where necessary to reflect actual use, inflated claims will be incorporated into the final decree, greatly complicating future water right enforcement and water allocation efforts. For example, the final decree might grant a claimant the right to irrigate 200 acres, when in fact only 120 acres have historically been irrigated. The claimant could legally irrigate 80 addition- al acres under the existing water right with a corresponding increase in actual water use. Junior users could be affected with little opportunity for appeal, and water available for future use in or out of stream could be reduced or elimi- nated. Ground Water Few aquifers in the greater Clark Fork Basin have been investigated in the detail necessary to accurately determine sustainable ground water yields. Certainly, large volumes of water reside in storage in the valley fill sediments of the Clark Fork valleys. Most of the major aquifers receive relatively abundant recharge, and several possess hydraulic and depositional characteristics that make them favorable targets for develop- ment. All, however, are integral components of the Clark Fork 4-17 TABLE 4-4. COMPARISON OF STREAMFLOUS WITH CLAIMED RIGHTS AND ESTIMATED ACTUAL WATER USE FOR IRRIGATION Subbasin Average Annual Flow cfs AF Adjudication Claims for Irrigation (pre-1973 rights) Acres cfs AF Estimated Actual Acreage in use in 1980 Acres AF Upper Clark Fork* (above Hilltown) 1.633 1,183,000 Blackfoot 1,402 1,016,000 Bitterroot 2,486 1,801,000 210,210 238,210 510,252 Flathead** 12,388 8,979,000 110,210 Lower Clark ' Fork* (from I MiUtown I past Noxon I Rapids) 21,020 15,230,000 I 56,730 3,385 996,068 80,953 1,319,765 106,930 2,308,270 126,354 55,677,877 1,590 357,763 28,821 100,681 112,755 174,917 413,000 106,180 483,710 711,700 31,659 345,110 * Adjudication claim figures for these basins adjusted to eliminate most duplication of claims for the same acreage. ** Adjudication claims submitted for Flathead Indian Irrigation Project listed flow rates and volumes, but no acreages. Sources: USGS 1987; DNRC 1988a; DNRC 1986; Elliott 1986. 4-17a hydrologic system. The level of development considered accept- able in a given aquifer system should depend both upon local considerations of ground water availability and surface water sources that recharge the aquifers and that ultimately receive ground water discharge from the aquifers. Because all aquifers receive some recharge from precipitation, only other recharge factors are discussed here. Lowland reaches of most smaller streams in the basin contain alluvial deposits that transmit ground water. The hydraulic characteristics of these deposits range from marginal to very favorable in terms of water yield to wells. They are typically limited in extent, and large well yields usually indicate nearby recharge from surface water bodies. Their location in tributary valleys frequently limits the use of such aquifers to supplying domestic and stock needs, although small- scale irrigation withdrawals are occasionally possible. Local industrial operations, especially mines, derive process water from some of these aquifers and present a potential for increased withdrawals in some areas. Secondary permeability (fracture and joint systems) controls ground water flow in most of the consolidated rocks occurring in the Clark Fork Basin. Precambrian-aged Belt series rocks, which are widespread in the basin, generally yield only small quan- tities of water to wells. Exceptions occur in areas where major fault systems provide relatively transmissive flow paths, typically along the margins of important structural basins. In these areas, well yields are occasionally adequate for community supplies and even modest irrigation. Despite their large areas of exposure throughout the region, these aquifer systems are at some risk for local overdevelopment, particularly in areas of increasing residential density, because of their storage and recharge limitations. < Bedrock aquifers featuring deep ground water circulation often express themselves as the thermal springs that are scattered throughout the basin. Some of these present the possibility of additional commercial development of geothermal water. The important high-yield aquifers of the Clark Fork region occupy the major structural/topographic basins and are composed of unconsolidated to semi-consolidated sands and gravel deposited by fluvial and glacial processes. They vary substantially in hydraulic characteristics, their mode of interaction with surface water bodies, and their relative degree of development. 4-18 Clark Fork Basin Missoula Aquifer. By measures of existing use and aquifer capability, the Missoula Aquifer is the most significant ground water system within the mainstem Clark Fork. Existing with- drawals are on the order of 61,000 AF/year, and an annual recharge of more than 87,700 AF was estimated for 1986. More importantly, the unusually favorable hydraulic characteristics of the aquifer material imply that very large increases in ground water withdrawals could be supported by the aquifer, as long as the Clark Fork is available as a source of natural and/or induced aquifer recharge (Clark 1986; Missoula City-County Health Department 1987) . Because this relationship implies responses in Clark Fork flows to ground water withdrawal, such increases in ground water use could be incompatible with instream flow objectives or existing water rights in the Clark Fork system. Upper Clark Fork. The aquifers of the Deer Lodge Valley and Silver Bow Creek are described in Chapters 1 and 3. These aquifers have a demonstrated record of supporting large well yields, at least locally. The existing high-yield wells serve as municipal, irrigation, industrial, and commercial water supplies. Relatively abundant recharge suggests that the aquifers could support higher levels of ground water development, ignoring for the moment any water quality concerns. Ground water leaves the upper Clark Fork through evapotranspiration or through discharge to gaining reaches of the Clark Fork. Bitterroot Valley. Valley-fill sediments of the Bitterroot Valley cover a relatively thin mantle of Quaternary-aged alluvial gravels (generally on the order of 50 feet in thickness) , which overlie at least several hundred feet of Tertiary-aged sediment of varying composition. The Quaternary gravels are generally permeable and can yield several hundred gpm to wells, depending on their saturated thickness. Bitterroot Valley aquifers generally receive recharge from irrigation losses and losing reaches of tributary streams; ground water flows toward the Bitterroot, which receives ground water discharge along most of its lowland reach (McMu^rtrey et al. 1972). Ground water uses from the Quaternary gravels include irrigation, municipal, and some industrial withdrawals. Less productive aquifers on the valley margins supply generally low well yields to an ever- increasing number of residential ground water users. In a number of areas, aquifers underlying elevated benches are heavily dependent on irrigation return flows and ditch seepage for recharge. Changing land uses and abandonment of some irrigation systems leave these high-elevation aquifers subject to lowered water tables and local water supply shortages. 4-19 Blackfoot River Basin. The Blackfoot River Basin contains two identifiable regions where accumulations of valley-fill sediments contain relatively large quantities of stored ground water and where favorable aquifer characteristics are at least a possibility. One underlies the river reach beginning ten miles upstream of Lincoln and ending two miles below the town. Here sediment accumulations up to 300 or more feet thick receive recharge from the Blackfoot River. The existing withdrawals are mainly small ones from domestic supply wells. There are a few more productive wells utilizing this aquifer, and some test data indicate that well yields of a few hundred gpm may be locally possible (Coffin and Wilkie 1971) . Major increases in ground water use would result in induced aquifer recharge from the Blackfoot River and/or decreased ground water discharge to downgradient gaining reaches of the river. The extensive glacial sediments underlying the lower reaches of Nevada Creek, the North Fork of the Blackfoot, and lower Monture Creek suggest that productive aquifer material may exist in places. These aquifers currently supply mostly domestic and stock wells and little information exists regarding the potential for greater ground water uses. Lower Flathead Basin Little Bitterroot Valley. The Lonepine Aquifer (Donovan 1985) of the Little Bitterroot Valley stores a relatively small volume of water in comparison with the regional Kalispell Valley Aquifer, but it is a locally important source of irrigation, domestic, and stock water. In addition, it has interesting management aspects to its behavior and use. The Lonepine Aquifer consists of very permeable gravels overlain by a massive thickness of Lake Missoula silts, which provide for effective aquifer confinement and artesian flow conditions. Most large withdrawals from the aquifer are from flowing wells used for irrigation and for supplying a commercial resort dependent on the geothermal flows that contribute recharge to the Lonepine system. Approximately 1,130 AF/year currently flow past the area of irrigation use (eventually reaching the lower Flathead River or shallow alluvial aquifers) . Pumping from the aquifer could allow for the capture of more of this through- flowing water and probably would induce additional aquifer recharge from the Little Bitterroot River. However, large additional withdrawals are not compatible with the maintenance of flowing wells in the area. Additional development could force the replacement of existing irrigation systems and the adoption of new modes of operation by the current water users. 4-20 The nearby Sullivan Flats-Big Draw Aquifer is another system with favorable characteristics for high-yield wells but with apparent constraints on the scale of development. In this case, the aquifer discharges virtually all of its modest annual flux (1,700 AF/year) through a spring that appears to be heavily appropriated for surface water use. The Mission Valley. This southern region of the Flathead Valley has a complex deposit ional history that accounts for a variety of known local aquifer systems. These are underlain by a thick sequence of glacial and glaciofluvial debris that is a widespread regional aquifer. Heterogeneous interstratif ied glacial deposits form the regional ground water flow system. It is recharged along the Mission Mountain front and at the north end of the Mission Valley. Regional flow paths are toward the south and west, discharging toward lower Mission Creek and the Flathead River (Boettcher 1982) . Locally favorable aquifer characteristics allow for yields of several hundred gpm from some municipal and irrigation wells, and flowing wells are possible in several areas. Annual recharge to the system probably far exceeds withdrawals, suggesting that the area is physically capable of supporting additional ground water development. Large additional withdrawals would occur at the expense of reduced head in the aquifer and reduced ground water discharge to the surface environment. The shallow aquifers overlying the regional flow system exhibit their own hydraulic characteristics and some degree of functional separation from the regional aquifer. Some of these are confined by surficial deposits of lakebed silts, resulting in local artesian aquifers in which wells may flow. The shallow aquifer of the Post Creek area is the most significant of these and supports domestic, irrigation, and commercial water uses often designed around flowing wells. Recharge to these flow systems may (as in the case of the Post Creek Aquifer) be abundant, but at the same time, existing uses are somewhat vulnerable to well interferences because of relatively low aquifer pressures. Jocko Valley. The Jocko Valley contains several hundred feet of valley-fill sediment, at least some of which must receive recharge from the Jocko River and irrigation systems in the area. The hydrologic characteristics of the aquifer material are not yet well described, and the aquifer's capability to support large ground water withdrawals has not been demonstrated. The existing wells are mainly small ones, used for domestic and stock water. 4-21 Water Exchanges Water exchanges may be an option to provide for future water development in the Clark Fork Basin. Three possibilities are discussed, including: 1) contracting for water from existing storage facilities, 2) sever and sell of existing water rights, and 3) leasing by the state or private parties. There are a number of storage facilities in the Clark Fork Basin whose releases satisfy existing water needs when the natural water supply cannot. While the storage capacity of many of these reservoirs may already be committed to supply the needs of existing users, others may have water available for purchase. For example, the state-owned Painted Rocks Project on the West Fork of the Bitterroot River has had water available for purchase under contract for some time. Water purchased from storage can be used in two ways. First, released water can be diverted directly by a user who is physically located downstream of the facility. Second, stored water can be purchased to replace water that would be depleted because of a new use higher in the drainage. The new user purchases the water and arranges for its release to eliminate the impact of the new use on a downstream right. Whether this approach can be taken depends on the existence of a storage facility above the affected senior appropriator. New users can also buy existing water rights and change the use and source of supply. This new water development, however, cannot adversely affect any senior or junior water users and must be approved by DNRC. There must be a willing buyer and a willing seller, and the transfer must satisfy the criteria under Montana law. Many western states have already implemented this approach to provide for new uses after basins become fully appropriated. The large hydropower facilities in Montana may be willing to sever and sell part of their water rights. This latter option may be feasible if it is based on the power company's demand for power (e.g., surplus power) and its ability to recover the lost hydropower revenues. For flows greater than 4,000 AF and 5.5 cfs, the DNRC currently has the authority to lease a limited volume of water from existing and future state, federal, and private reservoirs. For most of those reservoirs, the DNRC is the only entity that can lease water if they are included in a temporary preliminary decree, a preliminary decree, or a final decree. The DNRC must also acquire the water rights in its own name or enter into an agreement with or purchase the water from the entity holding the water right. Thus, the DNRC has the ability to lease stored water for future uses. Legislative action would be required for private parties to lease their rights. However, at this time, it 4-22 is not known whether leasing is necessary or even a viable option. The Probability of New Federal Irrigation Projects The Missoula Valley project, authorized in 1944, was the last federal project authorized and constructed in the study area. The probability of a new federal irrigation project in western Montana appears rather remote. The Bureau of Reclama- tion, in its Assessment and Implementation Plan of 1987, stressed that its primary mission as a water developer will be changed to a water resource management agency. The key finding of the study is that, "The Bureau's primary role as the developer of larger federally financed agricultural projects is drawing to a close. There have been no new construction authorizations of this type since 1968" (BOR 1987). Most U.S. Congressmen believe that the BOR has completed its primary mission of reclaiming the West. Additionally, with the surplus crops now being produced, many in Congress find it difficult to continue subsidizing new irrigation projects. In view of these circumstances, it does not appear advisable to plan on or expect such projects in the future. 4-23 CHAPTER 5 ACTION PLAN INTRODUCTION The management of aquatic resources in the Clark Fork Basin is the statutory responsibility of many agencies. Although rules and statutes place some limits on their flexibility, state, federal, and local governments can maximize their effectiveness through basinwide planning and cooperation. This chapter presents an action plan for maintaining and enhancing the quality of water and related resources in the Clark Fork Basin. It identifies primary issues and recom- mends the agency or coordinated agency actions needed to resolve them. In some instances, the action may be an interim step that must be taken before final solutions are obtained. It should be clearly recognized that the plan will continu- ally evolve — the results of past efforts, as well as plans for new programs, will require continuous reevaluation. Most importantly, the responsible agencies must progress in a logical sequence to address priority issues in coordination with other agency efforts. The action plan attempts to categorize the recommen- dations according to major issues, but there is clearly overlap among categories. This overlap demonstrates the critical need for coordination and continuous integration of information into a Clark Fork Basin management plan. COMPONENTS OF THE PLAN Data Management Throughout the past few decades, various individuals and organizations have collected environmental data in the Clark Fork Basin. These data were often not published or were generally unavailable to other interested parties. However, through a cooperative agreement with the EPA, the DHES has developed a central Clark Fork Data Management System. The initial emphasis of this system is to store and manage data collected for CERCLA (Superfund) purposes. Other data pertaining to the Clark Fork Basin are also important to Superfund and other programs and will be added to the system as needed. The Clark Fork Data Management System is also 5-1 tied to the Natural Resources Information System and the Geographical Information System administered by the Montana State Library. It is essential that valid scientific data pertaining to the Clark Fork Basin are entered in the overall Clark Fork data file, and strong support should be given to funding this comprehensive data management system. Public Involvement The purpose of the Clark Fork Basin Project has been to summarize existing information and encourage coordination of agency activities. The project has been aided in this process by the strong public interest expressed throughout the basin. Implementing the action plan and making progress on Clark Fork issues will require an informed and interested public. All phases of the planning process should be open to public participation. Government agencies should make information available to the public and should seek public involvement in decision-making. Public interest groups, such as the Clark Fork Coali- tion, which represents more than 70 organizations and several hundred individuals throughout the Clark Fork Basin, and the Northern Lights Institute, are particularly impor- tant. Their efforts to inform the public on important issues and to work with all levels of government and industry on permitting issues have aided in conflict resolution. The Northern Lights Institute and the Clark Fork Coalition propose to use a community-building approach to environ- mental problem solving by creating a "standing forum" of citizens who are committed to improving conditions on the river. Public interest groups are encouraged to participate in the implementation and formulation of the Clark Fork action plan. Funding One of the most difficult and essential components of the plan is funding. While existing state and federally funded programs can meet many requirements, most new programs will require special funding. The Clark Fork Project was initially funded through a direct grant from the Anaconda Minerals Company and later with monies from the Resource Indemnity Trust Fund. Some 5-2 funds were also available through cooperative agreements with the EPA. Funds for many of the various agency efforts in the Clark Fork Basin have been supplied by private firms as required by federal and state permitting processes. For example, Champion International, Inc. (now Stone Container Corp.), funded the fishery data collection required for the Frenchtown Mill discharge permit EIS, and the Montana Power Company has funded water quality data collection at the Milltown Dam site. Other firms and municipalities have funded data collection and analysis as needed for permit applications and renewals. Various interest groups, such as Trout Unlimited, have contributed funds directly for conducting special investigations. The EPA and the DHES have committed large sums of money to the investigation of hazardous wastes at Superfund sites in the upper basin. Recently, Congress appropriated $315,000 to the EPA to investigate water pollution problems in the Clark Fork-Lake Pend Oreille Basin. These funds have been distributed to state agencies in Montana, Idaho, and Washington to assess problems of nutrients and eutrophi- cation. Future funding will require diverse sources and innovative methods to derive maximum benefits. Public interest groups must continue to seek funds, and states must continue to work together to obtain funding for interstate projects. Joint federal, state, and local support for long- term monitoring projects will be needed to sustain progress. Careful planning and agency cooperation should make many reclamation projects eligible for funding through the Resource Indemnity Trust Fund. Certain projects may be funded partially or entirely through grants from foundations and industries. Successful funding in these instances will require careful coordination and integration of public interests. Recommendations The action plan is based on recommendations from ten technical work groups. Representatives of federal, state, and local governments and industries worked together to summarize existing conditions and to propose actions needed to correct problems and to improve the management of water resources. Because of the widely divergent interests and responsibilities of work group members, the recommendations pertain to a wide range of topics. 5-3 In general, the following recommendations emphasize abatement of pollution and careful planning of future basin developments to minimize impacts on water and related resources. Some recommendations require immediate agency action, while others suggest interagency investigations and planning. RECOMMENDATIONS Upper Clark Fork Reclamation A great deal of attention is currently focused on the upper Clark Fork, where elevated levels of metals are prevalent on land and in the waters. Remedial investigations and feasibility studies are underway at the four Super fund sites between Butte and Milltown. While most reclamation activities in the upper basin will be tied to Superfund, the extent and timetable for these activities is not certain. The following section outlines priority issues in the upper Clark Fork. Some of these are already being addressed to varying degrees through the Superfund process. "" ' " Butte Mine Flooding When the Anaconda Minerals Company ceased operations at the Berkeley Pit in 1982, all dewatering pumpage was discontinued. Since that time, the water level in the pit has risen and there is concern that this poor quality water may encroach into the alluvial aquifer and eventually adversely affect Silver Bow Creek and the Clark Fork. Since 1984, water levels in the Travona mine shaft and other mine workings have risen, and there is concern over the potential for discharge of contaminated ground water to the alluvium and/or the ground surface. EPA has several studies underway to evaluate these potential problems. The following two recommended actions are necessary first steps in this process. 1. Define the geohydrology of the mine area. While some work has been done to characterize the geo- hydrology of the mine area, it is an extremely complex and altered system. More detailed information is needed so that the potential effects of mine flooding can be predicted. 2. Develop an overall water management system to reduce the inflows to the Berkeley Pit. 5-4 Warm Springs Ponds The headwaters area of the Clark Fork has a multitude of heavy metals sources. A large part of the metals load in Silver Bow Creek is attenuated by the Warm Springs treatment ponds. However, the ponds are filling with sediment, and as their capacity diminishes, so will the level of treatment they provide. The ponds were designed to contain flows of about 700 cfs, but much smaller flows have been diverted around the ponds into the Mill-Willow Bypass because of dike failure or collection of debris on the gates. When the ponds are bypassed, untreated Silver Bow Creek water enters the Clark Fork, and metals concentrations rise, often above EPA acute aquatic-life criteria. In addition, intense summer thunderstorms can cause fish kills by mobilizing metals that have accumulated in the bypass. If the pond dikes failed because of earthquake or flood damage, millions of cubic yards of toxic sludge and sediments could be released to the river. As a whole, the Warm Springs Ponds system has been a useful sediment trap for Silver Bow Creek and has greatly improved water quality in the Clark Fork. However, the fact that water is frequently diverted around the ponds demon- strates the need to improve the system to control and reduce the movement of dissolved and suspended toxic elements from Silver Bow Creek into the Clark Fork. Stabilizing the Warm Springs Ponds against floods and earthquakes and improving the long-term efficiency of the system are also critical. These goals could be accomplished in a number of ways: 1. Renovate the existing Warm Springs Ponds system and stabilize the pond dikes to prevent damage and loss of contents during floods or earthquakes. 2. Renovate the Mill-Willow Bypass. 3. Improve the treatment efficiency of the ponds and/or expand the treatment pond capacity. These alternatives would be expensive, but they would probably be cost-effective in the long term. The ponds represent a pivotal point in the Clark Fork Basin, and improvements in the system are critical to the amelioration of the heavy metals problem in the Clark Fork. The Warm Springs Ponds system is currently a top priority operable unit within the Silver Bow Creek Superfund site. A feasibility study report that will define alterna- tives for the system is due out in early 1989. At that time, 5-5 the DHES should move quickly to select the preferred alternative and get work underway. Funding should be obtained from the responsible party. Floodplain Mine Wastes Large areas of the upper Clark Fork floodplain are covered by river-borne mine waste deposits or tailings disposal areas (e.g. Colorado Tailings) , the result of historic mining practices in which the Clark Fork was viewed mainly as a convenient means of waste disposal. These mine waste deposits are sources of contamination to soils, surface water, ground water, aquatic organisms, and other media. Once-vital riparian areas have been lost, and the mine wastes are considered blights on the landscape. The floodplain of the upper Clark Fork lies within the boundaries of the Silver Bow Creek Superfund site. It is anticipated that remedial or corrective actions to deal with the mine wastes will be implemented as part of the Superfund process. EPA and DHES have prioritized various areas within the site. Areas that pose human health hazards take precedence over those that pose environmental concern, and because the Superfund process is an arduous one, cleanup along the floodplain may be many years away. This section contains recommended actions to address some aspects of the floodplain mine waste problems in the upper Clark Fork. Reclamation of key areas along the floodplain could reduce the frequency of acutely toxic concentrations of metals in the upper river. Any management plan for the upper Clark Fork should consider how remedial actions would affect pH and alkalinity, as these parameters largely control the distribution of metals in the river. The actions outlined below should complement and perhaps expedite the Superfund process. 1. Identify priority streamside mine wastes. a. Review existing maps of streamside mine wastes in the upper Clark Fork to determine if these maps are adequate or if more mapping is needed. b. Review existing water quality data (particularly metals loading data) to help identify and priori- tize streamside mine waste areas best suited for reclamation. 5-6 c. Conduct a detailed ground survey to identify mine waste areas that are the most erosion-prone and that would be good candidates for reclamation efforts. 2. Define the geochemistry and hydrogeologic setting at priority streamside mine waste areas. a. Undertake a detailed geochemical and hydrologic study of sites selected for initial reclamation work. b. Use existing survey data, especially that developed by the University of Montana Geology Department, to determine additional study needs. c. Develop a detailed map of metals distribution in the priority floodplain mine waste areas. d. Monitor soil and ground water. 3. Evaluate the fluvial mechanics of the upper Clark Fork. Conduct a detailed evaluation of the fluvial mechanics of the river prior to any major reclamation efforts. Identification, evaluation, and reclamation of stream- side tailings areas could be wasted efforts if the river mechanics are poorly understood. The issues of potential sources of contamination from surface runoff, bank erosion, etc., must be set within the context of how the river functions as a physical system. 4. Select candidate sites for reclamation. Base selection of floodplain mine waste areas for recla- mation work on the geochemical, hydrogeologic, and physical setting, access, and landowner cooperation. Ideally, the sites selected would represent a variety of environmental conditions so that the knowledge gained from a few sites could be transferred to other sites in the floodplain. 5. Conduct reclamation demonstration projects. Conduct demonstration projects to test reclamation techniques in limited areas of streamside mine wastes before full-scale remedial actions take place. Results of these projects should be made available to land- owners, government agencies, and others interested in reclamation. 5-7 6. Support cleanup of large mine waste deposits. The Colorado Tailings and Ramsay Flats areas have been studied intensively by a number of groups in the past several years. Both areas are documented contaminant sources to Silver Bow Creek and local ground water. Emphasis should begin to be shifted from study to direct reclamation and abatement of these known pollution sources to reduce metals loading to Silver Bow Creek and the Clark Fork. Funding for reclamation of streamside mine wastes in the upper Clark Fork should be sought from the responsible parties. If there are no PRPs, other possible sources of funding include the Resource Indemnity Trust Fund, the General Fund, and the Coal Tax Fund. Soils and Reclamation Large acreages in the upper Clark Fork Basin are contaminated with a variety of substances, primarily arsenic and heavy metals. Most of the soil contamination is the result of smelter emissions, use of tailings-laden irrigation water, or proximity to waste dumps. The contaminated areas pose a number of human health and environmental hazards. People who live near waste dumps or contaminated soils may be exposed to dangerous levels of pollutants. Contamination of soils has resulted in loss of productive land and reduced agricultural yields. These soils are potential sources of surface and ground water contamination. The areas of greatest concern are in the vicinity of Butte and Anaconda within the boundaries of the Silver Bow Creek/Butte Addition and Anaconda Smelter Superfund sites. Expedited remedial actions have been initiated by the EPA in the communities of Mill Creek (relocation of residents) and Walkerville (removal or reclamation of waste dumps; cleanup of residential yards) . More of this type of work may be done in residential areas near the Old Works in Anaconda and Timber Butte south of Butte. However, once the immediate health hazards are re- solved, large acreages of contaminated land will still remain in both residential and agricultural areas. To date, EPA and the state have not established metals action levels for the Butte and Anaconda areas. Action levels established for other areas (e.g., the East Helena Superfund site) are likely not applicable because of natural variation in background metals levels due mainly to differences in geology. Establishment of site-specific hazard level criteria is 5-8 critical to the process of reclamation in the Butte and Anaconda areas. In the Deer Lodge Valley, there are areas that are devoid or nearly devoid of vegetation due to contamination from either smelter emissions or historic use of tailings- laden irrigation water. The lack of perennial vegetation in these areas results in wind erosion, increased surface water runoff, increased recharge of the shallow ground water system, and possibly increased metals loading to surface and ground water. Although some reclamation projects have been initiated to address these areas, more research is needed to determine if large acreages can be cost-effectively re- claimed. In order to establish hazard level criteria for the Butte and Anaconda areas, to support funding for reclamation projects, and to begin to establish vegetation in barren areas in the Deer Lodge Valley, the following strategies are recommended: 1. Conduct a background metals levels study in the Butte area . Determine natural concentrations of arsenic, cadmium, copper, lead, and zinc in soils in the vicinity of Butte. Because Butte is a highly mineralized area, background metals concentrations in soils may be higher than "typical" concentrations. The study must be carefully designed to avoid areas contaminated by smelter emissions, waste dumps, and other sources of contamination. The data will be useful in assessing the risks of heavy metals contamination and in establishing appropriate cleanup levels. 2. Establish action levels for soils cleanup for the Silver Bow Creek/Butte Addition and Anaconda Superfund sites. Establish appropriate action levels for soils based on health risk and environmental assessments, the new back- ground soil study for Butte, and the existing background soil study for Anaconda (Tetra Tech 1986c). The Superfund regulations require that the EPA and the DHES first determine action levels that are protective of human health and the environment without regard to cost. The next step is to determine cost-effective remedies for meeting those action levels. 5-9 3. Support funding for reclamation projects. Make funding of reclamation projects in the Clark Fork Basin a high priority. There must be sufficient funding in place to monitor the effectiveness of various reclamation techniques and to determine if there are environmental impacts associated with those techniques. 4. Apply reclamation techniques to larger areas. a. Transfer the knowledge gained from studies on small demonstration plots to larger land areas to determine if the techniques are successful, economically feasible, and environmentally sound. b. Fund the next phase of the Headwaters RC&D project, which involves six 10 to 15-acre sites, as a first step toward reestablishment of forage on lands contaminated by mine waste. Funding of other reclamation demonstration projects will be critical in the future. Funding for the background soils study should be provided through the Super fund process. Reclamation project funding could be derived from a number of sources, including the RIT program, Superfund, or the responsible party. A cost-share program should be considered to encourage landowner participation. Without such a program to under- write a portion of the reclamation costs, reclamation of agricultural lands would not likely be cost-effective for individual farm enterprises. Surface Water Quality The recommendations listed above for the upper Clark Fork primarily address the pervasive metals problems in the upper river. Reclamation efforts aimed at the variety of mine wastes could lead to eventual improvement in surface water quality. However, a number of other factors, such as nonpoint source pollution, nutrients and eutrophication, DO, and temperature are also current water quality problems in the Clark Fork. Recommended actions to address these issues are outlined below. 5-10 Nonpoint Source Pollution Nonpoint source pollution is caused by diffuse sources that are not regulated as point sources and normally is associated with activities such as agriculture, silviculture, construction, land disposal, hydromodif ication, and others. The primary pollutants are sediments, nutrients, toxic substances, pathogens, pesticides, acidity, and salts. Nonpoint source pollution is a major problem in the Clark Fork drainage. The primary pollutants are metals, derived from floodplain mine wastes and waste disposal areas, and sediment, derived mainly from agriculture and silvicul- ture. In the past, nonpoint problems in Montana have been addressed in a somewhat fragmented manner. However, baseline information does exist, and it can be used to compare future measurements of nonpoint source effects and to gauge the effectiveness of control programs. In 1985, Montana joined 55 other states, territories, and interstate water quality agencies in assembling existing information on water quality impacts caused by nonpoint sources of pollution. The effort was coordinated and the findings compiled and published by the Association of State and Interstate Water Pollution Control Administrators. The federal Clean Water Act of 1987 established a new policy for the control of water pollution, including a directive to the states to develop and implement programs to control nonpoint sources of pollution. Section 319 of the Act provides the legal basis for implementing such programs and sets forth requirements the states must meet to qualify for assistance. The State of Montana must strive to meet those requirements. Some of the funds should address critical nonpoint source problems in the Clark Fork Basin. Identifying, prioritizing, and initiating programs to reduce nonpoint source pollution problems in the Clark Fork Basin should be important goals for Montanans. Strategies for achieving these goals are: 1. Support the state nonpoint source management program. State, federal, and local agencies should aggressively pursue actions recommended by the DHES-WQB in the state nonpoint source management program proposed under Section 319 of the Federal Clean Water Act of 1987. The report, entitled Nonpoint Sources of Water Pollution in Montana, is available from the DHES-Water Quality Bureau in Helena. 5-11 2. Develop a specific NPS management plan for the Clark Fork. a. The DHES-WQB should develop a comprehensive, coordinated NPS control program for the entire Clark Fork Basin as an extension of the 319 program. Separate NPS control programs may be generated for specific areas of the Clark Fork. b. Identify and prioritize existing water quality problems and detail actions needed, including monitoring. c. Draw heavily on ongoing assessments of NPS problems in Montana and on plans prepared by EQC, the Cumulative Watershed Effects Cooperative, etc. 3. Create a regional water quality managers program. All agencies involved in NPS programs should support state and federal funding to develop a network of regional water quality managers in the DHES-WQB to tackle the NPS problems in the basin. These NPS water quality managers would be responsible for: developing nonpoint assessments and management plans in their region reviewing plans for activities (e.g., timber sale plans, mine plans) that may contribute nonpoint source pollutants to streams inspecting sites where land 'disturbance may occur to determine that BMPs are being employed conducting baseline monitoring holding meetings to keep the public apprised of the program and to receive their suggestions working with other agencies and organizations involved in regulation and abatement of nonpoint source pollution conducting complaint investigations. The Clean Water Act of 1987 calls for a 60/40 federal/ state match for funds. The Act earmarked the following monies for NPS programs, for which the states compete: 5-12 FY 88 $ 70 million FY 89 100 million FY 90 100 million FY 91 130 million However, Congress appropriated no money for FY 88, and EPA did not request any of the $100 million authorized for FY 89. There is currently an effort in Congress to direct EPA to apply some funds to the program in FY 89 from its existing budget. Another potential source of federal funds for nonpoint source pollution abatement is the so-called Governor's 20% Discretionary Fund, which is a portion of the state's allotment of money for construction of municipal wastewater treatment plants. The Water Quality Act of 1987 amended Clean Water Act Section 201(g) (1) by adding subsection (B) , which establishes a new purpose for which these funds can be used: "... any purpose for which a grant can be made under section 310(h) and (i) of this Act (including any innovative and alternative approaches for the control of nonpoint sources of pollution)." Any nonpoint source projects funded with section 201(g)(1)(B) money would require the same 40% nonfederal match as would those funded with section 319 money. The state has been told by EPA that Montana's Coal Severance Tax funds and the interest on the State Resource Indemnity Trust, which are used to support conservation programs, may be used as match for Clean Water Act section 201(g) (1) (B) funds if the identified conserva- tion programs are part of an EPA-approved NPS management program. Nutrients and Eutrophication Excessive algae growths in the Clark Fork and Lake Pend Oreille are one of the more difficult water quality problems of the Clark Fork Basin. Except for controlling heavy metals pollution in the upper basin, the problem of nutrients and algae growth is considered the highest-priority issue. Dense mats of filamentous green algae and diatoms, besides being aesthetically unattractive, affect water uses such as recreation and irrigation. Algae produce oxygen during daylight hours; but at night, in the absence of photosynthesis, algal respiration can deplete the oxygen needed by fish and other aquatic organisms. Large quantities of algae eventually die, creating sludge deposits and oxygen demands. Rooted aquatic plants (macrophytes) found in lakes or river backwaters have similar effects when they occur in excessive quantities. In the Pend Oreille River in Washing- ton, very dense growths of aquatic vegetation (Eurasian 5-13 milfoil) have choked out most other uses, including boat traffic. The cause of excessive algae growths is primarily due to the high concentrations of basic nutrients (nitrogen and phosphorus) found in the Clark Fork-Pend Oreille system. Despite this general knowledge, however, very little is known regarding the sources or fate of nutrients in this aquatic system. Nitrogen and phosphorus enter the water from the basin's natural geologic strata, irrigation return flows, animal wastes, domestic and industrial wastewater, and the atmosphere. The relative contribution of nutrients from each of these sources is generally unknown. Controls on nutrients to slow down or reduce eutrophi- cation can be implemented by a variety of methods, including: treating wastewater, limiting or banning the use of phos- phates in certain products (e.g., detergents), reducing soil erosion, putting voluntary restrictions on the use of lawn 'i- fertilizers, placing and maintaining septic tanks properly, treating urban stormwater runoff, and encouraging proper land use activities. Many of these control efforts require strong citizen support and voluntary participation; others require relatively expensive treatment operations. A special program to investigate the sources and fate of nutrients in the Clark Fork-Pend Oreille Basin was initiated in 1988. The investigation is a coordinated program funded under Section 525 of the Clean Water Act Amendments of 1987. The states of Montana, Idaho, and Washington, working in cooperation with the EPA, have outlined a three-year assessment of nutrient-eutrophication problems in the basin. The results of this investigation are expected to provide a measure of the eutrophication problem and sources of nutrients and to indicate appropriate control measures. The continued close cooperation of the three states is essential in meeting the program goals and sustaining the required funding. The following is an outline of the three-state program: 1. Montana study objectives. a. Conduct a critical review of all available criteria relating periphyton standing crop to beneficial uses and factors regulating periphyton standing crop in flowing waters. b. Determine the existing standing crop and nutrient status of periphyton in the Clark Fork River (seasonally) and relate data to existing criteria. 5-14 c. Conduct an on-site study at selected locations to determine factors (e.g., sediments, nutrients, temperature, substrate, metals, macroinvertebrates) limiting periphyton growth and standing crop in the Clark Fork. d. Identify primary nutrient sources and establish appropriate criteria for controlling periphyton growth in the Clark Fork Basin. 2. Idaho study objectives. a. Develop a nutrient budget for Lake Pend Oreille, including point and nonpoint sources. b. Assess nutrient levels and/or reductions necessary to protect lake water quality. c. Provide a final report in the Clean Lakes Phase I Diagnostic Study format. 3. Washington study objectives. a. Evaluate the trophic conditions within the Pend Oreille River system, including identification of limiting nutrients and characterization of current trophic status. b. Develop a seasonal and annual nutrient and water budget for the reach from Albeni Falls Dam to Box Canyon Dam (RM 90 to RM 34) . c. Characterize external loading sources to the Pend Oreille River, including comparison of local tribu- taries, nonpoint, and point sources. d. Evaluate potential internal loading of nutrients from macrophytes and sediments. In addition to the Montana objectives listed above, the following are recommendations for nutrient-related issues in the Clark Fork. 1. Determine the effects of the Phosphoria Formation and phosphorus mining on water quality. Determine the phosphorus load derived from the Phos- phoria Formation, a geologic strata rich in phosphorus near Garrison, or from past and present phosphorus mining in the area. The investigation should begin with 5-15 a thorough review of existing information on the geochemistry of the Phosphoria Formation, including its potential for affecting surface and ground water. Intense surface and ground water sampling should be conducted to characterize these sources of phosphorus. Wells should be sampled in the Garrison area during summer when ground water is most likely to enter the river and when additional phosphorus would cause the most problems. 2. Monitor nitrogen loading from the Bitterroot River. Conduct intense water quality monitoring along the lower Bitterroot to pinpoint the sources contributing to elevated levels of nitrogen in the Clark Fork system. The Clark Fork should be monitored directly above and below the confluence with the Bitterroot to determine the nitrogen load attributable to the Bitterroot. Septic drainfields and irrigation return flows are suspected sources. 3 . Limit nutrient loading to the Clark Fork and Lake Pend Oreille. a. Criteria for controlling eutrophication in the Clark Fork and Lake Pend Oreille are not known but common sense indicates we should work to limit nutrient loading. The Water Quality Bureau should require that all MPDES permits restrict nutrient loading in compliance with the nondegradation rules of the Montana Water Quality Standards. b. Regulatory agencies, industries, municipalities, and public interest groups should work to identify opportunities to reduce all forms of nutrient loading to the Clark Fork Basin. Some additional control of point and nonpoint sources may be necessary. DO, Temperature, and Mixing Zones It is important to maintain sufficient dissolved oxygen concentrations in the Clark Fork to meet the needs of fish and other aquatic life. Elevated stream temperatures, when combined with suboptimal dissolved oxygen levels, can have a synergistic effect on salmonid populations. Although some work has been conducted to study DO and temperatures in the Clark Fork, additional monitoring is warranted. 5-16 Monitoring efforts in the Clark Fork would be improved if the mixing zones created when tributaries enter the river were delineated. Otherwise, it is difficult to know if the tributary water or the Clark Fork is actually being moni- tored. The following actions are recommended to address these issues. 1. Monitor DO concentrations at key locations in the Clark Fork. Initiate a special WQB monitoring program to measure late summer, diel DO concentrations at key locations in the basin. Twenty-four hour measurements could define the duration as well as the magnitude of DO sags (the length of the DO depletion might be as critical as the minimum concentration) . The monitoring program should provide a systematic evaluation of DO in the river to determine if concentrations are affecting beneficial uses. 2. Monitor water temperature regimes in the Clark Fork. Initiate a program to characterize the water temperature regimes in critical river reaches, particularly during late summer. Temperature, like other water quality parameters, is highly variable, and a long-term data base is essential to interpret changes and to establish long-term trends. Available temperature data should be completed and analyzed to establish a historical data base. 3 . Document the extent of the mixing zone for Clark Fork tributaries. Conduct a rhodamine dye study to determine the extent of the mixing zone created when a tributary enters the Clark Fork. Failure to consider the extent of mixing could lead to erroneous interpretations regarding water quality and its relationship to other uses. Monitoring Water quality monitoring is one of the essential tools of water quality management. Scientifically valid data collected over a long period are necessary to assess changes in water quality. The need for water quality data on the Clark Fork became most evident in 1983 when Champion Inter- national, Inc., applied for a modification of its wastewater 5-17 discharge permit. The lack of adequate data to support permitting decisions resulted in delays and public uncer- tainty. Since 1984, the Water Quality Bureau has maintained an intensive water quality monitoring effort at more than 3 0 stations located from near the headwaters to the Idaho border. This water quality sampling, supplemented with biological data, is the most comprehensive water quality record for the basin. It is essential to continue this monitoring program for at least another biennium and to initiate other special monitoring programs to meet short-term monitoring goals on the Clark Fork. In addition to the WQB monitoring, several other agencies and industries have collected valuable data from surveys and specific projects. All of these programs have improved our knowledge, but developing a long-term, compre- hensive environmental monitoring program for the Clark Fork Basin is paramount. This long-term monitoring program should provide a sufficiently detailed record of water quality and biological data to identify trends and new problems and to measure the effects of resource development, changing land uses, and reclamation and pollution control programs. The strategies for achieving short-term monitoring goals are: Continue WQB monitoring in the Clark Fork Basin. a. As an interim to a future comprehensive program, the current WQB monitoring program should be maintained. Continuance of current monitoring can provide information for trend analysis, refine our knowledge of certain pollutants such as nutrients, measure progress in Superfund cleanup in the headwaters, measure effects of new mining projects, and define water quality over a broader range of flow conditions (FY 85-88 were relatively low-flow years) . b. This monitoring program should be reviewed to determine if changes are needed and if the program could be streamlined. c. Approve the WQB budget request to continue the monitoring program for another biennium. 5-18 2. Collect baseline monitoring data in some tributaries of the Clark Fork Basin. Collect baseline monitoring data in tributaries, especially those that may be affected by proposed mines, forest practices, and other activities that may con- tribute to nonpoint source pollution problems. Funding for baseline water quality monitoring of tributaries should be shared by the industries. 3. Monitor the effects of short-duration, high-intensity runoff events on Clark Fork water quality. Most water quality monitoring programs on the Clark Fork are designed to monitor late spring-early summer runoff events. However, in the last couple of years, significant late winter-early spring snowmelt runoff and thunderstorm events have occurred, and water quality monitoring programs designed with fixed-interval sampling often miss these events. Limited water quality samples that have been collected during these events have contained very high concentrations of heavy metals, and a number of fish kills have occurred near the head- waters. Although new monitoring programs have recently been initiated in the headwaters (installation of streamflow gaging stations by the USGS under contract with EPA, and short-term [August-November 1988] sampling of continuous monitors and an automatic sampler by the MBMG under contract with DHES-SHWB) , additional systematic monitor- ing is needed to define the frequency, duration, and extent of these conditions. Daily or every-other-day monitoring at one or two stations may be required for short periods. Additional flow-activated automatic sampling devices and the help of local residents in collecting water quality samples may be needed as well. Recommendations to meet long-term monitoring goals are; 1. Create a water quality monitoring cooperative. Appoint a monitoring cooperative (or committee) consisting of representatives from agencies or groups that have a direct interest in water quality management in the basin, such as DHES, DFWP, DNRC, DSL, USES, USGS, MBMG, SCS, Conservation Districts, the Confederated Salish and Kootenai Tribes, local governments, indus- tries, and others. 5-19 Develop a cooperative monitoring program. The goals of the monitoring cooperative or committee will be to: at Design a comprehensive ambient water quality and biological monitoring program that provides the sampling procedures, analytical methods, and quality control needed to satisfy all partici- pants' requirements. b. Reduce overall monitoring costs. c. Provide baseline data that can be supplemented with project-specific investigations. The monitoring program should: • define goals and objectives • define how the data will be stored and used by the participants • identify the specific monitoring needs of the Clark Fork and eliminate duplicative or nonessential monitoring • identify data needed to meet monitoring objectives • describe the following program components: -sampling station -sampling frequency -sampling techniques -analytical techniques -quality assurance program -data analysis and storage • estimate annual costs associated with the monitoring needs • define appropriate mechanisms for funding • define the appropriate role for each participant in implementing the program • recommend a structure and cooperative agreement to manage the monitoring program, including a schedule of periodic meetings to review and interpret data and to make necessary adjustments in the program 5-20 • identify how citizens should participate in the program. Water quality specialists assisting in the preparation of this report have suggested that a minimum of four monitoring stations are needed to measure long-term trends in Clark Fork water quality. As an example, the following monitoring program has been suggested: Four key monitoring stations (Deer Lodge, Turah, Alberton, and Whitehorse Rapids) should be maintained in the Clark Fork. Study parameters might include pH, EC, TSS, VSS, hardness, alkalinity, temperature, total recoverable and dissolved metals (As, Cu, and Zn) , daily sediment (at Turah and possibly Alberton) , and biota (monitored once per year at Turah and Deer Lodge) . Water quality should be monitored 12 times per year based on streamflow, and established stream gaging stations should be maintained at Deer Lodge, Turah, and Whitehorse Rapids. A new gaging station would be needed at Alberton. The USGS estimates that such a program would cost $91,000 the first year and $86,000 per year thereafter. Ground Water Ground water is a widely used resource in the Clark Fork Basin, and a number of investigators have characterized the quantity and quality of the ground water system. However, very little ground water work has been done in the lower river, and specific ground water quality issues remain in the upper and middle river. The following studies are recom- mended to address these issues. 1. Conduct ground water studies of the lower Clark Fork. a. Further water management objectives by making long- term observations in the lower Clark Fork Basin in areas where changing land uses, increased consump- tive water use, and other cultural activities may influence ground water availability and quality. Most of the ground water monitoring emphasis in the Clark Fork Basin has been focused in the upper basin. However, not all monitoring needs are tied to the areas of historic mining impact in the headwaters. b. Conduct a reconnaissance ground water study of the lower river (from Huson to Lake Pend Oreille) to gather basic information about the local aquifers and their relationship to the Clark Fork. A number of new monitoring wells may be required. 5-21 2. Study ground water effects on metals loading. Conduct a comprehensive study of the contribution of ground water to metals loading problems in the upper Clark Fork. The study should use existing wells (and possibly some new wells) and should focus on the headwaters and Deer Lodge areas. This may be partially addressed through the Silver Bow Creek RI/FS and the Clark Fork screening study. 3 . Document the extent of the carbonate zone and ground water flow patterns in the vicinity of the Anaconda and Opportunity ponds. Again, this may be addressed when the geohydrologic and geochemical conditions in the vicinity of the Anaconda and Opportunity ponds are further inves- tigated during future RI/FS activities at the Anaconda Smelter site. a. Determine the actual thickness of the alluvial deposits underlying the tailings contained in the Anaconda and Opportunity ponds. Two distinct source zones for solutes have been identified in the tailings — a saturated zone just above the alluvium and an oxidizing zone in the upper part of the tailings that will slowly move downward. Modeling has predicted that many thousands of years from now, oxidation of sulfides to sulfuric acid could lower the pH at the bottom of the tailings and cause the release of metals such as arsenic, cadmium, copper, lead, and zinc (Tetra Tech 1986b) . If there is sufficient thickness of carbonate-rich alluvium beneath the tailings, the acidity may be neutralized and the metals atten- uated before reaching the ground water. The unconsolidated alluvial deposits are estimated to range from more than 100 feet thick in the western portion of the site to about 20 feet thick east of the Opportunity Ponds. However, a detailed study should be conducted in the vicinity of the ponds to document the actual thickness and percentage of carbonate in the alluvium to determine if it will afford adequate ground water protection in the future. More modeling efforts may be required to make this determination. b. It is also important to determine ground water flow patterns through the carbonate zone of the alluvium. It may be that only a portion of the carbonate mass is available to attenuate the metals. An investigation should be initiated to address this question. 5-22 Initiate a monitoring network and a public education program in the Missoula Sole Source Aquifer designated area. The Missoula Aquifer was designated as a sole source aquifer in June 1988. The aquifer supplies nearly 100 percent of the drinking water for the greater Missoula area. A monitoring network should be established to help track changes in water quality and assist in making informed management decisions. In addition, a public education program should be initiated to encourage responsible use of the ground surface as a means of reducing pollution. Fisheries The Clark Fork fishery has been seriously damaged by more than a century of water quality degradation and physical habitat alterations. Water pollution abatement in the past two decades has improved the fishery, but game fish are considerably less abundant in the Clark Fork than in other rivers of comparable size. The factors affecting the fishery change as the stream flows from its contaminated headwaters to its confluence with Lake Pend Oreille. Some of these factors are readily recognized, while others are less obvious and require additional investigation. The upper river fishery continues to be damaged by the acute and chronic toxicity of heavy metals. Copper concen- trations frequently exceed criteria for the protection of aquatic life at all locations in the upper river. Episodes of acute toxicity, which often occur after thunderstorms, may kill an entire population, but the survival of early life stages of trout is probably most affected by chronic metals pollution. The scarcity of trout in most of the upper river further suggests that reproduction and recruitment are limited. Another obvious factor affecting trout production is the seasonal dewatering of the Clark Fork and its tributaries. Dewatering because of irrigation diversions results in diminished fish habitat and marginal water quality condi- tions. Segments of some tributaries are dewatered entirely for short times during some critical water years. The effects of other factors on the upper river fishery are less well known. Information is needed on spawning areas and on factors (other than toxicity) that may limit recruit- ment of young fish into the population. Physical habitat degradation has occurred in several areas due to mining waste deposits, stream channelization, and heavy livestock use in 5-23 riparian zones. Physical degradation could continue to affect fisheries even if water quality improvements were achieved. Less is known about the fishery from Milltown Dam to the mouth of the Flathead River. DFWP has surveyed fish populations in this reach and evaluated the importance of tributaries as spawning areas only in the past few years. Preliminary data suggest that the abundance of game fish is considerably below other rivers of comparable size. The lack of suitable spawning tributaries in this segment is thought to be a major factor in limiting salmonid populations. Water quality may also be a factor, as biologically sig- nificant heavy metals contamination has occurred in the Clark Fork below the Milltown Dam in high runoff years. The lower river fishery has been most affected by physical habitat alterations. The hydropower dams and reservoirs of the lower river have blocked fish migrations and created relatively poor fishery habitat. The rapid water exchange through the reservoir and fluctuating water levels limit the biological productivity needed to sustain a larger fish population. Early attempts to manage the reservoirs exclusively for salmonids have been unsuccessful, but recent introductions of cool-water species have shown some promise. The availability of spawning areas for salmonids is limited. Some tributary streams have subterranean flows in the lower reaches that block spawning migrations; other streams are scoured during spring runoff leaving poor spawning sub- strates. The goals of a fisheries program for the Clark Fork are to increase the abundance of game fish throughout the mainstem and to identify and protect the habitat required to sustain game fish production. Improving the Clark Fork fishery requires action, especially on the part of DFWP, in several separate, but related categories: 1. Eliminate acute and chronic toxicity conditions in the upper river. Design and implement a reclamation plan to prevent the direct entry of precipitation runoff from streamside tailings into the river. The reclamation plan should utilize existing data and new information gathered for this purpose (see "Floodplain Mine Wastes") . Government agencies, private parties, and landowners should work together on this plan. 5-24 2. Investigate trout fry and fingerling survival in the Clark Fork mainstem. a. Continue DFWP investigations of trout fry survival at selected locations in the upper river. Live fish containers developed for this purpose should be placed to help identify specific locations where acute and chronic toxicity conditions exist. These data should be used in the development of a reclamation plan (see #1) . b. Continue DFWP evaluations of the survival and growth of trout stocked at key locations in the river. The data gained from these test plants will be useful to assess the relative survival rates of different trout species and to better define factors that limit trout abundance. 3. Remove barriers to potential spawning areas. a. Identify all tributary streams where spawning trout migrations are blocked by natural or man-made barriers, and work with landowners and sportsmen's groups to remove such barriers or provide fish passage around them. The following tributary streams have been identified as having barriers or potential barriers to spawning trout: Sixmile Creek, Harvey Creek, Tamarack Creek, Siegel Creek, Elk Creek, and Prospect Creek. b. Exercise beaver control on streams where beaver dams are affecting trout access to important spawning areas. 4. Protect instream flows. a. Complete measurements of instream flow requirements for fisheries and analysis of fish populations on the middle river and tributaries. DFWP study results should be used to support an application for water reservations needed to maintain and enhance the existing fishery. b. Investigate opportunities for the public or private purchase or lease of water rights in the key tributary streams to maintain instream flows. Warm Springs Creek at the Clark Fork headwaters is an example. c. Continue seeking a long-term DFWP lease or purchase of water rights from Painted Rocks Reservoir to maintain instream flow in the Bitterroot River. 5-25 d. Provide for a state water commissioner to monitor and control legal water uses, especially on the upper Clark Fork and on the Bitterroot River. 5. Survey spawning grounds. Conduct a systematic survey of tributary streams to identify important spawning grounds and rearing habitat. The DFWP should protect critically important areas by special regulation, riparian zone management, instream flows, and other management programs as needed. 6. Regulate reservoir water levels. Evaluate the tradeoffs among various user groups under different flow scenarios with an integrated model utilizing data on the water requirements for irrigation, recreation, and fisheries. The model should be used to determine reservoir operations that have the least effect on beneficial uses and the most benefit across the broadest array of uses. 7. Develop a stream corridor management plan. Utilize existing information on channel instability due to natural and man-made events, riparian land uses, riparian vegetation, sediment transport, and hydrologic data to prepare a stream corridor management plan for the Clark Fork Basin. The plan should involve local, state, and federal agencies, other interested parties, and landowners and should provide for long-term management programs to protect agricultural lands, enhance water quality, and protect and enhance fish and wildlife habitat. The plan shouid identify funding requirements and sources, and outline an implementation schedule. 8. Improve physical habitat for aquatic life. a. Commission a bottom-contour map of the Noxon Rapids and Cabinet Gorge reservoirs to aid in fisheries management of the reservoirs. The map should include depth contours at least down to the level of maximum drawdown to assist fisheries and reservoir managers to minimize effects on fisheries and optimize biological production. b. The DFWP should work with sportsmen's groups and the Washington Water Power Company to develop and evaluate artificial structures in the reservoir to create fish habitat and substrates for macro- invertebrates . 5-26 9. Complete fish population analysis for the upper Clark Fork. The DFWP should complete the analysis, interpretation, and publication of fish population data collected in 1987, as this is the most complete population inventory ever attempted on the Clark Fork. The data analysis should be made available to all interested parties. Recreation The Clark Fork Basin offers many exceptional recrea- tional opportunities. The river and its tributaries are a focal point for many forms of recreation ranging from waterfront parks in Missoula to Whitewater rafting in Alberton Gorge. Many individuals and groups have urged the state to more actively promote recreation and tourism as a means to diversify the basin's economy. Many private and public facilities exist to meet recreational needs, but it is unknown if appropriate facilities are available for future needs . Federal, state, and local government agencies, and universities should work to evaluate recreation needs and to formulate plans for improved recreational opportunities. The following agencies should be involved in this planning effort: Department of Fish, Wildlife, and Parks, Department of Commerce, U.S. Forest Service; U.S. Bureau of Land Management, and Bonneville Power Administration. Local, city, and county planning groups, and representatives of Washington Water Power and Montana Power Company should be an integral part of this overall planning effort. The Montana university system has the potential to contribute expertise to this planning effort. The private and public organizations should work with the universities to develop this plan. The following strategies are recommended for recreation issues in the basin. 1. Conduct a comprehensive survey of recreation use. Conduct a comprehensive analysis of all active and passive recreational uses in the basin, especially those closely associated with the river and its tributaries. The analysis should include a study of aesthetics, a discussion of outcome domains (why recreationists visit 5-27 the Clark Fork, what they are seeking from their ^ experience, why they do not go to the mainstem, how the mainstem compares to their other favorite streams, etc.)/ ^nd a discussion of existing uses and facilities and future needs. Ideally, this survey would be coor- dinated with a similar survey on Lake Pend Oreille in Idaho. Develop and implement a basinwide recreation plan. a. Utilize the recreation survey data to plan for the long-term recreational needs of the basin. The plan should consider and provide for such activi- ties and facilities as fishing access areas, RV parks, camping, parks for the handicapped, nature trails, bicycle paths, canoe pull-outs, boat ramps, fishing, and other water-based recreation facili- ties. b. Evaluate and encourage opportunities for special community activities associated with the riverfront in communities along the Clark Fork. Local govern- ments, public interest groups, and recreation plan- ners should convene workshops and public information sessions to identify and encourage appropriate recreational and waterfront development programs. Program planning and site development will require major investments. A variety of funding sources should be considered, including special revenues from gasoline sales, fishing licenses, bed taxes, state land lease fees, and tax on recreational equipment, and grants-in-aid from interested parties or businesses that would benefit from such efforts. '' Water Management Issues Water Rights Effective management of water resources in the Clark Fork Basin in the coming years depends greatly on the resolution of a number of water rights issues. Chief among these is making a determination of the physical and legal availability of water in the basin. This determination cannot be made until the status of large hydropower companies' water rights is decided and an accurate adjudi- cation is completed. Other issues include the water rights of the Confederated Salish and Kootenai Tribes, new water use permits, and water allocation alternatives. The following actions are recommended: 5-28 1. Determine the status of large hydropower water rights. Determine the status of WWP's total water right (claim for 35,000 cfs and provisional permit for 15,000 cfs) at Noxon Rapids. If the Water Court decides that WWPs ' claimed rights are accurate, and if WWP chooses to exercise its right to object to new uses on the basis of adverse effects, then little or no water may be available to upstream users for appropriation in most years (without storage) . This information is essential for existing and prospective water users to assess the impacts of new water use permits on the availability of water. 2. Determine the physical and legal availability of water in the basin. Complete the water availability analysis. DNRC and other cooperators (WWP, BOR, MPC, MSU) are currently conducting a study to determine whether hydropower interests have been or would be unreasonably affected by the granting of additional provisional water use permits. Once this water availability analysis is complete, it may be possible to reach a mutually acceptable decision regarding the physical and legal availability of water in the basin. 3. Complete an accurate adjudication in the Clark Fork Basin. The adjudication will establish the owner and amount of the water right, the priority date, the point of diversion, and the place of use. This is important because present information suggests irrigation claims made to the Water Court may be inflated. If adjudicated as claimed, this could have a significant effect on the legal availability and future use of surface water in the basin. 4. Encourage settlement of the reserved water right of the Confederated Salish and Kootenai Tribes. Determine the extent of the aboriginal fishing and cultural water rights claimed by the Confederated Salish and Kootenai Tribes in the Flathead Basin. The BIA has submitted claims, on behalf of the tribes, for water rights and instream flows on streams in the Flathead system. These issues could affect water availability for new uses in the Clark Fork Basin. 5-29 5. Seek legislation for a moratorium on issuing new water use permits. Seek legislation for a moratorium on new water use permits (for purposes other than rural, domestic, and small quantity industrial uses) until some of the issues surrounding the physical and legal availability of water in the Clark Fork Basin are resolved. The legislation should specify a certain size limit for these uses that would allow individuals to meet their needs. 6. Formulate water allocation alternatives. a. Develop a mechanism to deal with water needs should a decision be made to close the Clark Fork Basin to new water use permits. b. Examine alternatives or options such as interbasin exchanges, free market exchange, and reallocation of hydropower water rights. WWP has expressed a willingness to participate in the exploration of alternative allocations. Institutional barriers to these options should be addressed. 7. Improve public information on water rights. Develop a program to increase awareness of water rights procedures and issues in the Clark Fork Basin. Instream Flow Instream flow reservations are needed in the Clark Fork Basin to maintain fish and other living organisms, to protect water quality and domestic water supplies, and to enhance aesthetic qualities. Instream flows are a partial solution to the dewatering problem. However, because instream flow rights cannot affect senior diversionary water rights, they only preserve the status quo of stream depletion. They do not prevent dewatering, but can reduce future demands on the streams once the rights are acquired. Rewatering of streams that have severe flow problems can only be accomplished through new strategies, such as purchasing and leasing senior water rights, building new storage projects, and conserving water to free up additional water for instream uses. Some of these strategies will require new legislation, but if they can be implemented, they will help improve the stream fisheries as well as their recreational and aesthetic values. 5-30 The following actions are recoiimiended : 1. Encourage the city of Missoula to file an instream flow reservation in the Clark Fork. Encourage the city of Missoula to file an instream flow reservation application to protect flows in the Clark Fork that recharge the Missoula Aquifer. The Clark Fork provides approximately 46 percent of the annual recharge to the aquifer, which supplies drinking water for Missoula residents and water for two municipal systems, many small community systems, several large industrial users, and private well owners. It would therefore be in the best interest of the city to protect instream flows in the Clark Fork. 2. Encourage others to seek instream flow reservations in remaining portions of the basin. Seek instream flow reservations in the middle and lower Clark Fork and tributaries. Although instream flow reservation applications have been made by DFWP for the upper Clark Fork and its tributaries, there have been no such reservation applications for the remaining portions of the basin. It is important to the future of the Clark Fork that agencies such as DFWP, USES, BLM, DHES, and others file reservation applications. 3. Seek legislation to allow purchase of water rights. a. Seek legislation to allow agencies to purchase water rights for instream uses in areas where instream flow reservations cannot be met because of current flow regimes. In this case, there has to be a willing buyer and a willing seller, and the transfer must satisfy the criteria under Montana law. The transfer cannot adversely affect any existing water users. b. Seek legislation to allow the state to buy or lease senior water rights to use instream and to transfer water conserved through increased efficiency to instream use with compensation to the owner. This is the only way water can be obtained from senior right holders. This would be extremely important for instream flow protection in dewatered streams that are over-appropriated. 5-31 4. Evaluate the feasibility of new water storage projects in the upper basin. A detailed study of the upper basin hydrology should be conducted to identify potential water storage sites. Control and storage of high spring flows would be a useful means to maintain instream flows and alleviate water shortages. As the cost of water increases with increased demand, water storage becomes more feasible. Land and Water Use Inventory Management decisions regarding water resources in the Clark Fork Basin are hampered by, among other things, the lack of an up-to-date land use data base and the lack of coordination in ground water and surface water permitting processes. Recommendations to address these issues are: Update land use data in the Clark Fork Basin. Facilitate future water management decisions by maintaining an accurate, up-to-date land use data base in the Clark Fork Basin. For example, estimates of irrigated acres in the basin (given in this report) range from 230,000 to 400,000. No one knows how much land is actually under irrigation. Ideally, the data base would be updated yearly in a consistent manner and the data would be made widely available. This could be coupled with an analysis of potential future water uses and needs, so that the trade-offs and implications of current actions are more fully understood. Initiate conjunctive management of surface and ground water. a. The DNRC should identify those areas in the Clark Fork Basin where surface water-ground water relationships need to be defined. The DNRC should also identify the analytical tools needed to evaluate ground water use impacts on surface flow. Areas where future development may occur should be given a high priority. The priority site list should be used to establish funding directives for research in the basin. 5-32 b. The DNRC should consider modifying its administra- tive structure to allow for a unified surface and ground water permitting system. Such a modifi- cation is needed to provide for integrated, conjunctive management of ground and surface waters. The Clark Fork Basin is an area that would benefit from this change. Natural Resource Damages Claim In December 1980 President Carter signed into law the Superfund legislation to provide for liability compensation, cleanup, and emergency response for hazardous substances released into the environment and for the cleanup of inactive waste disposal sites. Liability under Section 107 of the Act not only provided for cleanup of hazardous waste sites, but extended to damages for injury to and destruction of natural resources, including the costs of assessing such damages. Section 107 provides that, after deduction of the State's costs, all such damages recovered from responsible parties are to be deposited into a trust fund for the restoration or replacement of lost resource value. The Montana Legislature, in adopting the Montana "Mini Superfund" law, also included a course of action under state law for assessing natural resource damage claims. In 1983 Montana officials recognized the magnitude and complexity of the Butte/Anaconda site and the fact that federal funding was not available to assist in assessing the damages. Because substantial natural resource losses have occurred and are continuing to occur, the state filed a claim against Anaconda Minerals Company/ARCO in December 198 3 in U.S. District Court. The claim addresses the entire Clark Fork watershed upstream from the Milltown Dam at Bonner. As required by the 1986 amendment to Superfund, Montana's Governor has now appointed certain state officials as trustees who have the obligation to assess and pursue natural resource damage claims. In 1987 the Montana Legislature appropriated funds from the Resource Indemnity Trust Fund to pursue the natural resources damage assessment for the Clark Fork sites and any other potential sites. Their action was taken with the expectation that the State's claims could begin to be coordinated with any ongoing Superfund investigations. 5-33 The following actions are recommended: The State of Montana and the Legislature should continue to support aggressive pursuit of the natural resource damages claim to assure appropriate compensation to the state from responsible parties. It is essential that the State fully utilize the opportunities provided by Superfund legislation both to eliminate the hazardous waste sites and recoup the value of lost or injured resources. Funds recovered under this authority will be placed in trust and used to restore the full resource potential of the Clark Fork Basin. Program Implementation and Continuity During the past four years, the Clark Fork Basin has been the focus of many agency activities. The Clark Fork Basin Project initiated by Governor Schwinden has worked to coordinate these activities and to formulate an action plan for the future. The completion of this report concludes the Clark Fork Basin Project, but it should also signal the beginning of a new effort to implement the project recommen- dations. It is essential to maintain the continuity of agency activities to assure progress in pollution abatement and water resource management. Three organizational structures were presented in the draft report (continue the Clark Fork Basin Project, create < Clark Fork Basin Commission, and create an interstate basin organization) . Strong support was voiced for the continua- tion of the Clark Fork Basin Project in the Governor's Office. The following program is recommended: 1. Continue the project in the Governor's Office as it has been structured in the past. A Clark Fork Basin Project coordinator, whose primary responsibility is the Clark Fork Project, would serve as chairman of the Interagency Task Force and the Citizen's Advisory Council. Objec- tives of the project would be to: a. Maintain a high level of communication with govern- ment agencies, public interest groups, and the general public. b. Work with legislators and agency administrators to ensure that actions recommended by this report and other investigations are implemented. c. Seek funding to implement the recommended programs. 5-34 d. Initiate and promote an interstate (Montana, Idaho, and Washington) basin program to encourage basin- wide coordination of water resource management issues of regional importance. e. Maintain coordination and cooperation of divergent regulatory authorities and other interested parties with responsibilities for resource protection and management . f. Continue to seek new approaches to government regulation that will reduce conflict and improve efficiency. g. Conduct special projects as recommended by the task force. 5-35 REFERENCES CITED Andrews, E.D. 1987. Longitudinal dispersion of trace metals in the Clark Fork River, Montana. Chemical quality of water and the hydrologic cycle, edited by R.C. Averett and D.M. McKnight. Chapter 11. Lewis Publishers, Inc. Chelsea, Michigan. ASARCO, Inc. 1987. Application for an operating permit for the Rock Creek Project. Submitted to the Department of State Lands. Helena, Montana. Averett, R.C. 1961. Macroinvertebrates of the Clark Fork River, Montana, a pollution study. Water Pollution Control Report 61-1. Montana State Board of Health and Montana Department of Fish and Game. Helena, Montana. 27 pp. Bahls, L.L. 1987. Periphyton community structure in the Clark Fork River and its tributaries. Summer 1987. Department of Health and Environmental Sciences-Water Quality Bureau. Helena, Montana. Berg, R.K. 1983. Middle Missouri River planning project. Job Progress Report, Federal Aid to Fish and Wildlife Rest. Project No. FW-3-R-11. Job 1-A. Department of Fish, Wildlife and Parks. Great Falls, Montana. 30 pp. 1984. Trout heaven. Montana Outdoors, Sept. /Oct. : 27-30. 1986a. Middle Clark Fork River fishery monitoring study: Evaluation of the effects of pulp and paper mill effluents on the fish population. Department of Fish, Wildlife and Parks. Missoula, Montana. 1986b. Lower Clark Fork Basin investigations. Job Progress Report, Federal Aid to Fish and Wildlife Rest. Project No. F-37-R-1. 39 pp. Department of Fish, Wildlife and Parks. Missoula, Montana. Beuerman, D. , and R. Gleason. 1978. Water quality of the Silver Bow Creek drainage; heavy metals and nutrients. Project 0662. Department of Health and Environmental Sciences-Water Quality Bureau. Helena, Montana. R-1 Bionomics. 1978. The effects of a treated copper mining, milling and smelting effluent on rainbow trout (Sajjno gairdneri) and the water flea (Daphnia magna) during partial chronic and chronic exposure. Report BW-78-2- 040. Prepared for the Anaconda Company. Butte, Montana. 30 pp. Bionomics. 1979. The effects of continuous exposure to a treated mining/smelting effluent on selected aquatic organisms. Report BW-79-8-531. Prepared for the Anaconda Company. Butte, Montana. 29 pp. Boettcher, A.J. 1982. Ground-water resources in the central part of the Flathead Indian Reservation, Northwestern Montana. Montana Bureau of Mines and Geology. Memoir 48. Butte, Montana. 28 pp. Boettcher, A.J., and A.W. Gosling. 1977. Water resources of the Clark Fork Basin upstream from St. Regis, Montana. U.S. Geological Survey Bulletin 104. Prepared by U.S. Geological Survey under cooperative agreement with Montana Bureau of Mines and Geology. Butte, Montana. Bohn, H.L., B.L. McNeal, and G.A. O'Connor. 1979. Soil chemistry. John Wiley and Sons, Inc. New York, New York. Bonneville Power Administration. 1985. Sales statistics for western Montana. Unpublished data. Bonneville Power Administration. Portland, Oregon. Botz, M.K. 1969. Hydrogeology of the upper Silver Bow Creek drainage area, Montana. Montana Bureau of Mines and Geology Bulletin 75. Butte, Montana. Botz, M.K., and G.L. Knudson. 1970. Hydrogeology of the Berkeley Pit area. Part I, the alluvium. Report to the Anaconda Minerals Company Mining Research Department. Butte , Montana . Botz, M.K., and R.W. Karp. 1979. Examination of factors influencing water quality in the upper Clark Fork River system. Prepared by Westech for the Anaconda Copper Company . Butte , Montana . Braico, R.D. 1973. Dissolved oxygen and temperature diurnal variations in the Clark Fork River between Deer Lodge and Superior, Montana, for the period August 2-3, 1973. Department of Health and Environmental Sciences-Water Quality Bureau. Helena, Montana. R-2 Brook, E.J., and J.N. Moore. Unpublished manuscript. Distribution and particle-size control of metals in bed sediment from the Clark Fork River, Montana, USA. University of Montana, Missoula. Brooks, R. 1988. Distribution and concentration of metals in sediments and water in the Clark Fork River flood- plain, Montana. M.S. Thesis. University of Montana, Missoula. 105 pp. Brosten, T.M. , and M.A. Jacobson. 1985. Historical water quality data for the Clark Fork (River) and the mouths of selected tributaries. Western Montana. U.S. Geologi- cal Survey Open-File Report 85-168. Helena, Montana. Brown, C.J.D. 1971. Fishes of Montana. Endowment and Research Foundation, Montana State University. Bozeman, Montana. 207 pp. Buck, F.E., H.L. Bille, C.F. Heidel, and A.D. McDermott. 1959. Water resources survey, Powell County, Montana. State Engineer's Office. Helena, Montana. Bureau of Reclamation and Bureau of Indian Affairs. 1985. Comprehensive review report. Flathead Indian Irriga- tion Project. Executive summary, Volume 1 of 3. Prepared at the direction of Secretary of the Interior. Bureau of Reclamation. 1987. Assessment '87: A new direction for the Bureau of Reclamation. 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Assessment of the Colorado Tailings Pond contribution to decreasing ground and surface water quality. Special student project. Montana Bureau of Mines and Geology, Montana College of Mineral Science and Technology. Butte, Montana. U.S. Army Corps of Engineers. 1978. Dam safety inspection, Warm Springs tailings dam and Yankee Doodle tailings dr.m projects. Prepared for the Department of Natural Resources and Conservation. Helena, Montana. U.S. Borax. 1988. Conceptual mine plan for the Montana Silver Venture. Submitted to the Department of State Lands. Helena, Montana. U.S. Department of Agriculture. 1977. Clark Fork of the Columbia River Basin cooperative study. Prepared in cooperation with the Department of Natural Resources and Conservation. Portland, Oregon. R-20 1985a. Plan of work for reclamation techniques for heavy metal contaminated agricultural lands in Deer Lodge, Powell and Silver Bow counties, Montana. Prepared by the Soil Conservation Service in cooperation with the Department of Natural Resources and Conserva- tion, Cooperative Extension Service and the Montana Bureau of Mines and Geology. U.S. Department of Agriculture. Forest Service, Northern Region. 1985b. Proposed Forest Plan, Bitterroot National Forest. Hamilton, Montana. 1985c. Forest Plan, Flathead National Forest. Kalispell, Montana. 1986a. Lolo National Forest Plan, Final Environ- mental Impact Statement. Missoula, Montana. 1986b. Forest Plan, Helena National Forest. Helena, Montana. 1987a. Forest Plan, Deer Lodge National Forest. Butte, Montana. 1987b. Kootenai National Forest Plan. Libby, Montana. U.S. Department of Commerce. 1982. 1982 U.S. Census of Agriculture. Volume 1, Geographic area series, Part 26, Montana state and county data. Bureau of the Census. U.S. Government Printing Office. Washington, D.C. U.S. Department of Interior. 1981. Water and power resources service project data. Water Resources Technical Publication. U.S. Government Printing Office. Denver, Colorado. U.S. Fish and Wildlife Service. 1966. Supplementary follow-up report for Cabinet Gorge, project F.P.C. No. 2058, Clark Fork River, Idaho-Montana. U.S. Department of Interior. Portland, Oregon. 17 pp. U.S. Geological Survey. 1982. National Handbook of Recommended Methods for Water Data Acquistion. Office of Water Data Coordination. U.S. Geological Survey, U.S. Department of the Interior. Revised 1982. Reston, Virginia. 1987. Water resources data, Montana. Water year 1986, Vol. 2, Columbia River Basin. Helena, Montana, 170 pp, R-21 U.S. Water Resources Council. 1979. Procedures for evaluation of national economic development (NED) benefits and costs in water resources planning. Final rule. Federal Register, 44(242). December 14, 1979. Washington D.C. 1983. Economic and environmental principles and guidelines for water and related land resources. March 10, 1983. Washington D.C. Vanek, A.F. 1972. The Sunday Missoulian. November 19, 1972. Missoula, Montana. Walker, J.T. 1977. Recreational use of the lower Blackfoot River. Missoula County Commissioners and the Department of Fish and Game. Missoula, Montana. 162 pp. WATER. 1987. Pend Oreille River Eurasian water milfoil control program 1987. Project completion report submitted to Pend Oreille County, Washington. Watson, V. J. 1985. A synthesis of water quality problems in the Clark Fork River Basin. In Proceedings of the Clark Fork River Symposium, edited by C.E. Carlson and L.L. Bahls. Montana Academy of Sciences, Montana College of Mineral Science and Technology. Butte, Montana . 1988a. Dissolved oxygen in the upper Clark Fork River, summer 1987. Unpublished manuscript. University of Montana. Missoula, Montana. 1988b. Dissolved oxygen in the middle Clark Fork River, summer 1987. Unpublished manuscript. University of Montana. Missoula, Montana. Wilson, W. , J. Sonderegger, C. Hawe, and T. Duaime. 1988. Reclamation techniques for heavy metal contaminated agricultural lands in Deer Lodge, Powell, and Silver Bo v counties. Laboratory and field data summary. Montana Bureau of Mines and Geology Open-File Report 200. Butte, Montana. Woessner, W.W., J.N. Moore, C. Johns, M.A. Popoff, L.C. Sartor, and M.L. Sullivan. 1984. Arsenic source and water supply remedial action study, Milltown, Montana. Final report to the Department of Health and Environ- mental Sciences-Solid and Hazardous Waste Bureau. Helena, Montana. R-22 Wright Water Engineers and the Department of Natural Resources and Conservation. 1982. A water protection strategy for Montana, Missouri River Basin. Helena, Montana . Zackheim, H. 1984. Small-scale hydro in Montana. Western Wildlands 10(2): 28-32. Montana Forest and Conservation Experiment Station. Missoula, Montana. R-23 APPENDIX PUBLIC COMMENTS AND RESPONSES INTRODUCTION This appendix contains public comments received on the Clark Fork Basin Project Draft Status Report and Action Plan. The 30-day public comment period ended October 28, 1988. Meetings were held in Butte (October 18), Missoula (October 19) , and Plains (October 20) , to hear public comments and concerns. Those meetings were tape recorded and the comments received are summarized (paraphrased) below. Responses are provided in bold where appropriate. Written comments are provided following those from the public meetings. COMMENTS FROM PUBLIC MEETINGS Butte The public meeting in Butte was held on the evening of October 18, 1988, at the War Bonnet Inn. Ole Ueland, Rancher • The recommendations of this report should be provided to the State Water Plan Advisory Council. Response: This report and its recommendations will be presented to the State Water Plan Advisory Council. • There is a real need for upstream, off stream storage. Storage is highly recommended as a result of the state water plan meetings. All agencies and groups must work together to meet multiple use needs - agriculture, fish, recreation, water guality, hydropower, improved rangeland and forestry management, etc. Response: A recommendation to evaluate water storage projects has been added on page 5-32, Instream Flow section. • The sale of irrigation water rights is not a good idea, although there may be some value in the exchange of water rights from nonagricultural areas, and perhaps upstream users. A-1 • The water rights of the downstream power companies may significantly affect upstream uses. It will be difficult to develop upstream and offstream storage if they have the water rights to all this water. • There is concern about ground water quality and irrigation wells and the ability to continue to use this source of water. • Low pH and high metals concentrations in Butte and Anaconda area soils resulting from past fallout from the smelters is a problem for farmers and ranchers in developing irrigation systems. • The covering up of some sites that is being done by EPA is putting cleaner water into the stream and the polluted soils are not draining into the river as much. • Some discussion of the benefits and costs of cleanup in the headwaters should be included if public support is to be obtained. • The idea of using municipal wastewater for irrigation is good if metals are not excessive. Communities like Deer Lodge and Drummond should be considering this sort of operation. • Data from the numerous studies should be given to the State Libraries, the State Water Plan, and the computerized data base. There is a need to build on studies. Jerry Gless, Citizen • The 30-day public comment period for this report is too short. Response: The public comment period could not be extended due to the publication deadline for this report. • The major problem in the drainage is that 100 years of rent on the environment just came due. There is a staggering volume of toxic material that is extremely complex. • The Clark Fork Basin Project in the Governor's Office has been useful and essential as a clearing house for all the agencies. However, the recommendations may not go very far without force of law. A-2 Response: Implementation of these recommendations will require very strong public support. Progress made by EPA has been disappointing. The complexity of the issues certainly warrants a great deal of study. However, there has not been much evidence of innovative technologies, as called for in the recent Clean Water Act Amendments. EPA has simply covered up the problems in Walkerville, which may or may not work. Once the feds leave, maintenance will be up to the state. This maintenance may be substantial in areas where reclamation and contouring does not work well. Three years have been spent on an emergency action in Walkerville, and the result has been to cover up the contaminated material. This will be followed by an RI/FS, It is doubtful that new remediation techniques would be attempted in these areas because so much money has already been spent on the emergency work. Local resources have not been used to the full extent possible (i.e., mining and engineering expertise at Montana Tech) . EPA does not always play by its own rules - e.g., they considered routing mine water to the Butte Metro Sewer, which would violate the "pass-through" rule. There are innovative methods for reclamation, such as use of zeolites, that should be explored. Bob Tribelhorn, SCS - Deer Lodge • New water storage projects to address instream flow needs should be considered. There are possible sites, but they would be expensive. Response: A recommendation to evaluate water storage projects has been added on page 5-32, Instream Flow section. • There is no timetable presented in the report for resolving the Butte Mine Flooding issues. Considering the effects the Butte Mine water would have on the rest of the system, maybe something could be done to help speed up some of the work that is necessary. Response: The Butte Mine Flooding is a high priority for both EPA and DHES, and both groups are working on solutions to this problem. A-3 Gene Vuckovich, Manager - City of Anaconda • The utilization of the delivery system from Storm Lake, Twin Lakes, and the storage in Silver Lake and possibly Georgetown Lake could be managed more effectively, as the delivery system is not being used to the maximum. The Anaconda Minerals Company used to store the water and use it throughout the year. The delivery system has not been used effectively during the past few years. The water has been discharged downstream in early spring and then it is gone. Renovation of the storage and delivery system should be considered. Response: We agree that this water system could be used more effectively to minimize water shortages and improve water quality. The renovation of the system should be explored as part of the recommendation to evaluate new water storage projects (page 5-32) . • Anaconda-Deer Lodge County is interested in using municipal wastewater for irrigation as a means of wastewater disposal. Proposals have been submitted to the state to use the water for irrigation in the valley. Tom Malloy, New Butte Mining Inc. • Silver Bow Creek now falls under the I stream classifi- cation. Discharge limits are based on the previous 12-month monitoring period. Because the Metro Storm Drain has not flowed for quite seme time, the criteria are essentially being based on flow from Blacktail Creek, which is good quality water. Discharge criteria for Silver Bow Creek proper are therefore extremely low, in fact so low that Butte drinking water does not meet these discharge limits, especially the arsenic standard. • The I classification standards will limit industrial and economic growth on Silver Bow Creek proper. • The report should include the I classification standards for comparison with current federal standards. Response: It was not possible to include a detailed discussion of the I classification standards in the main text of the report. However, a table that compares the various standards is provided on the following page (A- 4a). A-4 TABLZ A-1 TRAVCNA SHAFT CCNTAMINANr-SPBCIFIC VtHER QUALTTY BASED ARARS (micrograms/li ter ) (total recoverable metals) I Classification I CLasslficatia- . Gold Book , Aquatic- Effluent- Daily naxinun. Monthly Averagj^ SCWA Bunan Health Life WX'^ Guidelines Concentrations Concentrations ' Arsenic 5Cr Cadmium 10^ Copper lOOo'' Iron 300*' Lead sf Zinc 5000^ .0022 360j 190^^ 1.6^ 2^d 1000"= 142j 5.6^ 170^ 154^^ 1000^ 5C0' 100^ 300^ 150^ 600^ 1500^ 750^ 2.4^ 34.3 lbs/day 8.4^ 317*^ 3.5" 1.6^ 50^ 5.6^ 211" Not less than 6.0 or greater than 9.0 standard units Safe Drinking Water Act; 40 CFR Part 141, Subpart B Qean Water Act; 40 CFR Part Dl Clean Water Act; 40 CFR Part 440 I Classification; 150!^ of the larger of either the chronic Gold Bode value or 1/2 of the mininun monthly mean I Classification; larger of either the chronic Gold Book value or 1/2 of the mininun monthly mean Primary MCLs Secondary MCLs 1-hour acute; hardness = 155 mg/L 4-day chronic; hardness = 155 ng/L Daily maxijiun Monthly average 153X of the Gold Book criteria; 4 day chronic; hardness = 155 ing/1 1/2 minimLm monthly mean EPA Gold Bode criteria; 4 day chronic; hardness = 155 mg/L Based on EPA Gold Bode criteria (1000 pg/1 150!? of 1/2 minijiiiTi monthly mean , EPA Gold Book Hunan Health Criteria; LxlO excess cancer risk Source: Camp, Dresser and McKee 1988c. A-4a Bob Dent, ARCO • The report should include an executive summary. A summary would likely be beneficial for legislators and others who may otherwise just look at the recommendations. There would probably be meri •. in prioritizing the recommendations by assigning a number to each, or at the very least, the top ten recommendations should be listed. Response: An executive summary could not be prepared in time for publication of the final report. However, if possible, such a summary and a prioritization of recom- mendations will be prepared for distribution at a later date. Phil Tarangeau, Clark Fork Coalition • The report should spell out the end results that are hoped to be achieved in upper river reclamation efforts. The report should recognize the SARA 121 cleanup standards that require preference be given to treatments that significantly and permanently reduce toxicity, mobility, and volume of wastes. An integrated, multi-faceted approach is needed to achieve SARA 121 cleanup standards. Response: See responses on page A-46 and A-47 to the 1- Clark Fork Coalition's written comments regarding this issue. • Why are only four monitoring stations on the Clark Fork recommended for the long-term monitoring program? Response: See response on page A-45 to the Clark Fork Coalition's written comments regarding this issue. • The public comment period should be extended by seven days. Response: The public comment period could not be extended due to the publication deadline for this report. A-5 Missoula The public meeting in Missoula was held on the evening of October 19, 1988, at the Courthouse Annex. Unknown Citizen • Persons logging and mining on private land do not seem to have responsibility for impacts on water downstream. The legislators in Montana, Idaho, and Washington should be hearing from the Clark Fork Basin Project concerning the recommendations of the report and specific laws that should be passed to protect water quality. Existing laws are not adequate. The state should do more to protect water quality. Response: The recommendations of this report will be provided to Montana legislators and interested persons in each of the three states. Abe Horpestad, DHES-Water Quality Bureau • The report states that algal growth in the Clark Fork is excessive; by what standards? Some rational basis or standard is needed for judging whether it is excessive. Until there is some means of measuring or determining "excessive" algal growth, any talk of limiting nutrients is begging the question. Before alot of money is spent to try to limit nutrients, we need to know what we will get for those dollars. The concept of excessive algae is a societal judgement. It is in the eye of the beholder. What is excessive here is not excessive on the other side of the divide. A consensus of the people is needed to judge what is excessive. There are some DO violations in the river and the algae is a bother to some persons using the river. Response: There is a need for criteria or standards to determine when algae growths affect other beneficial uses. This is one purpose of the tri-state research program funded under the Clean Water Act, Section 525. Algae growths in the Clark Fork have caused dissolved oxygen depletions during the past few years. Clearly, this is an impact on beneficial uses, but we do not have a correlation between algae density and oxygen depletion. A-6 • Rooted plants in the Pend Oreille River obtain nutrients from sediments rather than from the water column. The growth of these plants is being blamed on nutrient inputs to the river here. Response: The discussion on pages 5-13 and 5-14 describes how excessive aquatic macrophyte growths and algae have similar detrimental effects on water quality - Additional text on aquatic macrophytes has been added on page 3-91. • Lake Pend Oreille is similar to Flathead Lake in that nutrient problems are generally due to local inputs such as near-shore developments, rather than lakewide water quality. • The recommendation regarding the Phosphoria Formation calls for additional ground water sampling. Floods and runoff and the input of particulate matter from the Phosphoria Formation are probably as important, or more important, than ground water. Response: The recommendation addresses both ground and surface water (see pages 5-15 and 5-16) . • Data suggest that sporadic (short-duration, high metals concentrations) events control fisheries in the upper Clark Fork. The data gathered under Super fund investigations will not define the applicable cleanup levels. Sampling will have to be essentially on a daily basis to measure the magnitude and frequency of those kinds of events. That has not occurred and there are no plans for it to occur. Response: See recommendation #3, page 5-19. • The ARARs will say that instream values should not exceed a certain value that was based on a series of monthly or twice-monthly sampling. Even if the standards are achieved (and there are no numeric standards for the Clark Fork after the last revision of the water quality standards) , it may not mean anything to the fish, they may be dead anyway. • There is not necessarily a 1:1 correspondence between high flow events and high metals values. Some of the high values are due to sudden thaws or freezes, etc. Response: See recommendation #3, page 5-19. A-7 Peter Nielsen, Clark Fork Coalition • We don't know what level of algae growth is acceptable in the Clark Fork, but we do know that what is out there is excessive. There are DO violations, and algal growth is obnoxious. The growth of algae must not impair beneficial uses. • There has been strong support in the community in the last few years for efforts to limit nutrients in the Clark Fork (i.e., the pulp mill, WWTP, phosphate ban). There is a widespread belief that the Clark Fork is "grungy" . • There is no detail in the report regarding rooted plants (Eurasian milfoil) in the Fend Oreille River. The report should identify the plant, discuss the rapid rate of growth and spread, and discuss the perceived threat that it will invade the Clark Fork system. Response: The text has been modified on page 3-91 and on pages 5-13 and 5-14. • The issue of nondegradation standards should be explained more thoroughly in the report. There is a difference of opinion as to what constitutes compliance with nondegradation rules. Response: The Water Quality Bureau is responsible for interpreting and enforcing nondegradation rules on a case- by-case basis subject to concurrence by the Board of Health. It is not the purpose of this report to interpret the rules. • Nutrients should be regarded as deleterious substances as defined under the rules. Nutrient loading should be limited to the amount actually discharged in 1982 (when the rules were adopted) , rather than the design capacity. If the WQB had allowed increased loading up to the design capacity of the Missoula WWTP, it would have been almost a doubling over 1982 actual discharge. Nutrient loading to the Clark Fork and Lake Pend Oreille cannot be limited if certain sources are allowed to double. • The action plan should recommend limiting total nutrient loading from all sources. It should recognize that some control of nonpoint sources and some additional control of MPDES permits may also be necessary. Response: The recommendation has been modified (page 5-16) . A-8 The recommendations regarding nutrient loading are too short, too brief, and do not go far enough. The action plan should be far more specific in detailing the avail- able range of alternatives for controlling and/or limiting nutrient loading to the river. The plan should spell out specific alternatives that are possible now, such as detergent regulations, land use planning, septic tank rules, wastewater treatment technologies, land use practices, etc. Response: Nutrients and eutrophication have been identified as the highest-priority issue in the lower Clark Fork Basin. Funding has been actively sought through the Clean Water Act-Section 525 for better information on this topic. As you have indicated in your written comments, "the purpose of these studies is to tell us what to do to lessen the problem." It is necessary to complete the studies before recommending control strategies. See also the response on page A-45 to the Clark Fork Coalition's written comments regarding this issue . The plan recommends more studies to document DO and temperature phenomena in the river. There is already evidence of frequent violations of state DO standards, which is further justification for holding the line on nutrient loading. In light of these violations, it is a serious omission that the report does not address a plan to reduce these violations. Solutions should be identified. Response: Work group members suggested additional dissolved oxygen and temperature data would be helpful in assessing water quality problems. The diurnal decline of dissolved oxygen values in some parts of the river is attributed to algae respiration. Low streamflows during the past few years have exacerbated this problem. All efforts to reduce algae growths should help to reduce the dissolved oxygen problem. See response to the previous conunent. The perception in the state water plan meetings was that water rights would be "taken". The report should clarify that the suggested ways of dealing with water rights would be voluntary. There would have to be a willing seller and a willing buyer. Response: The final report has been modified to reflect this policy. See page 4-22 and the recommendations on page 5-31. A-9 The reclamation alternatives presented are institutional controls (capping, containing, stabilizing, fencing etc.) only. The report should acknowledge that Super fund calls for permanent solutions. Work should be done on assessing technologies for long-term, permanent remedies that will address the mobility, toxicity, and volume of wastes. It is a little dangerous to have a report from the Governor's Office that could potentially drive Superfund by endorsing particular alternatives at the exclusion of others, particularly if these alternatives are not sufficient. We do not want to foreclose any options. Response: The report does not endorse or recommend specific remedial technologies for Superfund sites. Please see the responses on pages A-46 and A-47 to the Clark Fork Coalition's written comments regarding this issue . If you are talking about exercising beaver control you better stay out of Rattlesnake Creek. Response: The report recommends beaver control only in locations where beaver dams are found to affect critical trout spawning habitat. Monitoring data are instrumental in helping to resolve conflict and in making better decisions. It is very important to sustain monitoring in the basin. Many of the industries in the basin are very supportive of this. Four stations for long-term monitoring are not adequate to give us the type of information we need. An additional group or an extension of the interagency monitoring group consisting of industries, agencies, and public interest groups should be formed to discuss specifically the funding of monitoring in the basin. A public-private partnership should be established to fund this program so that it is sustainable. Response: The report has emphasized the importance of water quality monitoring. A cooperative monitoring program where decisions and funding are shared by industry, government, and citizens has been suggested. We do not believe that another group in addition to the monitoring cooperative is needed. The recommendation has been modified on pages 5-19 to 5-21 to clarify the intent of the program. The selection of four monitoring stations is presented as an example of the bare minimum monitoring effort needed to measure long-term trends in water quality. A-10 The report should stress the gains that are possible ■* through increased water use efficiency and conservation. Studies are needed to determine how much could be conserved if conservation principles were applied. This might be the best option of all for instream flows. Response: Water conservation is addressed in recommen- dation #3b, page 5-31, Instream Flow section. We agree that water conservation should be practiced, and that more more information is needed to encourage conservation by all water users. Jim Toole, Clark Fork Coalition • The model of Lake Pend Oreille shows that the throughputs of nutrients are largely from the Clark Fork. In Flathead Lake, there is much lower input, so the near-shore contribution is proportionally much greater. Response: It is our understanding that very little is known about the trophic status of Lake Pend Oreille. While your statement may be true, the present and pro- posed studies of nutrients in the Clark Fork and Lake Pend Oreille under Section 525 of the Clean Water Act are intended to provide the necessary hard data. • The aesthetic problems are perceived differently in the Clark Fork than in other rivers because of low numbers of trout. A similar algae growth may occur in the Madison River, but the fishing has never been better there. • Utah and Colorado have just recently passed water use laws. An analysis of these laws should be done, as there may be some valuable information to be gained from that legislation. • Fish kills in the upper river have been written off super- ficially as due to copper toxicity. Data have been produced by UM geologists on the flux in oxidation and reduction that takes place in the Milltown sediments. In the Milltown Reservoir, the metals react in response to fluctuating redox conditions. The same process is taking place at much higher levels in Silver Bow sediments. During runoff, reduced forms of soluble metals produce an acid-reduced state that is extremely toxic. A-13 If you conducted an analysis, it would probably show high levels of soluble metals that are precipitated under normal oxidation conditions. This occurs at every sedimentation site in the river. The metal levels in sediments in the lower reservoirs are at least ten-fold higher than background, and are over 100 times higher at Milltown. This occurs at all streamside riparian sites. Along with the Cladophora that died the previous year, an organic "fuel" is produced. Following a heavy runoff this is mixed and trapped in the sediments. The oxidation of this organic matter reduces the metals and produces a high level of these soluble metals at the bottom. Any fish trying to spawn in these areas has got to meet this increased toxic level. This is a model, and obviously speculation because we have not done a damn thing about measuring it. This is where we ought to start. If we continue to plan to do streamside reclamation studies without a picture of the fluvial mechanics in that floodplain, we are likely doomed to failure. An extensive and intensive study of these tailings should be a number one priority. Response: Recommendations for intensive study of the streamside tailings and fluvial mechanics are found on pages 5-6 to 5-8. Dennis Workman, DFWP - Hissoula • The state can buy all the water it wants for instream use (such as from Painted Rocks) , but without a right, it has no control over the water. Once delivered, DFWP cannot protect it to the mouth, and the water does not neces- sarily reach the intended stretch of river. • The measures recommended in the report to enhance fisheries are good. • When the Clark Fork is compared with other rivers, there are alot of similarities - most have been adversely affected by channel straightening, dewatering, algae, high sedimentation during runoff, etc. People on the west side are accustomed to clean rivers - they relate to clear water, low algal growth, etc. • If we are serious about improving the Clark Fork fishery, we need to take care of the toxic metals problems - this is where the most progress can probably be realized. A-14 Tailings in the riparian zones are continually resuspended into the river. We should begin by eliminating the sources near Butte, and then carry on down through the Deer Lodge Valley. Growth of trout in Clark Fork compares favorably with other rivers - there is no reason other than toxic metals for the poor fish populations (numbers of tributaries are similar, etc.) Our fishery studies do not always show the subtle effects of some metals (e.g., cadmium). The next most important recommendation for fisheries in the Clark Fork (after heavy metals) is renovation of the Warm Springs Ponds. If we had an efficient, operating settling pond system at Warm Springs that would effectively stop the downstream migration of toxics from the Ramsay area and the Colorado Tailings, wouldn't it be essentially a demonstration that toxics are having an effect on the river if we started to see improvements below the pH shacks? I think it would. Mike McLane, DNRC - Missoula • There are already some provisions in Montana law to buy, sell, and exchange water rights. It is not clear if an exchange can occur from a consumptive to a nonconsumptive use. • With an instream flow, when moving from a consumptive to a ^ nonconsumptive right, the point of diversion and the ?iftrf protected reach would have to be specified. Phil Tarangeau, Clark Fork Coalition • Super fund is going to eliminate acutely toxic conditions. At least that is the procedure that has been identified (institutionalized) to deal with those problems. • The procedure is supposed to be the identification of the lfc?»y degree of cleanup required, then the evaluation of the •jf-,j£^xnost cost-effective means of achieving that degree of cleanup. In the recent past, EPA has reversed that process. It has found a cheap means of preventing the y I migration of a hazard, and then identified that as the f; I most cost-effective means of achieving the remedy. A-15 It is incumbent on the agencies, such as DFWP, to express concern that the degree of cleanup be defined first, then the mechanism to achieve that degree of cleanup be determined. Removal or temporary capping should not be eliminated simply because of the mass of tailings that confront us in the upper basin. Permanent methods and treatments that significantly reduce the toxicity, mobility, and volume of wastes should be considered. Recognizing that you did not want to get into this Super fund morass, which no one understands (not even the people that manage the morass) , we have to face it and recognize that removal and either off-site or on-site treatment will have to be considered as well as reclamation. Superfund needs to follow section 121 cleanup standards. Response: The EPA and DHES are following Superfund procedures . Phil Hertzog, DHES-Solid and Hazardous Waste Bureau • The MBMG has recently put in some automatic samplers in the upper river that may help define short-duration, high- intensity events. So far there have not been any significant runoff events this year to trigger them. Response: A discussion of this recent monitoring effort: was added to the text on pages 3-63 and 3-64. • The report probably needs to emphasize more that improving water quality in the Clark Fork Basin improves water for irrigated agriculture. No one has really assessed the impacts of the current quality of water on productivity in irrigated fields or damages from past water quality. It is important not to leave the farmer out. Response: Irrigation-affected lands are discussed on pages 3-40 to 3-42. Representative of Irrigation District • The people here seem to want all the water to go down the river and out of the state. There is no better way to get water in the ground than through irrigation. I agree with the Governor-people before fish. Fish can always be replanted, that is why there are hatcheries. A-16 All the water rights should be reserved for the people. I'm for water and irrigation in this state to the full extent. Every drop we can get is needed. If we don't use it, we'll lose it. Idaho will sell the water to California or Washington. If it weren't for irrigation, the state would be barren. We need water for the people, for trees, grass, alfalfa fields, cattle, etc. Let's keep this state green! Water from irrigation helps to promote rainfall - water begets water. Every gallon possible should be for Montana people. Plains The public meeting in Plains was held on the evening of October 20, 1988, at the Plains High School. Doug Farrell, Cabinet Resource Group ,%' A person living on Noxon Rapids Reservoir reported that algae growth this year was much heavier than it has ever been. Is this a condition of warm weather or slower streamflows, and are there trends along these lines? Response: The Water Quality Bureau has reported an increase in algae statewide due to drought conditions. Some of the worst algae blooms have been recorded in reservoirs. Factors affecting the algae growth include reduced water volumes, increased nutrients, and lack of scouring flows. •' What is the timeline for being able to set a total nutrient goal for the Clark Fork? The Cabinet Resource Group strongly support efforts on nutrient loading. Response: The tri-state studies are expected to provide useful information and goals within a three-year period; approximately 1991. ■i -t A-17 • In the general area of Trout Creek, the good fishing is mostly on the tributaries. The Kootenai Forest Plan, which projects sensitive road building and timber harvesting, significant decreases in fisheries due to sedimentation, etc., is of concern. This is the wrong direction for the state to be moving. The state should get more involved in preventing this kind of loss. The Forest Service has limited enforcement and monitoring capability. Response: The legislature's study of forest practices conducted by the Environmental Quality Council is a move toward improving this situation. • Montana is the only state in our general region that does not have legislation covering BMPs for forestry use. This is a gap that Montana needs to address. Response: See response to previous comment. • The Cabinet Resource Group supports the recommendations for systematic surveys of better tributary spawning grounds and a bottom contour map of Noxon Rapids Reservoirs. Both would be helpful. • How will monitoring be coordinated between the mining companies and the monitoring agencies? Monitoring in tributaries with proposed mining is a good idea. There have been some real problems with water quality monitoring at the Troy Mine, which are getting better. Baseline data was done using methods that are very different from the monitoring program, so pre and post mine conditions cannot be compared. This is an illogical situation. Response: Monitoring problems that occurred at the Troy Mine were corrected. This is not typical of current monitoring operations. • The Cabinet Resource Group has asked that ASARCO's baseline monitoring program be designed right off the bat so that a direct comparison can be made with monitoring data. The state should look at the baseline data and decide what constitutes degradation of state water. Response: A recommendation for baseline monitoring by the Water Quality Bureau in tributaries that may be affected by mining is provided on page 5-19. A-18 Reading this report brought home the scope of the problem that has been created by mining activity in the upper river. It certainly behooves us to take every precaution to avoid duplicating the mistakes of the past in the mining ventures planned for the lower river. It should be realized that we are dealing with a technology that has the potential for very costly problems. Although I have some concern about a report that is sometimes pretty general (especially NPS and nutrient loading, where recommended implementations sounded pretty vague and general) , my response to the Clark Fork Basin Project report and the effort in general is that, by in large, it smacks of good government and good management. I would like to express my admiration for the initiative and follow through it took to try to put together the mass of somewhat unrelated data. It was a worthwhile effort and a success, and it should be continued. Judy Hutchins, Clark Fork Coalition • Nutrient loading in the river should definitely be limited. However, control of point sources is only the first step. There is also a need to continue serious work on controlling nonpoint sources of pollution, Response: The recommendation has been modified (page 5-16) . ■fe^ There is not much discussion in the report about consistent DO violations that have been occurring in the river in the past few years. A comprehensive policy to address these repeated DO violations is needed. Response: See responses on pages A-45 and A-46 to the Clark Fork Coalition's written comments regarding this issue. Is the recommendation for exercising beaver control serious? Why not address killing off all the great blue herons-they affect the fish. Why not address the cows stomping through the streams... The ultimate impediments to spawning are the Cabinet Gorge and Noxon Rapids reservoirs. Response: Fisheries biologists assisting in the preparation of this report have indicated the importance of tributary streams to sustain fish populations. A-19 • The first recommendation for fisheries should address chronic as well as acute toxicity. Response: The recommendation has been modified to include chronic toxicity. • The long-term monitoring program of four stations is not sufficient and the recommendation should be clarified. Response: The recommendation has been modified to clarify the intent of the monitoring program. See also the response on page A-45 to the Clark Fork Coalition's written comments regarding this issue. • The Clark Fork Basin Project should be continued in the Governor's Office and an interstate basin organization should be created to deal with the tri-state region. Local government units and concerned people should be involved in the interstate organization so that it is not ■ just another level of bureaucracy. Response: See response on page A-45 to the Clark Fork Coalition's written comments regarding this issue. • There may not be alot of public comment on the report because the comment period was so short. Fred Roach, Citizen • Are the recommendations a summary of the study? How many years did it take to put this project together, and how much money was spent on it? "This is all you could come up with? The section on nonpoint source pollution looks like a ten-minute exercise at a word processor. It doesn't look like you have much here." Response: Comment noted. • Specific enforcement of some of the existing regulations is needed, i.e., the 310 law and logging. There has been slash piling in the creek, damming of the creek, sedimentation, dragging of logs through the creek, etc. Complaints have been made to the local ASCS, and DHES-WQB, but no one came to investigate. • More people are needed to enforce laws. Citizens should be encouraged to report violations, then action should be taken on them. A-20 Champion was allowed to fill out the necessary permits months after they had done the logging. The citizenry should be involved to help in monitoring efforts on the Clark Fork. Monitoring of tributaries, logging practices, etc., is needed. Jean Morrison, Citizen • Do discharge permits have stipulations that take low streamflows into account? Are the permits reviewed and made more stringent? A recommendation is needed to change that bottom 7-day, 10-year low flow. It should be lifted, because the river has been lower the last 3-4 years. The basis should be adjusted. Response: Adjustments in the 10-year low-flow values are made as new data are available. It is a long-term, ongoing process. • Didn't Flathead County instigate a regulation whereby people were not to use detergents in water that would go into Flathead? Response: Flathead and Lake counties have implemented a ban on the sale of phosphate-based detergents. • Local and county government should participate in monitoring, e.g., the local sanitarian. Local citizens should be involved, particularly those who have similar job duties. There is a need to hire somebody who could report it when people dump certain kinds of things into the river that aren't to go to the river. Shouldn't there be a tax assessment that could be used to support such an effort? Matching local/state funds might be one way to obtain support. Response: Local and county government should have a role in water quality monitoring. A cooperative monitoring program to aid in organizing this effort has been recommended (pages 5-19 to 5-21) . • The burial of old asphalt and highway debris associated with the highway project in Plains is a concern. It is to be buried on the Pack River property with a well and stream nearby, and none of it is very far from the river. Is it necessary to obtain a permit from the EPA for such disposal? Years ago there were alot of problems with illegal dumping of material in the river from the industry that was there. A-21 Response: A permit is generally required to dispose of solid and/or hazardous wastes. More information can be obtained from the DHES-Solid and Hazardous Waste Bureau in Helena. Tim Williamson, Clark Fork Coalition • For point sources, nondegradation guidelines should be followed specifically. DSL, WQB, and other state agencies' recognition of the nondegradation law is in its infancy. It should remain a strong guideline for the pemmitting processes. The law should be interpreted to be the actual 1982 output, rather than some theoretical value. • For the first time in Montana, the WQB and DFWP have data on the river that clearly show that when water quality is high, fish populations are higher. • The DSL has no intention of coordinating baseline data with monitoring for the Rock Creek Mine. The Clark Fork Coalition does not think this is acceptable, and is certainly illogical at best. What is the purpose of baseline data if comparisons cannot be made? Response: The recommendation on page 5-19 for the WQB to conduct baseline monitoring in tributaries is intended to provide the basis for these comparisons. • The Clark Fork River Watchers did some DO monitoring in the river after receiving informal certification through a short training session with WQB. The Coalition would like to see a group of people certified through training workshops and supplied with equipment. Any support from the state in such an effort would be appreciated. Citizen monitoring does have a place and is working in other parts of the country. Such a group could respond to crises or report activities on the river, and the costs of monitor- ing could be reduced. It may be the only way to go for long-term monitoring. Response: Citizen monitoring can be very useful provided their efforts are closely coordinated with agency monitoring programs. The role of citizens should be considered by the monitoring cooperative (see recommendations on pages 5-19 to 5-21) . A-22 Where possible, in the upper river, actual cleanup should occur rather than just stabilization or protection of the river from these toxic hazardous wastes. SARA does give strong preference to remedies that reduce the toxicity, mobility, and volume of hazardous wastes at these cleanup sites. It is a matter of money and costly technology. When and if the monies and technology are available, it should occur at least on a small site basis. Perhaps there is an intensive contamination site that could be used as a model for some type of removal or reduction of those toxic wastes. Response: See responses on pages A-46 and A-47 to the Clark Fork Coalition's written comments regarding this issue . Use of herbicides and insecticides are not mentioned in the report. Roadside spraying along the highway, which parallels the entire length of the river, is a concern. The value of this spraying is doubtful- it is not an effective way of dealing with the knapweed problem and the potential hazards of using the spray are not worth it. Response: Herbicides and insecticides were not reported to be a problem in the Clark Fork Basin, although some problems have occurred in the past. We agree that pesticide use is a potential hazard to water quality. Norm Resler, Citizen •' • It appears that the Clark Fork from Missoula on down seems to take a back burner in the state. The Clark Fork is not at its potential - the state should make more of an effort to improve the fisheries in the lower river. The focus should be on the lower Clark Fork as a potential blue ribbon stream to get more state involvement. • Most of the improvements in fisheries have been the result of private industries, particularly WWP. The state DFWP has said it won't plant fisheries in what is considered a river. Yet the WWP can do it in two reservoirs. Their efforts in the reservoirs have been quite successful - the bass fisheries are doing well, etc. Some species should be suitable. A-23 There is no place for industry to put toxic wastes in Montana. The cost to transport them out of the state is so prohibitive that private industries are forced to flush it down the sewer. A toxic waste dump site should be established in Montana so that the waste can be concentrated, rather than distributed widely. Bill Holland, Mayor of Plains • How do you account for all the scum and foam that is seen in the river this side of Stone Container? You see it every day when you are following along the river. It must be contamination of the river. Response: Foam occurs in the river above and below the Stone Container mill at Frenchtown. Some increase in foam does occur immediately below the mill. Foam is believed to result from natural organic substances derived from plants. Decomposing algae is believed to contribute to foam and scum in the river. Rick Duncan, Clark Fork River Watchers • The report and recommendations are appreciated. Continued long-range monitoring on the Clark Fork is a concern. What will happen to these programs with a change of administration in Helena and the impending financial difficulty our state is in? Response: Continued progress in the Clark Fork Basin will require strong public support. WRITTEN COMMENTS The written comments received during the comment period are provided below. Each letter received is presented in its' entirety, and is followed by a separate page with responses to numbered items in the letter. 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