20141010DEQ Comment.pdf

I
—STATE OF IDAHO
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—DEPARTMENT OF
ENVIRONMENTAL QUALITY 7MR OCT -9 p 3:09
1445 North Orchard •Boise,Idaho 83706.[phone] UT !LIF S COMMl3SltJi CL.Butch’Otter,Governor
www.deq.idahogov Curt Fransen,Director
October 7,2014
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Jean Jewell
Idaho Public Utilities Commission
472 W.Washington
Boise,ID $3702
Re:Brian Subdivision Water Users Association Nitrate Challenges
Dear Ms.Jewell:
It is my understanding that the Brian Subdivision Water Users Association (Brian Water)is currently
working through the Public Utilities Commission (PUC)as part oftheir mitigation strategy in dealing
with elevated nitrate levels in their drinking water.I would like to take this opportunity to explain
the background and history behind this system and their path towards compliance.
Nitrate is considered an acute contaminant in drinking water because it can have serious health
impacts in a relatively short amount of time following consumption.Nitrate levels above 10 mg/L
are particularly serious for infants less than six months old,causing methemoglobinemia or blue baby
syndrome.Because of the seriousness of elevated nitrate levels,Brian Water has been required to
continue to provide public notification to its customers on a routine basis since 2011,instructing
customers not to drink the water or use it to make formula.
The system was,as you probably know,owned by Tony Bowar.He first experienced the nitrate
issues in 2010 until they continued to climb and eventually exceeded the maximum contaminant
level (MCL)of 10 mg/L.The system was disapproved in February of 201 1 and Tony entered into a
consent order shortly after in April of 2011.The system sat with Tony,and made very little progress,
until it was transferred to the homeowners in 2013.The homeowners inherited the nitrate problems
as well as the consent order and the requirement to mitigate the problem,and have been working
diligently to resolve it.
As part of the process involved in solving this problem,the representatives of Brian Water have
explored numerous options,but have found difficulty getting any of them to work for their specific
scenario.They have explored Point-of-Use (POU)treatment,looking into purchasing individual in-
home filters for each house.Unfortunately,because ofthe acute risk associated with nitrate,POU
treatment is not allowed by DEQ.Centralized treatment at the wellhead has also been explored,but
the system has found that there is nowhere to discharge the waste stream produced by centralized
treatment in a way that does not simply exacerbate the problem further.Drilling a brand new well
was also difficult due to the lack of siting for a well lot that meets setback requirements,as well as
the requirement to have a redundant source of supply,which would necessitate drilling two new
wells that do not have nitrate issues.
Printed on Recycled Paver
10/08/20 14
Jean Jewel
Page 2
As you can see,this system has worked on this issue for quite some time,and has explored many
different options,which has led them to the interconnection with United Water and working with the
PUC.DEQ fully supports Brian Water in their pursuit of an interconnection with United Water as it
will provide their customers with a very reliable source of drinking water that meets all health based
standards.If you have any questions regarding nitrate or Brian Water,feel free to contact me at
[phone] or via e-mail at [e-mail].
Sincerely,
Brandon Lowder
Regional Drinking Water Supervisor
ec:TRIM 2014ACA5889