20061222DEQ comments.pdf

. STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
2006 DEC 22 MI 8: I
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I' ' J" (', '" J ~'I ,'\2ffI'TIL/TIES CO;'vjp~1ISSI~~M.~s E. RISCH, GOVERNOR
IONI HARDESTY, DIRECTOR
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1118 F STREET' LEWISTON, 10 83501 . [phone]
December 19 2006
Karl Morell
Ball Janik LLP
1455 F Street, NW, Suite 225
Washington, D.C. 20005
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RE:Coimnents Docket No.AB.;.570(Sub-No;2~. Palouse River & Coulee
City Railroad, Inc.~Abandonment Exemption-InLatah County, Idaho
Dear Mr. Morell:
The Lewiston Regional Office of the Department of Environmental Quality has received
your request on behalf of Palo use River & Coulee City Railroad Great Northwest
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Railroad, Inc. for assistance in identifying possible water quality issues involved with the
above mentioned project.
We appreciate the opportunity to review this project, and believe the railroad
abandonment project provides the opportunity to coordinate our efforts to identify and
produce an inventory of potential environmental quality problem areas that may arise
from the abandonment of this section of railroad line. This letter does not constitute a
Clean Water Act Section 401 certification and additional or different considerations and
conditions may be specified in connection with the Department's review of specific
activities. Currently, we have identified the following water quality and environmentalproject requirements and concerns.
1. Water quality protection will need to be carefully addressed since the proposed
abandonment crosses and is adjacent to Paradise Creek. Paradise Creek is
identified in the Idaho State Water Quality Standards as Waterbody ill
170601O8CLO05 , urban boundary to IdahofWashington border. The
waterbody is currently listed in Section 4 of the Idaho 2002 Integrated Report as
impaired due to bacteria, siltation, thermal modification, flow alteration, habitatalteration, ammonia and nutrients, and is included in the Paradise Creek TMDL
and the Idaho State Water Quality Management Plan. The Par;:tdise Creek Total
Maximum Daily Load lists allowable pollutant load allocations. Your project will
need to comply with the allowable pollutant load allocations listed in the Total
Maximum Daily Load.
2. The location of the abandonment is an industrial site and adjacent to a site
mitigated for the presence of hazardous materials where known hazardous
materials were stored and spills occurred. A hazardous material remediation "
plan, which includes DEQ notification, should be put in place to address
haZardous material remediation if these substances are discovered during
abandonment.
3. A Clean Water Act Section 402 Storm Water National Pollution Discharge
Elimination Permit and an accompanying Storm Water Pollution Prevention
Plan should be provided for the site during abandonment activities.
We suggest information be presented in a report that fully characterizes the site and the
concerns we have raised and the hazard risk to water and the environment resulting
from any activities associated with the railroad line abandonment activity. The report
should be submitted to the Department to determine if additional or different
considerations and conditions may be specified in connection with the Department's
review of specific activities.
Thank you for the opportunity to provide further comment on this project If you would
like to. discuss these comments or have any questions please contact the Lewiston
Regional Office at [phone].
Sincerely,
J- H ~.-
Hudson Mann
Acting Regional Administrator
Cc:ToniHardesty, Director, Department of Environmental Quality
Curt Fransen, Idaho Attorney Geperal Office
Don Howell IPDC/Boise