20041012DEQ Comments.pdf

STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
HECEIVED
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2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. [phone] UTiLiTfES CnMf~~iSStGtl Dirk Kempthome, Governor
C. Stephen Allred, Director
June 15, 2004
Ron Law, Executive Administrator
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Subject: Proposed Union Pacific Railroad Abandonment.
Dear Mr. Law:
Tills letter is in response to the Idaho Public Utilities Commission s notice concerning
abandonment of the Coeur d' Alene Industrial Lead from milepost 2.25 Feeley Spur to milepost
7.5 near Gibbs, Idaho. At its eastern terminus the rail line flanks the Spokane River for
approximately ~ mile. The rail line pas~es by residential neigh,borhoods, schools ~d parks in
we~tem Cbe~ d' A1ene~ It is ~e~dily" ac~essible to the public. Afte~ disyussio11S With long time
residents of~e Coeur d' Alene area, oUr understanding is that th~ line p~arily""carried forest
products to and from lumber mills. Petroleum products were transported t6 heating. oil
distributors and an ~ha1t piant. Creosote from treated ties is a contaminant knq-wn to exist
along the railroad bed. Herbicides, used in vegetation control and spilled petroleum product are
potential contaminants in the rail corridor as well.
The Department of Environmental Quality (DEQ) is not aware of any large' releases of hazardous
materials along the rail line. Based on the potential contaminants of petroleum products, the
long history of line operation and our experience with other rail line abandonment projects, DEQ
requests a reconnaissance assessment of the rail bed and adj acent right of way. over its length.
The assessment should inventory any areas with discolored soils or devoid of vegetation for no
apparent reason.. The extent of these areas should be mapped. Any areas inventoried should
undergo soil testing using a defensible sampling design to establish the nature of any
ntamination, its extent, and maximum concentration values. The type of cont.amination
suspected at any particular site should dictate the constituents sampled and assessed. A diesel
extended TPH analysis (Method # SW80 15 modified) may be indicated given the fact that heavy
petroleum products were carried over the line.
Since the line is known to have creosote contamination on its bed and it is easily accessed from
the populated areas it passes, additional testing and assessment should be completed to assure
that no public health issues exist. A scientifically supportable random sampling of the grade and
right of way shouid be completed to establish the surface and near surface (12 inches)
concentrati.o:qs of creosote ap.d herbicides. These data should be subj ected to a ~sk based
assessment protocol that should guide grade closure alternatives protective of human health andthe environment.
~. ,.. ~ " ;. =
Ron Law
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Executive Administrator
June IS-, 2004
Page 2
There is a short section of the rail grade situated along the Spokane River. Any abandonment
activities such as rails and .ties removal should apply best management practices (B11Ps)
designed to protect the river from nonpoint source pollution. Once installed these BMPs should
be inspected on a regular basis and enhanced if not achieving the desired control of runoff and
nonpoint source pollution.
Any area uSed to temporally store and/or treat salvaged rails and ties should be situated well
away from the river. It should be adequately fenced to restrict public access. Any temporary
storage and/or treatment facility situated any place along the rail line will be ove.r the Rathdrum
Prairie-Spokane Valley Aquifer, a sole drinking water source for 450 000 residents of the region.
Local critical materials regulations (ill AP A 41.01 :0 400) designed for aquifer protection will
apply to any associated chemical storage at a storage and/or treatment site. Groundwater
protection is required by the Idaho Groundwater Rule (IDAP A 58.01.11). Primary and
secondary impermeable layers for containment of drainage gener~ted from precipitation on
stored rails and ties would be warranted. Adequate measures to collect,isolate and treat any
accumulating liquids should be in place. Should tie wasbing be contemplated on such a site
liquid waste minimization measures would be required in addition to a liquids removal or
treatment plan. RCRA regulations may apply, dependent on any wastes generated.
If you have any questions concerning this response, please direct these to Kreg Beck at 208-769-
. 1422..er kbeck~deq.state.id.
Sincerely,
Gwen P. Fransen
Regional Administrator
c: Surface Trcillspor-~tion BoareL 1925 K St., mv, 'Vas hlngtOll-, D.C. 20423-0001
C. Stephen Allred, DEQ-State Office
Kreg Beck, DEQ-Coeur d' Alene
Richard Martindale, PIID-Coeur d' Alene
Rand Wichman,'Kootenai County Planning & Zoning