20101021DEQ Comment.pdf

~-A STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY CE
20m OCT 2 I PH 2: 08
1445 North Orchard. Boise, Idaho 83706 . [phone] !Dl\Hu f",j",
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C.L. "Butch" Olter, Governor
Toni Hardesty, Director
October 21, 2010
Idaho Public Utilties Commission
PO Box 83720
Boise, ID 83720
RE: Comments Case No. UPR-R-I0-0l, Notice ofIntent to Abandon a Rail Line
Milepost 0.9 to 1.75 of the Stoddard Industrial Lead, Nampa, Idaho
Dear Sir/Madam,
The Boise Regional Offce ofthe Department of Environmental Quality (DEQ) has received a Notice of
Intent that the Union Pacific Railroad (URR) intends to abandon and discontinue serice from milepost
0.9 to 1.75 of the Stoddard Industrial Lead in Nampa, Idao. UPRR is required to consult with State
environmental program agencies prior to development of an Environmental Report. The Envionmental
Report wil analyze the pptential envionmental impacts caused by the proposed abandonment. We
appreciate the opportunty to provide these preliminary comments on this project. However, we
anticipate UPRR wil initiate communication with DEQ for more in-depth discussions regarding the
abandonment plan for the identified rail line segment and the potential envionmental concerns for this
project as par of the development of the Environmental Report.
1. Air Quality. Please review IDAP A 58.01.01 for all rules on Ai Quality, especially those regarding
fugitive dust (58.01.01.651), trade waste burnng (58.01.01.600-617), perts to construct
(58.01.01.201), and odor control plans (58.01.01.776).
2. Hazardous Waste. The types and number of requirements that must be complied with under the
federal Resource Conserations and Recover Act (RCRA) and the Idao Rules and Standads for
Hazardous Waste (IAP A 58.01.05) are based on the quantity and tye of waste generated. Ever
business in Idaho is required to track the volume of wastes generated, deterne whether or not each
type of waste is hazardous, and ensure that all wastes are properly disposed of according to federal,
state, and local requirements.
3. Solid Waste. No trash or other solid waste should be buried, burned or otherwise disposed at the site.
These disposal methods are regulated by varous state regulations including Idaho's Solid Waste
Management Regulations and Standards, Rules and Regulations for Hazardous Waste, and Rules and
Regulations for the Prevention of Ai Pollution.
4. Water Quality. Site activities must comply with the Idaho Water Quality Standards (IDAPA
58.01.02) regarding hazardous and deleterious materals storage, disposal, or accumulation adjacent
to or in the immediate vicinity of State waters, and the clean up and reporting of oil filled electrical
equipment, hazardous materials, used oil, and petroleum releases.
Printed on Recycled Paper
Idaho Public Utilities Commission
October 21, 2010
Page 2 of2
5. Water Quality. A pollution prevention plan for sediment and erosion control should be developed to
identify and prevent sediment and erosion resulting from the rail bed abandonment. A Clean Water
Act Section 402 NPDES Constrction Storm Water Perit may be required by the US Environmental
Protection Agency.
6. Ground Water. DEQ requests that ths project comply with Idaho's Ground Water Quality Rules
(IDAP A 58.01.11) which states that "No person shall cause or allow the release, spiling, leaing,
emission, discharge, escape, leaching or disposal of a contaminant into the environment in a maner
that causes a groundwater quality standard to be exceeded, injures a beneficial use of ground water, or
is not in accordance with a permt, consent order or applicable best management practice, best
available method or best practical method."
7. Surface Water. If this project is near surface water, DEQ requests tht projects incorporate
construction best management practices to assist in the protection ofIdao's water resources. Total
Maximum Daily Load storm water perit conditions may apply. A National Pollution Dischage
Elimination System (NDES) Permit may be required for this project.
8. Surface Water. If the project wil involve de-watering of ground water during excavation and
discharge back into surface water, a short term activity exemption (from this offce) wil be needed
which describes treatment of the water from this process to prevent excessive sediment and tubidity
from entering surface water.
9. General. Railroad ties, debris dumps, and contaminated areas should be identified, assessed and
properly remediated. Abandonment methods need to prevent leaching of wood preseratives from
treated wood surfaces durng dismantling of rail line strctues.
10. General. Adjacent properties along the proposed abandonment segment should be evaluated for
potential underground storage tanks, leakig underground storage tans, hazardous waste sites, and
remediation sites that may impact proposed abandonment activities.
Than you for the opportunty to provide preliminar comments on this project. Additional comments
may be necessary after receiving more information regardig specific abandonment plans. If you would
like to discuss these comments or have any questions, please contact the DEQ Boise Regional Offce at
[phone].
nelY/HV=-¿ ~/J~Pete Wagner f/ v
Regional Administrator
Boise Regional Office
c: Michael McCurdy, DEQ-BRO Ground Water and Remediation Manager
Natalie Clough, DEQ-SO Hazadous Waste Compliance Manager
Douglas Conde, Deputy Attorney General