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03-29 Robert Neufeld1 Charlene Way From:Robert Neufeld <robneu1@yahoo.com> Sent:Thursday, March 29, 2018 9:30 AM To:City Clerk Subject:Opposition to Costco Attachments:Costco Geo-technical.docx My name is Robert Neufeld. I reside at 3756 W Snow Cherry Ct. Meridian, Idaho 83646. I represent the North Meridian Water Quality Coalition. We are concerned that the City of Meridian has failed to address the issue of protecting our very high quality drinking water supplies by not addressing the impacts that construction of a Costco would have on that resource. I am submitting written comments in opposition to the proposed new Costco to be located at Ten Mile and Chinden and will be speaking on behalf of the Coalition at the City Council meeting on April 3, 2018, 1 Geo-technical Engineering Report Proposed Costco Wholesale Warehouse Kleinfelder Project #20180872.001A CW #16-0096 October 9 2017 My remarks tonight are intended to help you as elected officials fully understand the significance of our local groundwater supply and the potential impacts the proposed Costco could have on that supply for our current and the future residents of North Meridian and other locations North and West of the proposed Costco Site. Idaho Department of Water Resources (IRWB) and Idaho Department of Environmental Quality both cite that Water Quantity and Quality in Idaho are both abundant and of extremely high quality. IDWR is charged with the development of the statewide water policy and associated component basin and water body plans for the State of Idaho. In 2012 IRWB adopted a revised State Water Plan that reflected the changing landscape of water in Idaho. IRWB opens that new plan with the following comments directed to the citizens of Idaho: “Water is the lifeblood of Idaho. Many changes have occurred since the last plan was adopted in 1996. The policies and actions in this Plan reflect a keen awareness of the uncertainty of future conditions of water supply and demand”. As Idaho and in particular Ada County and the City of Meridian continue to grow, demands will increase on our local groundwater supplies and increase the potential for local sources of contamination. Water in this area is commonly referred to as in the “Treasure Valley Aquifer”. Map showing the location of groundwater wells in the northern portion of the Treasure Valley Aquifer. The concentration makes it difficult to see the details. The far right section shows Lucky Peak Reservoir and I-84 2 Groundwater production facilities are shown above are from the IDWR web site and show those in and around Ada County. As you can see the largest concentrations are in the areas west and north of the I- 84 corridor. According to IDWR a Comprehensive Aquifer Management Plan (CAMP) is currently in progress for the Treasure Valley Aquifer. Water flows in the basin are generally in a northwesterly direction from the Boise River beginning near Lucky Peak Reservoir westerly through Boise and then northwesterly towards Meridian. Groundwater flows move horizontally through various layers of the soil below the surfaces. Ground Water Flow Systems The Treasure Valley contains a complex system of shallow, intermediate, and deep aquifers. Shallow aquifers often supply water to rural domestic and some irrigation wells. Municipal, industrial, and some irrigation wells typically draw water from deeper aquifers. Intermediate aquifers, found in the transition from shallow to deep zones, supply water for domestic, irrigation, and municipal uses. Quote: “While groundwater is abundant and water quality is high in the Treasure Valley, continued growth and demands upon our water supply must be made with knowledge of the impacts that development will have on our drinking water system. Contamination of ground water is nearly always the result of human activity. In areas where population density is high and human use of the land is intensive, groundwater is especially vulnerable. Virtually any activity whereby, chemicals or wastes may be released to the environment, either intentionally or accidentally, has the potential to pollute groundwater. When ground water becomes contaminated, it is difficult and expensive to clean up”. That quote is from the US EPA website. Ground Water Protection More than 95% of the water used by Idaho households comes from ground water. DEQ is responsible for protecting the quality of ground water in Idaho and relies on a combination of programs to protect ground water from pollution, clean up degraded ground water, and monitor and assess ground water quality. DEQ's ground water policy is to maintain and protect the existing high quality of Idaho's ground water and restore degraded ground water where feasible to support beneficial uses. IDAHO GROUNDWATER QUALITY MANAGEMENT A MANUAL FOR LOCAL OFFICIALS PREPARED BY PAUL JEHN IDAHO DEPARTMENT OF HEALTH AND WELFARE DIVISION OF ENVIRONMENTAL QUALITY BUREAU OF WATER QUALITY 450 WEST STATE STREET BOISE, ID 83720-999 0 Ground water contamination is nearly always the result of human activity. In areas where population density is high and human use of the land is intensive, high levels of ground water are especially vulnerable. Virtually any activity whereby chemicals or wastes may be released to the environment, either intentionally or accidentally, has the potential to pollute ground water. When ground water becomes contaminated, it is difficult and expensive to clean up. 3 Groundwater is one of Idaho’s most important and fragile natural resources. Idaho is the fourth largest user of groundwater in the United States; groundwater supplies over 90 percent of the state’s drinking water and 100% of the water supply to the City of Meridian and many other surrounding communities. Traditionally, man has disposed of his waste products in a variety of ways, sometimes with little thought for its potential impacts on groundwater quality. Groundwater pollution may lead to nuisance problems like hardness, color, taste, odor or appearance. More serious problems develop when the pollutants are pathogenic organisms, flammable or explosive substances or toxic chemicals. Groundwater quality in Idaho is generally very good. However, local problems have arisen which suggest that prudent management of this natural resource is imperative. The most promising action now available is prevention of contamination. The EPA has set a maximum drinking water concentration of 5 ppb for some compounds (e.g., benzene). To put this in perspective, one ounce of benzene will degrade 3,125,000 gallons of water to a level of 5 ppb. Hazardous wastes are defined on the basis of ignitability, corrosivity, reactivity and toxicity. Contamination of groundwater by toxic or hazardous chemicals has been reported nationwide and has caused the closing of both public and private wells. Underground Storage Tank Regulations The final federal regulations covering Underground Storage Tanks (USTs) that contain petroleum or hazardous chemicals were issued in September 1988. Over 90 percent of Idaho’s drinking water is groundwater. Organic chemicals and gasoline and other petroleum products are among the contaminants most frequently found in groundwater. The chemicals that make up gasoline (such as benzene and toluene) are among the most toxic of commonly found chemicals. These chemicals are included in a class of hazardous materials known as Volatile Organic Compounds (VOC’s) The Bureau of Water Quality, being the designated state agency to work with the EPA on the UST program, is evaluating possible program implementation options. The Bureau put together an UST Technical Advisory Committee (TAC) of affected parties to help provide input on these options. Since it is expected that EPA will not be providing financial support to those directly impacted by the program, the Bureau and TAC will be evaluating several alternatives to help with this problem. Underground and above ground storage tanks holding petroleum products, acids, solvents and chemicals can develop leaks from corrosion, defects, improper installation, or mechanical failure of the pipes and fittings. Volatile Organic Compounds (VOC’s) VOC’s enter the environment from plastics, dyes, rubbers, polishes, solvents, crude oil, insecticides, inks, varnishes, paints, disinfectants, gasoline products, pharmaceuticals, preservatives, spot removers, paint removers, degreasers, and many more. VOC’s Can cause cancer and liver damage, anemia, gastrointestinal disorder, skin irritation, blurred vision, exhaustion, weight loss, damage to the nervous system, and respiratory tract irritation. 4 Figure 1 Petroleum fuels. Diesel and gasoline are well-known indirect causes of groundwater pollution. In some instances, these fuels, when kept in underground storage, can leak significantly and seep into the ground around them, leading to groundwater contamination. States and territories have been submitting information about their UST programs since 1988. As of September 2017: • 538,193 confirmed releases have been reported; • 516,882 cleanups have been initiated; and • 469,898 cleanups have been completed. 5 Petroleum releases from leaking underground storage tanks (LUSTs) pose numerous potential threats to human health and the environment. Petroleum can seep into and through the soil to the water table. At the water table, these liquids can accumulate as a pool on top of the water because most substances in underground storage tanks (USTs) (e.g., petroleum) are less dense than water. Here the chemicals can dissolve into and contaminate ground water and surface water. In Idaho, ground water supplies about 95% of the population's drinking water, so keeping it clean is a high priority. In addition, vapors from petroleum releases can be a health and safety concern. Idaho UST/LUST Program Idaho Department of Environmental Quality Waste Management and Remediation Division Underground Storage Tank/Leaking Underground Storage Tank Program 1410 North Hilton Boise, ID 83706 Phone: 208-373-0247 Fax: 208-373-0154 Idaho's UST Program Web page Exit | Idaho's LUST Program Web page Exit Fund Program Idaho State Insurance Fund Petroleum Storage Tank Fund Exit 1215 West State Street Boise, ID Mailing Address: P.O. Box 83720 Boise, ID 83720-0044 Phone: 208-332-8100 Phone: 877-997-7664 Fax: 208-334-3696 USTs store petroleum products or certain other hazardous liquids that can harm the environment and human health if released into the environment. USTs are subject to Idaho rules and federal regulations. Idaho has about 3,500 regulated USTs; there are about 561,000 nationwide. Records from the Idaho Department of Environmental Quality indicate that from 1990 to March 2018 there have been 1517 reported Leaking Underground Storage Tanks (LUST) in Idaho. 6 As the population of Idaho, especially in the Treasure Valley and The City of Meridian as the growth leader has increased, so has the frequency of LUST incidents. Meridian has reported 22 LUST events. 7 Numerous Groundwater drinking wells for private and public use lie in the path of any leaks from the UST’s proposed by Costco as they are located northwest of the UST site. Water levels in the area surrounding the site have been measured in ranges from 8.5 – 16 feet below existing ground surface. Domestic Water wells in the immediate area have been recorded as having artesian capabilities. Meaning water levels are actually pushing groundwater above the ground surface. As a matter of the public record, Staff at the City was so concerned about high water levels in the Bainbridge development that the sent an email to a Brighton representative requesting information on how many homes in the development had been constructed with basements? The home at 5862 Carlese Ave built by Gardner Homes had two basement pumps running 24/7 last spring trying to keep the basement dry. The water was pumped through a discharge line placed on top of the ground and out to the street. The email exchange between staff and the representative from Brighton is attached next. 8 9 Contamination of groundwater is almost exclusively the result of human action. Of the organic components that make up Petroleum products, Benzene is the most troublesome. The USEPA has designated Benzene as a hazardous substance in accordance with the Clean Water Drinking Act. They also limit the maximum level of Benzene in local water supplies to 5 parts per billion (ppb). US Health & Human Services Agency for Toxic Substances and Disease Registry reports that of all the components in Gasoline, Benzene is the most hazardous. Idaho Department of Environmental Quality provides regulations for Underground Storage Tanks (UST) installed in Idaho and note that since the initial regulations were passed by the Legislature that there have been 1,517 reported LUST incidents in the State and 22 in Meridian. 10 of the 22 were related to Gas Station facilities and the remaining were large businesses that had onsite gas fueling stations. Long exposure to Benzene has been found to cause Cancer, specifically leukemia and are known to target the nervous system and blood forming organs. Continued expose to Benzene can be harmful to human reproductive organs, immune systems, bone marrow, and lead to severe anemia. When this application was submitted to City Staff for review and comments there was no discussion of the impacts of this project on Water supplies or quality. In the Draft report submitted by the applicant to the staff for the P & Z Commission hearing, the document from Kleinfelder was unsigned and not a full report. How can staff fairly and responsibly report to the Planning & Zoning Commission when the report is incomplete and subject to change? The City Council must now step up and represent the local constituents who live in Meridian and drink from the Treasure Valley groundwater aquifer. The final signed version was submitted to the City on March 22, 2018 and contains numerous additions that were not present in the Draft utilized by Staff and the Planning & Zoning Commission in their decision. The following are excerpts from The Kleinfelder Report noted above. Under Kleinfelders direction, Haztech drilling installed three groundwater monitoring wells at the site in June 2017 in order to monitor the static groundwater level at the site. Groundwater levels were observed at depths ranging from approximately 11 feet to 18 feet below existing ground surface (bgs) in these monitoring wells. Additional test wells were drilled on site to determine soil conditions and depth to water. “Based upon the results of our field exploration, laboratory testing and Geo-technical analysis, it is our professional opinion that the proposed project is Geo-technically feasible, provided the 10 recommendations presented in the Geo-technical report are incorporated into the project design and construction”. 1.1 General “The purpose of our geotechnical report was to evaluate soil and groundwater conditions at the site and provide geotechnical recommendations for project design and construction”. 1.2 Project Description “The fuel facility will contain three 30,000 underground storage tanks, fueling station and metal canopy and pre-manufactured kiosk. Four borings and one test pit were completed within the fuel facility area”. 2.1 Site Description “Grading plans are not currently available, however, based upon the existing site grade we anticipate cut and fill depths will be on the order of five (5) feet or less. Additionally, based upon past experience we estimate that underground storage tank (UST) installation for the fuel facility will require an excavation of about 18 feet below existing ground surface and loading dock excavations will be about 4 feet below existing grade”. 3.3 Groundwater “We observe groundwater seepage, as evidenced by wet SPT samples and soil moisture, at depths ranging from 8.5 feet to 16 feet below ground surface (bgs). Groundwater observations in the three piezometers installed during our explorations were consistent with this range of groundwater observations. Ground water at this site is expected to fluctuate seasonally based on precipitation and local irrigation practices. A detailed investigation of regional and local groundwater conditions was outside the scope of our investigation”. (What about other sites) How can any reasonable person not recognize that the installation of the fuel storage tanks associated with the Costco project will be in or immediately upon the ground water underlying this project? The Geotechnical report fails to address the issue of the tanks in or in the proximity to current ground water levels by stating that it was not within the scope of work for them. Kleinfelder reports that up to 5 feet of excavation will be required for this project. With Groundwater levels reported at 8.5’ to 16’ and the removal of up to 5’ of existing top soil; means there even less earth to act as a filter from leaking Underground Storage Tanks and to the runoff of storm water contamination. I have in my hands a one once container of coffee creamer. This is the amount of Benzene that would affect 3 million plus gallons of groundwater to the point of exceeding the EPA requirements of 5 ppb. 11 The City of Meridian has an obligation to every water consumer in the City and beyond to protect the very high quality groundwater in our aquifer from contamination. Tonight, You must vote to reject this application as the applicant has failed to address the issues outlined previously to protect our drinking water. Idaho Code Section 67.6537 (4) “REQUIRES municipalities to address aquifer impacts in their Comprehensive Plans” The City of Meridian’s comprehensive plan does not cover this State Law Requirement and it my understanding that while a draft Comprehensive Aquifer Management plan has been prepared by staff, the adoption of that plan could be months and possibly years away. This application before the City Council tonight must be denied. The Applicant and Staff have failed to identify, recognize, and address the impacts of this project on our local aquifer and the high quality drinking water that serves all the residents of Meridian and many surrounding areas and communities. Failing to deny this project could subject the City of Meridian to future law suits due to the future contamination of our local groundwater supply.