DEQ STATE OF IDAHO
DEPARTMENT OF ENVIRONMENTAL QUALITY
BOISE REGIONAL OFFICE 1445 North Orchard StreetBoise, ID 83706-2239(208) 373-0550
DEQ Response to Request for Environmental Comment
Date: October 10, 2018
Agency Requesting Comments: City of Meridian
Date Request Received: October 4, 2018
Applicant/Description: Elevate Franklin Storage H-2018-0109 MDA, RZ
Thank you for the opportunity to respond to your request for comment. While DEQ does not review
projects on a project-specific basis, we attempt to provide the best review of the information
provided. DEQ encourages agencies to review and utilize the Idaho Environmental Guide to assist
in addressing project-specific conditions that may apply. This guide can be found at
http://www.deq.idaho.gov/ieg/.
The following information does not cover every aspect of this project; however, we have the
following general comments to use as appropriate:
1. Air Quality
Please review IDAPA 58.01.01 for all rules on Air Quality, especially those regarding
fugitive dust (58.01.01.651), trade waste burning (58.01.01.600-617), and odor control
plans (58.01.01.776).
The property owner, developer, and their contractor(s) must ensure that reasonable
controls to prevent fugitive dust from becoming airborne are utilized during all phases of
construction activities per IDAPA 58.01.01.651.
Per IDAPA 58.01.01.600-617, the open burning of any construction waste is prohibited.
The property owner, developer, and their contractor(s) are responsible for ensuring no
prohibited open burning occurs during construction.
For questions, contact David Luft, Air Quality Manager, at 373-0550.
2. Wastewater and Recycled Water
DEQ recommends verifying that there is adequate sewer to serve this project prior to
approval. Please contact the sewer provider for a capacity statement, declining balance
report, and willingness to serve this project.
IDAPA 58.01.16 and IDAPA 58.01.17 are the sections of Idaho rules regarding
wastewater and recycled water. Please review these rules to determine whether this or
future projects will require DEQ approval. IDAPA 58.01.03 is the section of Idaho rules
regarding subsurface disposal of wastewater. Please review this rule to determine
whether this or future projects will require permitting by the district health department.
All projects for construction or modification of wastewater systems require
preconstruction approval. Recycled water projects and subsurface disposal projects
require separate permits as well.
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DEQ recommends that projects be served by existing approved wastewater collection
systems or a centralized community wastewater system whenever possible. Please
contact DEQ to discuss potential for development of a community treatment system
along with best management practices for communities to protect ground water.
DEQ recommends that cities and counties develop and use a comprehensive land use
management plan, which includes the impacts of present and future wastewater
management in this area. Please schedule a meeting with DEQ for further discussion
and recommendations for plan development and implementation.
For questions, contact Todd Crutcher, Engineering Manager, at 373-0550.
3. Drinking Water
DEQ recommends verifying that there is adequate water to serve this project prior to
approval. Please contact the water provider for a capacity statement, declining balance
report, and willingness to serve this project.
IDAPA 58.01.08 is the section of Idaho rules regarding public drinking water systems.
Please review these rules to determine whether this or future projects will require DEQ
approval.
All projects for construction or modification of public drinking water systems require
preconstruction approval.
DEQ recommends verifying if the current and/or proposed drinking water system is a
regulated public drinking water system (refer to the DEQ website at
http://www.deq.idaho.gov/water-quality/drinking-water.aspx). For non-regulated
systems, DEQ recommends annual testing for total coliform bacteria, nitrate, and nitrite.
If any private wells will be included in this project, we recommend that they be tested for
total coliform bacteria, nitrate, and nitrite prior to use and retested annually thereafter.
DEQ recommends using an existing drinking water system whenever possible or
construction of a new community drinking water system. Please contact DEQ to
discuss this project and to explore options to both best serve the future residents of this
development and provide for protection of ground water resources.
DEQ recommends cities and counties develop and use a comprehensive land use
management plan which addresses the present and future needs of this area for
adequate, safe, and sustainable drinking water. Please schedule a meeting with DEQ
for further discussion and recommendations for plan development and implementation.
For questions, contact Todd Crutcher, Engineering Manager at 373-0550.
4. Surface Water
A DEQ short-term activity exemption (STAE) from this office is required if the project will
involve de-watering of ground water during excavation and discharge back into surface
water, including a description of the water treatment from this process to prevent
excessive sediment and turbidity from entering surface water.
Please contact DEQ to determine whether this project will require a National Pollution
Discharge Elimination System (NPDES) Permit. If this project disturbs more than one
acre, a stormwater permit from EPA may be required.
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If this project is near a source of surface water, DEQ requests that projects incorporate
construction best management practices (BMPs) to assist in the protection of Idaho’s
water resources. Additionally, please contact DEQ to identify BMP alternatives and to
determine whether this project is in an area with Total Maximum Daily Load stormwater
permit conditions.
The Idaho Stream Channel Protection Act requires a permit for most stream channel
alterations. Please contact the Idaho Department of Water Resources (IDWR), Western
Regional Office, at 2735 Airport Way, Boise, or call 208-334-2190 for more information.
Information is also available on the IDWR website at:
http://www.idwr.idaho.gov/WaterManagement/StreamsDams/Streams/AlterationPermit/AlterationPermit.htm
The Federal Clean Water Act requires a permit for filling or dredging in waters of the
United States. Please contact the US Army Corps of Engineers, Boise Field Office, at
10095 Emerald Street, Boise, or call 208-345-2155 for more information regarding
permits.
For questions, contact Lance Holloway, Surface Water Manager, at 373-0550.
5. Hazardous Waste And Ground Water Contamination
Hazardous Waste. The types and number of requirements that must be complied with
under the federal Resource Conservations and Recovery Act (RCRA) and the Idaho
Rules and Standards for Hazardous Waste (IDAPA 58.01.05) are based on the quantity
and type of waste generated. Every business in Idaho is required to track the volume of
waste generated, determine whether each type of waste is hazardous, and ensure that
all wastes are properly disposed of according to federal, state, and local requirements.
No trash or other solid waste shall be buried, burned, or otherwise disposed of at the
project site. These disposal methods are regulated by various 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 Air
Pollution.
Water Quality Standards. Site activities must comply with the Idaho Water Quality
Standards (IDAPA 58.01.02) regarding hazardous and deleterious-materials storage,
disposal, or accumulation adjacent to or in the immediate vicinity of state waters (IDAPA
58.01.02.800); and the cleanup and reporting of oil-filled electrical equipment (IDAPA
58.01.02.849); hazardous materials (IDAPA 58.01.02.850); and used-oil and petroleum
releases (IDAPA 58.01.02.851 and 852).
Petroleum releases must be reported to DEQ in accordance with IDAPA
58.01.02.851.01 and 04. Hazardous material releases to state waters, or to land such
that there is likelihood that it will enter state waters, must be reported to DEQ in
accordance with IDAPA 58.01.02.850.
Ground Water Contamination. DEQ requests that this project comply with Idaho’s
Ground Water Quality Rules (IDAPA 58.01.11), which states that “No person shall
cause or allow the release, spilling, leaking, emission, discharge, escape, leaching, or
disposal of a contaminant into the environment in a manner that causes a ground water
quality standard to be exceeded, injures a beneficial use of ground water, or is not in
accordance with a permit, consent order or applicable best management practice, best
available method or best practical method.”
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For questions, contact Albert Crawshaw, Waste & Remediation Manager, at 373-0550.
6. Additional Notes
If an underground storage tank (UST) or an aboveground storage tank (AST) is
identified at the site, the site should be evaluated to determine whether the UST is
regulated by DEQ. EPA regulates ASTs. UST and AST sites should be assessed to
determine whether there is potential soil and ground water contamination. Please call
DEQ at 373-0550, or visit the DEQ website (http://www.deq.idaho.gov/waste-mgmt-
remediation/storage-tanks.aspx) for assistance.
If applicable to this project, DEQ recommends that BMPs be implemented for any of the
following conditions: wash water from cleaning vehicles, fertilizers and pesticides,
animal facilities, composted waste, and ponds. Please contact DEQ for more
information on any of these conditions.
We look forward to working with you in a proactive manner to address potential environmental impacts
that may be within our regulatory authority. If you have any questions, please contact me, or any our
technical staff at 208-373-0550.
Sincerely,
Aaron Scheff
aaron.scheff@deq.idaho.gov
Regional Administrator
Boise Regional Office
Idaho Department of Environmental Quality
ec: TRIM 2018AEK156