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Rathdrum Prairie Aquifer
Contact Us
DEQ Coeur d'Alene
Regional Office
2110 Ironwood Parkway
Coeur d'Alene, ID 83814
ph: (208) 769-1422
fx: (208) 769-1404 |
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Water Quality in the Coeur d’Alene Region:
Operation of the Burlington Northern Santa Fe
Railroad’s Mainline Refueling Facility at Hauser, Idaho |
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| Brief History of Facility |
Permitting Process |
In the mid-1990s, the Burlington Northern Santa Fe Railroad (BNSF) proposed development of a mainline refueling facility at Hauser, Idaho. Because of certain zoning restrictions, the facility required a conditional use permit from Kootenai County. BNSF applied for the permit in November 1997.
The project and proposed locations on and off the Spokane Valley-Rathdrum Prairie Aquifer generated considerable public input and debate. The primary concern was siting a large refueling facility over the aquifer, which is the sole drinking water source for 500,000 residents of the greater Spokane-Coeur d’Alene Area.
Following considerable public debate and hearings, on April 19, 2000, the Kootenai County Board of Commissioners granted a conditional use permit to BNSF with 33 stipulations. Following are four key stipulations of the permit involving DEQ:
- Review by DEQ of plans and specifications for all wastewater treatment and aquifer protection features of the facility
- Oversight by DEQ of inspections of the facility
- Monitoring of the facility to assure effectiveness of environmental safeguards
- Funding for a DEQ staff position to provide oversight
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| The refueling facility was constructed between 2001 and 2003, but did not begin operations until September 2, 2004. The photo at right shows the main parts of the facility. |
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Petroleum Release |
| After operating for about three months, the facility reported a petroleum release to DEQ on December 10, 2004. DEQ staff responded to the scene to oversee BNSF’s initial efforts to excavate soils contaminated with petroleum. Several thousand yards of contaminated soils were excavated over a weekend. Excavation stopped when additional soil removal would have compromised the stability of nearby buildings, even though the full vertical extent of the contamination had not been reached. Excavated soil contaminated with petroleum was eventually shipped by rail to a repository. |
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An investigation later revealed a break in the industrial wastewater line that carried petroleum-contaminated water from the refueling platform to an oil-water separator. The diagram at right shows key components of the facility.
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Since a petroleum release had occurred, BNSF was required to investigate the scope of the release (the vertical and horizontal extent of contamination) and develop a corrective action plan for cleanup. To begin, BNSF installed soil borings to collect soil samples and drilled monitoring wells to collect ground water samples for analysis. As required by state regulations, a consent order between BNSF and DEQ was finalized on May 6, 2005. The consent order governs the assessment and cleanup of the petroleum release of December 10, 2004. |
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Petroleum Containment |
Assessment of the wastewater line release was two months underway when BNSF reported to DEQ on February 14, 2005, that petroleum-contaminated water was detected in sumps (spaces where liquid can collect) monitoring the space between the first and second high-density polyethylene (HDPE) liners under the refueling platform. This detection revealed that two of the three barriers built to protect the soil and aquifer below the facility had failed. The diagram below shows the location of the liners.
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DEQ then requested and BNSF started an immediate investigation into this new problem. The BNSF investigation quickly showed that construction of the refueling facility was faulty, especially at key liner penetrations (known as boots) under the facility. Given this situation, DEQ determined that the facility was operating with a single barrier instead of the three protective barriers on which the county commissioners and the public relied. DEQ asked BNSF to stop refueling operations at the facility until the problems could be corrected. BNSF declined the request, and DEQ sought and obtained a temporary restraining order from District Court on February 23, 2005. The facility then suspended all refueling operations. |
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Temporary Closure of the Facility |
While the refueling facility was closed, BNSF worked to rebuild the barrier system that would protect the underlying soils and aquifer and negotiated a memorandum of agreement (MOA) with DEQ. The MOA specified that before DEQ would request lifting of the restraining order, allowing BNSF to resume refueling operations, three functional barriers had to exist between the depot’s two platforms and tank farm and the soils and aquifer beneath. The MOA also described the ground rules under which the barrier systems and ground water would be monitored site-wide to detect any future failure of the system. When the three barrier systems had been improved site-wide, DEQ joined BNSF in requesting that the restraining order be lifted, and refueling operations started again in early May 2005.
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| August 2009 Update |
Inspection Record |
DEQ has inspected the BNSF refueling facility at least monthly since the facility began operation in September 2004. From the time problems with the construction were recognized at the facility until well after they were solved, DEQ increased inspections to two per month and conducted oversight visits almost daily. During inspections, DEQ staff review key parts of the refueling system, all alarm logs, and documentation of response to substantive alarms. Inspectors also review all monitoring results and fuel reconciliation records (fuel dispensed versus fuel inventory received).
Inspections are conducted to assure that the release of petroleum or other harmful materials has not occurred and to detect conditions that could allow a release to occur. Although the first three inspections after operation began in September 2004 did not detect the broken wastewater line that caused the petroleum release on December 10, 2004, BNSF’s constant vigilance, encouraged by regular inspections, did. Since the refueling facility retrofit, DEQ conducted semimonthly inspections for about a year, eventually reducing them to once a month. Since the refueling facility resumed operation in May 2005, no issues have been identified that DEQ believes would indicate a release of petroleum or any other harmful material to the environment. |
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Implementation of the MOA between DEQ and BNSF |
The MOA between DEQ and BNSF governs two main processes: 1) the means by which the refueling facility will maintain three levels of barriers between fuel handling operations and the soils and ground water beneath the facility, and 2) how BNSF will monitor the effectiveness of the barriers. BNSF has retrofitted all the points through which pipes cross a barrier (such as the HDPE liners) with an approved seamless design to assure no leakage from these points.
Retrofits were completed on all three containment areas: the refueling platform, the tank farm, and the fuel delivery platform. The industrial wastewater pipes were replaced with double-walled piping with the capacity to detect leaks in the space between the two pipe walls. Monitors with alarms to detect the buildup of fluid were installed in sumps associated with the first and second liners. Ground water monitoring wells were installed next to and underneath the refueling platform and a series of wells to monitor petroleum vapors from the soil under the refueling and fuel delivery platforms. When these features were in place, DEQ agreed to and participated in BNSF’s request to remove the restraining order stopping refueling at the facility.
BNSF then submitted and DEQ approved changes to the site operational manual. The revised manual described how the new equipment and alarms at the site should be operated, along with a management plan to address all the cracks developing in the concrete platform floors. BNSF also submitted and DEQ approved the Enhanced Leak Detection and Ground Water Monitoring Plan, which outlines the methods, periodicity, and trigger levels that will require BNSF to report and investigate suspected releases of contaminants and unusual operating conditions. When these documents were all finalized on April 18, 2007, the substantive requirements of the MOA were met by BNSF. |
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Remediation Consent Order |
To address the petroleum release detected December 10, 2004, BNSF and DEQ signed a consent order on May 6, 2005. The consent order required a site investigation that established the horizontal and vertical extent of the petroleum release and its impact on ground water. BNSF had 11 monitoring ground water wells drilled around the release site. As the wells were drilled, samples were collected to determine if the chemicals that made up petroleum (known as petroleum constituents) were present. Based on this work, the extent of impact was defined both vertically and horizontally.
Petroleum constituents were detected in the ground water, but at concentrations less than the maximum contaminant levels for drinking water set by the U.S. Environmental Protection Agency. Petroleum constituents could be detected in the ground water up to 80 feet down-gradient (in other words, in the direction ground water flows) from the release site, but no further. Even though the chemicals detected were below maximum contaminant levels, Idaho’s ground water quality standard for the Spokane Valley-Rathdrum Prairie Aquifer is "no detectable increase above background" (Ground Water Quality Rule, IDAPA 58.01.11.200). Background refers to the levels of contaminants that naturally occur in the aquifer. If petroleum from the refueling facility reached ground water, it would violate Idaho’s ground water quality standard.
As more data was collected from monitoring wells, results showed that BNSF would need a corrective action plan to remove enough petroleum from the soil to stop it from entering ground water. To remove the petroleum, BNSF decided to inject air into the soil (a process known as air sparging) and extract petroleum vapors from the soil. The air sparging method injects air just below the ground water surface to make petroleum change into vapor form and to provide oxygen that helps microbes break down petroleum. Petroleum vapors are then released to the soil, where a vapor extraction system draws out the air from both the water and soil. These methods are commonly used to clean up underground petroleum contamination in areas like the Rathdrum Prairie, which have extremely porous soils. BNSF has been using the air sparging–soil vapor extraction system since February 16, 2005. As of March 2009, the system has collected 1,993 gallons of petroleum from the extraction wells distributed across the area impacted by the release. BNSF monitors the ground water wells quarterly and reports the results to DEQ. As of March 2009, no petroleum constituents have been detected (at levels greater than laboratory minimum detection levels) in any ground water wells monitoring the area where petroleum-contaminated water escaped from the broken wastewater line in 2004.
BNSF will stop using the air sparging–soil vapor extraction system if the amount of petroleum recovered from the system declines and if ground water monitoring continues to show no petroleum constituents in monitoring wells. BNSF will then be required to continue monitoring for at least one year to make sure no petroleum constituents are detected in ground water. BNSF will also be required to demonstrate, through computerized risk-based modeling and possibly some additional soil petroleum assessment work, that any remaining petroleum constituents in the soil are in small enough quantities that they cannot be detected in the ground water. When this is confirmed, DEQ will terminate the consent order. |
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