HomeMy WebLinkAbout005 MDEQ Response Email to M-371
Eric Foss
From:Fry, Kate <kfry@mt.gov>
Sent:Monday, October 17, 2022 2:24 PM
To:Eric Foss; Rory Romey
Cc:'jsullivan@tasman-geo.com'; Christopherson, Sarah
Subject:RE: North Park Rail Design and MDEQ Monitor Well M-37
Hi Eric,
Thank you for providing the information on the railroad spur construction and M-37. DEQ and the
City of Bozeman/CVS Pharmacy, through their consultant Tasman, do not object to the grading
around M-37 described in your September 30th email.
We are concerned about future access. Please provide contact information so arrangements can be
made to continue access to M-37. You mentioned that a different engineer is designing the industrial
site where you suggest future access will be located. Do you know if it is the same owner for this
site? Please provide a contact name for the owner of the site if possible.
Please let me now if you have questions.
Regards,
Kate
Kate Fry | Senior Project Officer
Waste Management and Remediation Division
Contaminated Sites Cleanup Bureau
Montana Department of Environmental Quality
Office: 406-444-6426
From: Eric Foss <efoss@alliedengineering.com>
Sent: Friday, September 30, 2022 4:12 PM
To: Fry, Kate <kfry@mt.gov>; Rory Romey <rromey@alliedengineering.com>
Cc: 'jsullivan@tasman‐geo.com' <jsullivan@tasman‐geo.com>; Christopherson, Sarah <Sarah.Christopherson@mt.gov>
Subject: [EXTERNAL] RE: North Park Rail Design and MDEQ Monitor Well M‐37
Hi Kate,
It has been a while since we corresponded about this project. Recently, we have been working on designing the rail spur
line that will cross Mandeville Creek and access the tract of land (Tract 2‐B of COS 2153A) that monitor well M‐37 is
located on. The access is challenging for rail design due to the geometry of the creek and the location of the monitor
well.
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Please see our attached plans. Sheet C3.0 best shows the proximity of the monitor well to the proposed grading. And
sheet C3.2 shows a cross section at this location. Our design shows an estimated 0.6‐ft of fill around the bottom of the
well casing. This would leave about 2.5‐ft of well casing exposed above the proposed finished ground level.
We would like to know if the proposed grading around the monitor well will be acceptable.
I also included an exhibit showing the current access and future access to the monitor well. Please see attached. Things
have changed a little bit on site recently. Earlier this year, the road easement for Red Wing Drive was abandoned within
the Montana Rail Link right‐of‐way. The at‐grade railroad crossing has been abandoned and removed at Frontage Road
and North 7th Ave. MRL has installed a gate at the edge of their right of way near North 7th Ave. Without a gate code
from MRL the current access to the monitor well is down a temporary access road running east‐west between the
NorthWestern Energy gate station and the cell tower, then directly north. In the future we anticipate the access to the
monitor well will be off of Wheat Drive and likely through an industrial site with a loading and unloading area. This site is
currently being designed by a different engineer.
Please let us know if you have any questions about our proposed plans.
Have a great weekend,
‐Eric
Eric Foss, EI
Civil Engineer
Allied Engineering Services, Inc.
32 Discovery Drive, Bozeman, MT 59718
Tel: 406.582.0221 x222 | Fax: 406.582.5770
Cell: 509.998.2797|Email: efoss@alliedengineering.com
Web: www.alliedengineering.com [alliedengineering.com]
DUNS: 00‐769‐3724
CAGE: 1GHU7
From: Fry, Kate <kfry@mt.gov>
Sent: Tuesday, January 18, 2022 8:44 AM
To: Rory Romey <rromey@alliedengineering.com>
Cc: Eric Foss <efoss@alliedengineering.com>; 'jsullivan@tasman‐geo.com' <jsullivan@tasman‐geo.com>;
Christopherson, Sarah <Sarah.Christopherson@mt.gov>
Subject: RE: North Park Rail Design and MDEQ Monitor Well M‐37
Hi Rory,
Thank you for considering options for protecting M-37 during construction and after construction
activities. I discussed your email with Jim Sullivan of Tasman Geosciences, the remediation
contractor for the City of Bozeman and CVS Pharmacy who are responsible for the cleanup of the
Bozeman Solvent Site.
As I mentioned in previous discussions with you, M-37 is part of the groundwater monitoring program
for the Bozeman Solvent Site. Although PCE concentrations in the M-37 are showing a decreasing
trend, groundwater monitoring in this area needs to continue until remedial actions are complete. At
this time, I cannot give an exact timeline for the groundwater monitoring.
One option available is to find an alternate location for M-37 that is close to its current location, but
outside of the proposed rail embankment, loading and unloading area, and heavy equipment traffic
area. This would involve abandoning M-37 before construction activities then reinstalling M-37 after
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construction activities. A new well would have to be installed in similar conditions as the existing M-
37 for comparable data collection. Similar arrangements have been conducted in another area of the
Bozeman Solvent Site.
DEQ must approve the relocation of M-37. However, DEQ will not require the City of Bozeman/CVS
Pharmacy to relocate this well to accommodate construction. If the City of Bozeman and CVS
Pharmacy agree to relocating M-37, it is unlikely that they will pay for the abandonment and
reinstallation if the relocation is not required by DEQ.
Because the well abandonment and well replacement is considered a remedial action (see §75-10-
701(20), MCA for the definition of remedial action) if a party other than the City of Bozeman or CVS
Pharmacy conducts the remedial action, DEQ would require a work plan for the well
abandonment/replacement, and DEQ would have to provide written permission for the work to be
conducted (§ 75-10-711(9), MCA and ARM 17.55.110
(http://www.deq.mt.gov/dir/legal/Title17.mcpx)). I can provide more information on this third party
process at a separate time.
I think it would be beneficial to have a call between you, the property owner/rail line owner, Tasman,
and DEQ to discuss how to move forward with the protection and/or relocation of M-37. Please let
me know a few days and times that work for you and I will coordinate with Tasman. I also think it may
be beneficial to meet on site to discuss the location of proposed improvement plans (e.g., rail line)
and/or alternate locations for M-37.
Tasman, on behalf of the City of Bozeman and CVS Pharmacy, will also need to discuss access
arrangements for the well. DEQ does not need to be part of that discussion if access arrangements
can be agreed upon.
I look forward to discussing this with you further. Please let me now if you have any questions.
Regards,
Kate
Kate Fry
Senior Project Officer
Waste Management and Remediation Division
1225 Cedar Street | Helena, MT 59601
PO Box 200901 | Helena, MT 59620-0901
406-444-6426 | kfry@mt.gov
From: Rory Romey <rromey@alliedengineering.com>
Sent: Wednesday, January 12, 2022 12:48 PM
To: Fry, Kate <kfry@mt.gov>
Cc: Ashley Sullivan (ashley@jlfarchitects.com) <ashley@jlfarchitects.com>; Eric Foss <efoss@alliedengineering.com>
Subject: [EXTERNAL] FW: North Park Rail Design and MDEQ Monitor Well M‐37
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Hello Kate,
Please see attached and below from Eric. There are future rail lines that would be a part of a private rail siding going
directly next to the existing monitor well M‐37. You had noted that it will be critical to avoid damage to or removal of
the well as part of any construction. With the current rail configuration, we are showing fill at the location of the
monitor well and it is quite close to the rail line. Right now we are looking at options to adjust the rail lines to stay away
from the monitor well completely. We did want to get your thoughts on the location of the well relative to the private
rail lines and other improvements. Do we need to worry about providing legal access to the monitor well via an
easement or other agreement? Red Wing Drive is in the process of being abandoned which will change access to the
well site.
Are there options to extend or provide protection around the monitor well?
Separation from improvements/disturbance?
What is the timeline for the well staying in place? I would imagine it would not be removed any time soon?
Please let us know your thoughts and if it would be easiest to just jump on a call.
Thank you,
Rory Romey, PE
Civil Engineer
Allied Engineering Services, Inc.
32 Discovery Dr., Bozeman, MT 59718 | Tel: 406.582.0221 x230 | Cell: 406.223.7827
Email: rromey@alliedengineering.com | Web: www.alliedengineering.com [alliedengineering.com]
DUNS: 00‐769‐3724; CAGE: 1GHU7
From: Eric Foss <efoss@alliedengineering.com>
Sent: Tuesday, January 11, 2022 9:05 AM
To: Rory Romey <rromey@alliedengineering.com>
Subject: North Park Rail Design and MDEQ Monitor Well M‐37
Rory,
Attached are a couple sheets from the rail design plans showing the location of monitor well M‐37 in respect to the
current rail design. With this proposed design the monitor well would be in about 5‐ft of fill coming off the 2:1 rail
embankment for the industry tack. The monitor well would be about 12‐ft horizontally off the edge of the rail.
If we need to completely avoid the monitor well we would need to shift the industry tracks to the south by about 10‐ft
which would eliminate some usable length of loading and unloading area. This would also push the fill slope for the
switch pad about 10‐ft closer to Mandeville Creek.
Perhaps the rail embankment could act as protection for the monitor well as opposed to leaving it out by itself to get hit
by heavy equipment. Is it acceptable for us to stack a couple 3‐ft tall, 48‐in diameter sections of manhole cylinders
around the monitor well to protect it within the rail embankment? I have seen this done before with a survey
monument in an area of fill.
‐Eric
Eric Foss, EI
Civil Engineer
5
Allied Engineering Services, Inc.
32 Discovery Drive, Bozeman, MT 59718
Tel: 406.582.0221 x222 | Fax: 406.582.5770
Cell: 509.998.2797|Email: efoss@alliedengineering.com
Web: www.alliedengineering.com [alliedengineering.com]
DUNS: 00‐769‐3724
CAGE: 1GHU7