HomeMy WebLinkAboutMay Creek Painting Plan for ESA HPA COR review
Over-Water Work: Painting Over May Creek
Water Quality Cert No. 16156
Summer 2025
Description of Work – painting over water:
Flatiron-Lane Joint Venture (FLJV) will perform over-water girder painting on BR-25W and BR-25E above
May Creek. This activity involves erecting containment, surface preparation, and painting using controlled
hand-spraying methods by subcontractor Purcell. The work is designed to avoid discharges to May Creek
and includes multiple environmental protections to ensure compliance with project permits and water
quality standards.
The following permitting requirements have been evaluated to ensure compliance:
• HPA (WDFW): mod needed
• 401 (Ecology): WQMPP V21 details activities associated with this work
• 404 (USACE): Not needed
• ESA (NMFS): an ESA update was provided by WSDOT to address painting activities and the
updated construction end date.
• Fish Note: May Creek is listed as a salmonid bearing stream. No fish exclusion is necessary for
this activity.
Scheduling:
• Over-water work at May Creek is authorized between June 15th and August 31st, 2025.
• The activity is expected to take 2–3 weeks to complete.
• Work will only occur during dry weather conditions and daylight hours.
Sequence of Work:
1. A pre-painting conference will be held 5 to 10 working days before beginning painting operations
to discuss the painting plan, construction operations, personnel, and equipment to be used.
2. Install a tarp-based containment system suspended over May Creek using cables anchored to
eco-blocks.
3. Prep bridge girders for painting using manual surface preparation methods, including
sandblasting.
4. Apply paint using a controlled hand-spray technique to minimize overspray and material loss.
5. Remove the containment system after over water work is complete.
BMPs for over water work
The following measures (and/or BMPs) will be incorporated into this work in order to minimize potential
quality impacts during construction.
• Environmental awareness training will be provided to all subcontractor personnel involved.
• Spill kit stocked on-site for immediate response to any accidental spills involving fuel or paint
materials.
• Designated equipment prep and cleanup area with secondary containment to prevent the
discharge of cleaning fluids or paint waste to the environment. This designated area will be
established upland and away from waters of the state.
• Paint will be contained to sealed spray systems or limited to less than 2 gallons if performing a
brush or roller application.
• Retractable containment tarp system and other necessary containment systems will be used to
capture any sandblasting media, paint drips, overspray, or debris from reaching the waters of the
state.
o The containment will extend beyond the width of the bridge decks above.
o The containment will be approximately 10 ft above the OHWM.
o The containment will be installed with a slight slope to one side, allowing any debris to
naturally accumulate on one side for safe, dry-land removal without requiring personnel
access onto the tarp.
o The containment will have material placed on top of the tarp to absorb paint related drips.
• A vertical containment system will be installed down wind of the painting area.
o The vertical containment system will be constructed with geotextile filter cloth that will
allow some airflow for worker safety while still capturing particulates of paint overspray.
• Painting operations will be restricted to favorable weather conditions, dry days with calm or mild
wind to prevent overspray, stormwater management, or reduced containment effectiveness.
• If degreasing bridge components is necessary, they will be cleaned manually using a degreaser
and absorbent material to prevent cleaning agents from entering state waters.
• Daily inspections of the containment system will ensure that the tarp remains secure, intact, and
effective during all operations.
• Environmental staff will perform frequent field checks to confirm BMPs are properly implemented
and maintained.
Contingencies:
• Work will be conducted only during daylight hours to avoid impacts from lighting over water.
• Environmental staff will frequently monitor the activity and verify BMPs are properly maintained
and followed.
• Should weather forecasts predict rain or wind, work will be paused, and the tarps will be retracted
to prevent stormwater accumulation.