HomeMy WebLinkAbout201904052_ECYCommentLetter.pdf
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
Northwest Regional Office 3190 160th Avenue SE Bellevue, Washington 98008-5452 (425) 649-7000
711 for Washington Relay Service Persons with a speech disability can call (877) 833-6341
July 30, 2019
Alex Morganroth
Planning Division
City of Renton
1055 South Grady Way
Renton, WA 98057
Re: Sound Ford Collision Center
File# PR19-000192, LUA19-000154, Ecology SEPA# 201904052
Dear Alex Morganroth:
Thank you for the opportunity to provide comments on the Sound Ford Collision Center. Based on
review of the State Environmental Policy Act (SEPA) checklist associated with this Project, the
Department of Ecology (Ecology) has the following comments:
HAZARDOUS WASTE AND TOXICS REDUCTION
Kyle Masters, (425) 649-7055, kyle.masters@ecy.wa.gov
Please be advised all waste streams generated at the new 850 Lind Ave SW property must be properly
designated, see WAC 173-303-070 at: https://app.leg.wa.gov/WAC/default.aspx?cite=173-303-070.
Designation will determine whether a waste must be managed as dangerous waste. Inadequate
designation creates risks and results in improper disposal of dangerous wastes. In Washington, we use
the term “dangerous waste” while the federal rules use the term “hazardous waste." Washington’s
Dangerous Waste Regulations are based on the federal Resource Conservation and Recovery Act
(RCRA); however, dangerous waste includes more wastes than the federal definition.
For more information, including information on common types of waste, compliance tips, and links to
additional publications, please visit Ecology’s automotive collision repair webpage at:
https://ecology.wa.gov/Regulations-Permits/Guidance-technical-assistance/Dangerous-waste-
guidance/Common-dangerous-waste/Automotive-collision-repair.
Please be advised you may not transfer dangerous waste to the sister facility at 101 SW Grady Way. If
you generate more than 220 pounds of dangerous waste in a month, or store on-site more than 2,200
pounds at any time, the 850 Lind Ave SW property will need an EPA/State Identification Number of
its own.
Alex Morganroth
July 30, 2019
Page 2
TOXICS CLEANUP PROGRAM
Eva Barber, (360) 407-7094, eva.barber@ecy.wa.gov
This proposed project is located in an area that may have been contaminated with heavy metals due to
the air emissions originating from the old Asarco smelter in north Tacoma (visit Ecology’s Tacoma
Smelter Plume map search tool: https://fortress.wa.gov/ecy/dirtalert/).
Soil contamination from the former Asarco smelter poses a risk to human health and the environment.
Children are at especially high risk from direct exposure to contaminated soil. Construction workers,
landscapers, gardeners, and others who work in the soils are also at risk.
Ecology recommends that the lead agency include the following as conditions of approval, prior to the
issuance of any site development permits or the initiation of grading, filling, or clearing:
Sample the soil and analyze for arsenic and lead following the 2012 Tacoma Smelter Plume
Guidance. The soil sampling results shall be sent to Ecology for review. If the project includes
open space areas, contact the Technical Assistance Coordinator, Eva Barber, for assistance in
soil sampling methodology within the open space area.
If lead or arsenic are found at concentrations above the Model Toxics Control Act (MTCA)
cleanup levels (Chapter 173-340 WAC); the owners, potential buyers, construction workers,
and others shall be notified of their occurrence. The MTCA cleanup level for arsenic is 20
parts per million (ppm) and lead is 250 ppm.
If lead, arsenic and/or other contaminants are found at concentrations above MTCA cleanup
levels, the applicant shall:
1) Develop soil remediation plan and enter into the Voluntary Cleanup Program with Ecology.
For more information on the Voluntary Cleanup Program, visit Ecology website at:
https://ecology.wa.gov/Spills-Cleanup/Contamination-cleanup/Cleanup-process/Cleanup-
options/Voluntary-cleanup-program.
2) Obtain an opinion letter from Ecology stating that the proposed soil remediation plan will
likely result in no further action under MTCA. The applicant shall provide to the local land
use permitting agency the opinion letter from Ecology.
3) Prior to finalizing site development permits, provide to the local land use permitting agency
“No Further Action” determination from Ecology indicating that the remediation plans
were successfully implemented under MTCA.
If soils are found to be contaminated with arsenic, lead, or other contaminants, extra
precautions shall be taken to avoid escaping dust, soil erosion, and water pollution during
grading and site construction. Site design shall include protective measures to isolate or
remove contaminated soils from public spaces, yards, and children’s play areas. Contaminated
soils generated during site construction shall be managed and disposed of in accordance with
state and local regulations, including the Solid Waste Handling Standards regulation (Chapter
Alex Morganroth
July 30, 2019
Page 2
173-350 WAC). For information about soil disposal contact the local health department in the
jurisdiction where soils will be placed.
The link below provides a fact sheet that explains more how the arsenic and lead clean-up levels were
set and why Ecology sees that they are protective for human health:
https://fortress.wa.gov/ecy/publications/SummaryPages/1109095.html
Thank you for considering these comments from the Department of Ecology. If you have questions or
would like to respond to these comments, please contact one of the commenters listed above.
Sincerely,
Katelynn Piazza
SEPA Coordinator
Sent by email: Alex Morganroth, amorganroth@rentonwa.gov
ecc: Rich Snyder, Sound Ford Collision Center
Eva Barber, Ecology
Kyle Masters, Ecology