HomeMy WebLinkAboutRE: VCNW 3233, former South End Auto property.msgHello Bill,
Diane described the situation before she left the cleanup program. We understand that your client is trying to get his business up and running on the property and is working with the
City of Renton on an occupancy permit. I’m sorry but Ecology cannot write an “Equivalent Letter” that states the property does not pose a health risk as you requested. We have to adhere
to cleanup standards and if a site meets those or not and to our boilerplate letters that outline compliance with the MTCA.
My understanding is that Diane wrote at 2 letters outlining remaining issues to resolve at the site. These letters follow the MTCA and VCP process and still stand, even if you disagree
with some of the items. Cleanup levels need to be appropriately developed so that we know remedial actions achieve the cleanup goals. All cleanup work needs to be well documented so
the agency doesn’t make assumptions about conditions at the site. My understanding of one issue, among others, is that a lot of soil was removed, but the number and location of confirmation
samples is insufficient to document that the remaining soil met cleanup standards and if it is protective of ground water.
I am asking that Mike Warfel assist with this site until a new site manager can be assigned. Please work with Mike on the remaining issues. We hope they can resolved.
Best Regards,
Louise Bardy
From: bill <bill@ecocompliance.biz>
Sent: Tuesday, June 2, 2020 9:55 AM
To: Bardy, Louise (ECY) <LBAR461@ECY.WA.GOV>
Subject: VCNW 3233, former South End Auto property
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Hi Louise. We've been working with Diane Escobedo on cleanup of the former South End Auto property in Renton (Ecology project ID VCNW3233). I understand that Diane is no longer with
the VCP program, so I'm reaching out to you to help us resolve a critical and time-sensitive issue with the City of Renton.
The subject property is currently being re-developed for use as a car dealership. Prior to issuing a Certificate of Occupancy (COO) for the new building, the City of Renton is requiring
that we obtain an NFA letter from Ecology, or, if an NFA cannot be obtained, that an "equivalent" letter be written that states the property does not pose a health risk to the people
who will be working at or visiting the property.
Our problem is that re-development is now nearing completion, and we realize that an NFA is not possible in the near-term because of existing groundwater contamination issues. Thus,
we are asking for your help in writing an "equivalent" letter so that we can get the COO from the City.
As discussed in the various site reports, an extensive amount of work has been done to characterize the property, including soil borings, grid sampling and groundwater sampling. Except
within a 75-foot wide wetland buffer area, site remediation involved the excavation and disposal of contaminated soil from all the identified areas, and post-excavation sampling to
confirm the soil meets Ecology's residential cleanup standards based on the scenario of direct contact. Although the wetland area has been characterized, there was no cleanup performed
in this area. We are currently sub-dividing the property so that the wetland buffer area will be a separate tax parcel. As its own parcel, we will deal with the buffer area at a separate
time. We are now focusing on the remainder of the property outside the buffer area.
Diane and I have disagreed on whether the appropriate cleanup standards were applied to the soil remediation effort (we based the standards on residential, direct contact with the soil;
she stated that standards based on protection of groundwater and/or surface may need to be used). This is something that still needs to be resolved.
Regardless of the cleanup standards ultimately applicable to the property, you will see via the various reports that the soil has been cleaned up to the residential, direct-exposure
standards we applied. Thus, we are asking that you write a letter stating that this is true. We understand that such a letter does not mean those are the cleanup standards that may
ultimately be applicable to the property, but simply that you agree that the soil meets the standards and poses no risk to human health based on that specific scenario.
Once again, this is a critical and time-sensitive issue. Your rapid attention to this matter is very much greatly appreciated. Please call me at 206-715-1396 as soon as possible.
Bill Kane
Eco Compliance Corporation
phone 425-271-5629
cell 206-715-1396
www.ecocompliance.biz <http://www.ecocompliance.biz/>