HomeMy WebLinkAboutEx_13_DOE_Comment
April 21, 2022
Alex Morganroth, Senior Planner
Department of Community and Economic Development
City of Renton
1055 South Grady Way, 6th Floor
Renton, WA 98057
Re: Brother Cadillac and GMC
File# LUA22-000125/PR22-000124, Ecology SEPA# 202201638
Dear Alex Morganroth:
Thank you for the opportunity to provide comments on the State Environmental Policy Act
(SEPA) notice of application utilizing the optional mitigated determination of non-significance
(ODNS/NOA-M) process for the Brother Cadillac and GMC project. Based on review of the
checklist associated with this project, the Department of Ecology (Ecology) has the following
comments:
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://apps.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 2019 Tacoma Smelter
Plume Guidance. The soil sampling results shall be sent to Ecology for review.
• 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.
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
Northwest Regional Office PO Box 330316 Shoreline, Washington 98133-9716 (206) 594-0000
711 for Washington Relay Service Persons with a speech disability can call 877-833-6341
Exhibit 13
RECEIVED
04/21/2022
AMorganroth
PLANNING DIVISION
DocuSign Envelope ID: 206613E4-C662-427B-B5B2-D00F0C51DB08
Alex Morganroth
April 21, 2022
Page 2
• 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 permitting agency the opinion letter from E cology.
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. 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 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 Ecology. For assistance and information about
Tacoma Smelter Plume and soils contamination, contact Eva Barber with the Toxics Cleanup
Program at (360) 999-9593 or by email at eva.barber@ecy.wa.gov.
Sincerely,
Kelli Sheldon
SEPA Coordinator
Sent by email: Alex Morganroth, amorganroth@rentonwa.gov
ecc: Eva Barber, Ecology
DocuSign Envelope ID: 206613E4-C662-427B-B5B2-D00F0C51DB08