HomeMy WebLinkAboutEx_10_DOE_Comment_Letter
July 7, 2021
Alex Morganroth, Senior Planner
Planning Division
City of Renton
1055 S Grady Way
Renton, WA 98057
Re: SWA2 Amazon
File# PR21-000051 / LUA21-000233, Ecology SEPA# 202103477
Dear Alex Morganroth:
Thank you for the opportunity to provide comments on the State Environmental Policy Act
(SEPA) notice of application utilizing the optional determination of nonsignificance (DNS)
process for the SWA2 Amazon 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. The area is
mapped at potential arsenic concentrations above 20 parts per million (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.
Because the removal of existing pavement might expose contaminated soil, 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,
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
DocuSign Envelope ID: 2C4A6631-DC6E-4782-B5C1-C3C1FD820667
Alex Morganroth
July 7, 2021
Page 2
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 or lead 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 ppm and lead is 250 ppm. Extra precautions shall be taken to
avoid escaping dust, soil erosion, and water pollution during construction. Site design shall
include protective measures to isolate or remove contaminated soils from public spaces.
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.
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) 407-7094 or via email at eva.barber@ecy.wa.gov.
Sincerely,
Katelynn Piazza
SEPA Coordinator
Sent by email: Alex Morganroth, amorganroth@rentonwa.gov
ecc: Eva Barber, Ecology
DocuSign Envelope ID: 2C4A6631-DC6E-4782-B5C1-C3C1FD820667