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STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
Northwest Region Office
PO Box 330316, Shoreline, WA 98133-9716 • 206-594-0000
September 27, 2023
Clark H. Close, Principal Planner
Planning Division
City of Renton
1055 S Grady Way, 6th Floor
Renton, WA 98057
Re: SW Grady Office and Shop Building
File# LUA23-000300, Ecology SEPA# 202304371
Dear Clark H. Close:
Thank you for the opportunity to provide comments on the State Environmental Policy Act (SEPA)
notice of application utilizing the optional determination of nonsignificance (ODNS/NOA) process
for the SW Grady Office and Shop Building 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.
Clark H. Close
September 27, 2023
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 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. 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 Diana Ison with the Toxics Cleanup
Program at (360) 999-9593 or via email at diana.ison@ecy.wa.gov.
Sincerely,
Kelli Price
SEPA Coordinator
Sent by email: Clark H. Close, cclose@rentonwa.gov
ecc: Diana Ison, Ecology