HomeMy WebLinkAboutC_Agency_ECY_Comment_Letter_220622_v1
June 22, 2022
Clark H. Close, Principal Planner
Department of Community & Economic Development, Planning Division
City of Renton
1055 South Grady Way, 6th Floor
Renton, WA 98057
Re: Blue Origin DaVinci Building
File# PR22-000181/LUA22-000197, Ecology SEPA# 202202914
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 Blue Origin DaVinci Building project. Based on review of the checklist associated
with this project, the Department of Ecology (Ecology) has the following comments:
TOXICS CLEANUP PROGRAM
Jing Song, (425) 229-2565, jing.song@ecy.wa.gov
Section B, Environmental Elements; Subsection 3, Water; Subsection b, Ground Water:
Data from monitoring wells at the adjacent property indicated depths to groundwater at
3 to 6 feet below ground surface (bgs). Is dewatering anticipated during soil removal
and construction? If yes, please add dewatering protocols.
Section B, Environmental Elements; Subsection 7, Environmental Health:
The proposed project is located immediate north of one site listed on the Model Toxics
Control Act (MTCA) Confirmed and Suspected Contaminated Sites List – Waste
Management Rainer site (cleanup site ID 9556, facility site ID 52815133) at 316 SW 15th
Street. The Waste Management Rainer site has petroleum hydrocarbons in soil and
groundwater. Cleanup has been started for this site but not completed.
Petroleum-contaminated soil (PCS) remained along the boundary between the Waste
Management Rainer site and the proposed project property, with a diesel concentration
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
Clark H. Close
June 22, 2022
Page 2
up to 3,000 milligrams per kilogram (mg/kg) at 4 feet bgs (PI-N-4), and a heavy oil
concentration up to 750 mg/kg at 6 feet bgs (NSW-2-6). The extent of the PCS was not
yet determined. PCS may have extended to the SEPA project property. Shallow
groundwater may also be contaminated with petroleum hydrocarbons.
If subsurface work planned at the proposed project location has the potential to
encounter soil and groundwater contamination, describe mitigation measures to
address the following:
Hazardous waste operations worker training, health/safety plan, and site control
requirements, per WAC 296-843.
Management of contaminated soil encountered during excavations, including
sampling, containment, and disposal at a permitted facility.
Management of contaminated ground water, if encountered, including sampling,
containment, and disposal at a permitted facility.
TOXICS CLEANUP PROGRAM
Eva Barber, (360) 999-9593, 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://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.
• If lead, arsenic and/or other contaminants are found at concentrations above
MTCA cleanup levels, the applicant shall:
Clark H. Close
June 22, 2022
Page 3
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 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,
Kelli Sheldon
SEPA Coordinator
Sent by email: Clark H. Close, cclose@rentonwa.gov
ecc: Jing Song, Ecology
Eva Barber, Ecology