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From:notification@civiclive.com
To:Party of Record
Subject:Party of Record/Public Comments 2022-11-23 07:40 AM(PST) Submission Notification
Date:Wednesday, November 23, 2022 7:40:53 AM
Party of Record/Public Comments 2022-11-23 07:40 AM(PST) was submitted by Guest on
11/23/2022 10:40:46 AM (GMT-08:00) Canada/Pacific
Name Value
NameFile:LUA22-000381
Gender Ms.
Name Kelli Price
Address:15700 Dayton Ave N
CityState:Shoreline, WA
Email nwsepa@ecy.wa.gov
Phone 206-594-0014
Party of Record Only
Thank you for the opportunity to provide comments on the State
Environmental Policy Act (SEPA) notice of application utilizing the optional
mitigated determination of nonsignificance (ODNS/NOA-M) process for the
WSADA Headquarter Expansion project. Based on review of the checklist
associated with this project, the Department of Ecology (Ecology) has the
following comments: 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: 1)
Develop soil remediation plan and enter into the Voluntary Cleanup Program
Comments
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.
TOXICS CLEANUP PROGRAM Jing Song, (425) 229-2565, jing.song@ecy.wa.gov
Section B Environmental Elements; subsection 7 Environmental Health: The
proposed project property is located immediately east (across Raymond
Avenue SW) of a cleanup site, Cummins Northwest Renton (Ecology facility
49562398). The Cummins Northwest Renton site received a No Further Action
(NFA) determination in 2003. However, additional data collected in 2021
indicated contamination was discovered at the Cummins Northwest Renton
site. Diesel, heavy oil, and arsenic were found in five monitoring wells installed
at the Cummins Northwest Renton site at concentrations above state cleanup
standards. Please refer to
https://apps.ecology.wa.gov/cleanupsearch/document/102089 for the data
collected at the Cummins Northwest Renton site. Due to the close proximity of
the Cummins Northwest Renton site to the project property, contaminated
may be encountered during construction of the proposed project. Please add
the contamination information in the SEPA checklist, and 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 potential contaminated groundwater or soil encountered
during excavations, including sampling, containment, and disposal at a
permitted facility. 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.
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To view this form submission online, please follow the link below:
https://rentonwa.gov/form/one.aspx?
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