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HomeMy WebLinkAboutC_ECYCommentLetter_221123 STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Northwest Region Office PO Box 330316, Shoreline, WA 98133-9716 • 206-594-0000 November 23, 2022 Andrew Van Gordon, Associate Planner Department of Community & Economic Development City of Renton 1055 South Grady Way, 6th Floor Renton, WA 98057 Re: WSADA Headquarter Expansion File# LUA22-000381/D12-045, Ecology SEPA# 202205648 Dear Andrew Van Gordon: 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: Andrew Van Gordon November 23, 2022 Page 2 • 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 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: Andrew Van Gordon November 23, 2022 Page 3 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. Sincerely, Kelli Price SEPA Coordinator Sent by email: Andrew Van Gordon, avangordon@rentonwa.gov ecc: Eva Barber, Ecology Jing Song, Ecology