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