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HomeMy WebLinkAbout201904052_ECYCommentLetter.pdf STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Northwest Regional Office  3190 160th Avenue SE  Bellevue, Washington 98008-5452  (425) 649-7000 711 for Washington Relay Service  Persons with a speech disability can call (877) 833-6341 July 30, 2019 Alex Morganroth Planning Division City of Renton 1055 South Grady Way Renton, WA 98057 Re: Sound Ford Collision Center File# PR19-000192, LUA19-000154, Ecology SEPA# 201904052 Dear Alex Morganroth: Thank you for the opportunity to provide comments on the Sound Ford Collision Center. Based on review of the State Environmental Policy Act (SEPA) checklist associated with this Project, the Department of Ecology (Ecology) has the following comments: HAZARDOUS WASTE AND TOXICS REDUCTION Kyle Masters, (425) 649-7055, kyle.masters@ecy.wa.gov Please be advised all waste streams generated at the new 850 Lind Ave SW property must be properly designated, see WAC 173-303-070 at: https://app.leg.wa.gov/WAC/default.aspx?cite=173-303-070. Designation will determine whether a waste must be managed as dangerous waste. Inadequate designation creates risks and results in improper disposal of dangerous wastes. In Washington, we use the term “dangerous waste” while the federal rules use the term “hazardous waste." Washington’s Dangerous Waste Regulations are based on the federal Resource Conservation and Recovery Act (RCRA); however, dangerous waste includes more wastes than the federal definition. For more information, including information on common types of waste, compliance tips, and links to additional publications, please visit Ecology’s automotive collision repair webpage at: https://ecology.wa.gov/Regulations-Permits/Guidance-technical-assistance/Dangerous-waste- guidance/Common-dangerous-waste/Automotive-collision-repair. Please be advised you may not transfer dangerous waste to the sister facility at 101 SW Grady Way. If you generate more than 220 pounds of dangerous waste in a month, or store on-site more than 2,200 pounds at any time, the 850 Lind Ave SW property will need an EPA/State Identification Number of its own. Alex Morganroth July 30, 2019 Page 2 TOXICS CLEANUP PROGRAM Eva Barber, (360) 407-7094, 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://fortress.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 2012 Tacoma Smelter Plume Guidance. The soil sampling results shall be sent to Ecology for review. If the project includes open space areas, contact the Technical Assistance Coordinator, Eva Barber, for assistance in soil sampling methodology within the open space area.  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 land use 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. Site design shall include protective measures to isolate or remove contaminated soils from public spaces, yards, and children’s play areas. 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 Alex Morganroth July 30, 2019 Page 2 173-350 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, Katelynn Piazza SEPA Coordinator Sent by email: Alex Morganroth, amorganroth@rentonwa.gov ecc: Rich Snyder, Sound Ford Collision Center Eva Barber, Ecology Kyle Masters, Ecology