DOE Comment on MDNS 001O
STATE OF WASHINf.TON
DEPARTMENT OF ECOLOGY
PO Box 4]l]5 • Olympia, Washington YNSn4-J]ZS •(360) 407fi30t1
April 10, 2007
Mr. Grant Beck YOUr BddtesS
Community Development Director _ ,'' ~ I IS in the
City of Yelm ~ ~~- ~ ,{ Rlisqually
Po Box 479 jA_,. _ _ ` J. watershed
Yelm, WA 98597 _~„_
Dear Mr. Beck:
Thank you for [he opportunity [o comment on the mitigated determination of nonsignificance for [he
Crystal Springs Planned Uni[ Development project (SEPA No. OS-0770) located on Crystal Springs Road,
north of Yelm Avenue West (SR S l0) as proposed by Pacific Frontier, LLC, c/o Petra Engineering. The
Department of Ecology (Ecology) reviewed the environmental checklist and has [he following
comment(s):
FLOODPLAINS: Kevin Farrell (360) 407-7253
Dae [o regional flooding concerns within both the City of Yelm and adjacent un-incorporated areas,
we would enwurage the City to proactively require an analysis of potential impacts [o flooding
downstream of this proposal It is suggested that an analysis of downstream culverts also be
conducted [o ensure the flood carrying capaciTy of Yelm Creek will not be diminished.
SHORELANDS: Sarah Lukas (360) 407-7459
The applicant's proposal appears to place a substantial amount of fill in and adjacent to the Floodplain
of Yelm Creek. This landfilling may no[ be wnsiscent with the guidance in [he Yelm Shoreline
Master Program (SMP). The SMP states in the Landfilling Section, General Regulation 5, that,
"Prior to issuance of any permit for landfilling in or along a stream, it must be demonstrated that the
fill will not cause any detrimental change in flood elevations, or restrict stream flow or velocity. No
fill which adversely affects the capabiliTy of a stream to carry 100-year flood Flows will be allowed."
What assurance has the applicant demonstrated [ha[ these impacts will not result from the proposed
placement of fill along Yelm Creek?
TOXICS CLEANUP: Lisa Pearson (360) 407-6261
If contamination is currently known or suspected during construction, testing of [he potentially
contaminated media must be conducted. If contamination of soil or groundwater is readily visible, or
is revealed by testing, Ewlogy must be notified. Contact the Environmental Report Tracking System
Coordinator at the Southwest Regional Office a[ (360) 407-6300. For assistance and information
about subsequent cleanup and to identify the type of testing that will be required contact Mc Bob
Warren with the Toxics Cleanup Program at (360) 407-6361.
WATER QUALITY: Margaret Hill (360) 407-0246
Any discharge of sediment-laden runoff or other pollutants to waters of the state is in violation of
Chapter 90.48 RCW, Water Pollution Control, and WAC 173-201A, Water Quality Standards for
Surface Waters of the State of Washington, and is subject to enforcement action.
~~ CO
April 10, 2007
Page 2 of 3
Erosion control measures must be in place prior to any clearing, grading or construction. These
control measures must be effective [o prevent stormwater runoff from carrying sail and other
pollutants into surface water or storm drains that lead [o waters of [he state. Sand, silt, clay particles,
and soil will damage aquatic habitat and are considered to be pollutants.
Proper disposal of construction debris must be on land in such a manner [hat debris cannot enter Yelm
Creek, buffers, wetlands and wetland buffers or cause water quality degradation of state waters.
Soil in stockpiles should be stabilized or protected with sediment-[rapping measures to prevent soil
loss. All exposed areas of final grade or areas that are not scheduled for work, whether at final grade
or otherwise, shall not remain exposed and un-worked for more than two days, between October 1
and April 30. Between May 1 and September 3Q no soils shall remain exposed and un-worked for
more than 7 days.
Clearing limits and/or any easements or required buffers should be identified and marked in [he field,
prior to the start of any clearing, grading, or construction. Some suggested methods are staking and
flagging or high visibility fencing.
A permanent vegetative cover should be established on denuded areas at final grade if they are not
otherwise permanently stabilized.
Properties adjacent to the site of a land disturbance should be protected from sediment deposition
through the use of buffers or other perimeter controls, such as filter fence or sediment basins.
All types of sediment control, such as sediment ponds or traps, should be constructed as a first step in
grading and be made Tunctional before any upslope disturbance takes place.
Provision should be made to minimize the tracking of sediment by wnstmction vehicles onto paved
public roads. If sediment is deposited, it should be cleaned every day by shoveling or sweeping.
Water cleaning should only be done after the area has been shoveled out or swept.
After completion of this project, stornwa[er runoff will likely contain increased levels of grease, oils,
sediment, and other debris. Appropriate source controls, such as good housekeeping should be used
to prevent these substances from entering stormwa[er. Treatment devices should also be used to
further reduce polluted runoff.
During constructiou, all releases of oils, hydraulic fluids, fuels, other petroleum products, paints,
solvents, and other deleterious materials must be contained and removed in a manner that will prevent
their discharge to waters and soils of the state. The cleanup of spills should take precedence over
other work on the site.
The SEPA checklist indicates that coverage under a Construction S[ormwater National Pollution
Discharge Elimination System (NPDES) permit will be obtained for [his project. The permit is
required because the site has pre-construction discharge (to Yelm Creek and wetlands) and because
the project will dis[mrb one acre or more soil surface area. The permit application form, called a
Notice of Intent, is available on Ecology's websi[e aC
htto'// ecy a eo /oroerams/ -q/s[ormwa[er/construct on/#Applieation. Applicants are
encouraged [o submit completed forms and to publish public notices more than 38 days before the
planned start of [he project to avoid delays.
April L0, 2007
Page 3 of 3
Ecology's comments are based upon [he information provided with the SEPA checklist. As such, they do
not constitute an exhaustive list of [he various authorizations that must be obtained or legal requirements
[hat must be fulfilled in order to carry out the proposed action.
If you have any questions or would like to respond [o these comments please contact the appropriate
reviewing staff listed above.
Department of Ecology
Southwest Regional Office
(AW: 07-2416)
cc: Kevin Farrell, SEA
Charles Gilman, HQ/WQ
Margaret Hill, WQ
Sarah Lukas, SEA
Lisa Pearson, TCP
Joyce Smith, HQ/WQ
Jeff Mclnnis, Petra Engineering, LLC (Applicant)
lack Long, Pacific Frontier