Critical Areas Review Tech Memorandum 10.11.2022Land Services Northwest October 18, 2022
LAND SERVICES
NORTHWEST
120 STATE AVE NE PMB 190
OLYMPIA, WA 98501
360-481-4208
10/18/2022
RE: CRITICIAL AREA REVIEW FOR PARCEL#’S 64300700400 AND 64300700501
INTRODUCTION
This letter is the result of a critical area review conducted on the 10 acre parcel #64300700400 at 16330
SE RAILWAY RD Yelm, WA with the legal description of Section 19 Township 17 Range 2E Plat MCKENNA
IRRIGATEDTRACTS BLK 7 LT 4 Document 009/044 and the 4.89 acre parcel #64300700501 at 16314 SE
Railway Road Yelm, WA with the legal description of MC KENNA IRIG TRS LOT 5 BLK 7 LESS SWLY 245.18F
(Figure 1).
Land Services Northwest October 18, 2022
CURRENT CONDITIONS
Parcel #64300700400 is a relatively flat parcel that is bounded by and old rail bed and Northern Pacific
Road NW to the north, Railroad View Road NW to the south, a vacant field to the northeast and a single
family residence to the southeast. To the west is the other subject property, parcel # 64300700501.
That parcel has a single-family residence with an outbuilding for chickensin the southern half and a
vacant field to the north. There is Railroad View Road NW to the south and Northern Pacific Road NW
to the north. There is a Puget Sound Energy Transformer Power Station to the west with a stormwater
pond (Figure 2).
EXISTING INFORMATION REVIEW
In order to get a better understanding of the properties and their position of the landscape, the
following information was reviewed:
National Wetlands Inventory (NWI) Map (Appendix B)
The US Fish and Wildlife Service wetland shapefile data does not show any wetlands within 300 feet of
the property.
Thurston County Area Soil Survey, Soil Conservation Service (U.S. Department of Agriculture, 1973)
National Resource Conservation Service Shapefiles (NRCS Web Soil Survey, 2022) (Appendix C)
The NRCS Soil Survey shows the property as containing:
Spanaway gravelly sandy loam 0-3%
The Spanaway series consists of very deep, somewhat excessively drained soils that formed in glacial
outwash. They are on terraces and plains. Slopes are 0 to 15 percent. The mean annual precipitation is
about 1,270 millimeters. The mean annual temperature is about 10 degrees C.
TAXONOMIC CLASS: Sandy-skeletal, isotic, mesic Typic Humixerepts
TYPICAL PEDON: Spanaway gravelly sandy loam - fern-grass prairie. (Colors are for moist soil unless
otherwise stated.)
Oa--0 to 3 centimeters; black (10YR 2/1) highly decomposed plant material, very dark brown (10YR 2/2)
dry; mostly from grass roots and moss. (0 to 4 centimeters thick)
A--3 to 38 centimeters; black (10YR 2/1) gravelly sandy loam, very dark grayish brown (10YR 3/2) dry;
weak fine granular structure; soft, very friable, nonsticky and nonplastic; many fine roots; very high in
organic matter content, has mellow, sooty feel; 34 percent gravel; strongly acid (pH 5.4); clear smooth
boundary. (25 to 50 centimeters thick)
Bw--38 to 48 centimeters; dark grayish brown (10YR 4/2) very gravelly sandy loam, grayish brown (10YR
5/2) dry; weak fine subangular blocky structure; soft, very friable, nonsticky and nonplastic; common
fine roots; 45 percent gravel, 10 percent cobbles; moderately acid (pH 5.8); clear smooth boundary. (8
to 20 centimeters thick)
Land Services Northwest October 18, 2022
2C--48 to 150 centimeters; light brownish gray (10YR 6/2) dry; extremely gravelly sand; single grained;
loose; few fine roots; 60 percent gravel, 10 percent cobbles; slightly acid (pH 6.1).
TYPE LOCATION: Pierce County, Washington; 1.6 kilometers south of Spanaway, east of Pacific Avenue
in the SE1/4 SW1/4 section. 33, T. 19 N., R. 3 E.
RANGE IN CHARACTERISTICS: Solum thickness is 35 to 70 centimeters. The mean annual soil
temperature is 9 to 12 degrees C. These soils are usually moist but are dry in the moisture control
section for 75 to 90 consecutive days following summer solstice. The umbric epipedon is 25 to 50
centimeters thick. Rock fragments are 35 to 85 percent, with 35 to 60 percent gravel, 0 to 60 percent
cobbles and 0 to 5 percent stones
The A horizon has hue of 10YR through 5YR, value of 2 to 4 dry, and chroma of 1 or 2 moist and dry. It
has weak granular or blocky structure and is moderately acid or strongly acid.
The Bw horizon has value of 4 or 5 dry and 3 or 4 moist. It is very gravelly sandy loam, very gravelly loam
or extremely gravelly sandy loam. It has weak fine or medium blocky structure and is strongly acid to
slightly acid.
The 2C horizon has hue of 7.5YR to 2.5Y, value of 5 or 6 dry and 4 or 5 moist and chroma of 2 through 4
dry or moist. It is extremely gravelly sand or extremely gravelly loamy sand with or without thin layers of
sandy loam. It is massive or single grained and is slightly acid or neutral.
GEOGRAPHIC SETTING: Spanaway soils are on glacial outwash terraces and plains at elevations of about
30 to 150 meters. Slopes are 0 to 15 percent. These soils formed in glacial outwash. These soils are in a
maritime climate with cool, dry summers and mild, wet winters. The mean annual precipitation is 890 to
1650 millimeters. The mean annual temperature is about 10.5 degrees C. The frost-free season is 150 to
200 days
DRAINAGE AND SATURATED HYDRAULIC CONDUCTIVITY: Somewhat excessively drained; slow runoff;
high saturated hydraulic conductivity.
USE AND VEGETATION: Used for woodland, pasture, cropland, homesites and wildlife habitat. Native
vegetation is Douglas-fir, Oregon white oak, shore pine, and red alder with an understory of salal,
western brackenfern, western swordfern, scotchbroom, common snowberry, red huckleberry, Oregon-
grape, rose, creambush oceanspray, Indian plum, Solomons-seal and Idaho fescue.
Thurston County Geodata Wetland Inventory (Appendix D)
Thurston County maintains a geodatabase of wetland stream and waterbody features. These shapefiles
did not show any wetlands streams or waterbodies within 315 feet of the subject properties.
Land Services Northwest October 18, 2022
USGS 7.5 Minute Quadrangle Topographic Maps (Appendix E)
The USGS maintains topographic maps which show natural and man-made features. This map does not
show any hydrologic features within 300 feet of the subject properties.
Washington Department of Natural Resources Stream Type Map (Appendix F)
The WA Dept of Natural Resources has a map that shows stream types in accordance with the WAC 222-
16-31. This map does not show any streams or wetlands within 300 feet of the subject property.
Washington Department of Fish and Wildlife Priority Habitats and Species Database (Appendix G).
The Washington Department of Fish and Wildlife Priority Habitats and Species Mapper shows the
Townsend's Big-eared Bat and Yuma myotis. These are general polygons. The bats may feed on
macroinvertabrates in the area, or rest in the attics of the garage or the single-family homes, however
no guano or other signs of bats were found on the site during the visits.
These are general inventories of information gathered by remote sensing and a site visit was necessary
to verify the information.
RECONNAISSANCE METHODS
Land Services Northwest personnel surveyed the property on September 27, 2022 looking at plant
communities, slopes, drainage patterns while paying special attention to swales and low spots where
water might collect.
Land Services Northwest based its wetland evaluation on the routine on-site determination method
published in the 1987 Wetland Identification and Delineation Manual (Environmental Laboratory, 1987)
and the Western Mountains Valleys and Coast Region (Version 2.0) (USACE, 2010). The Wetland-
adapted plant species (hydrophytes) were evaluated as indicators of soil saturation and inundation.
Soils were excavated to 18 – 24 inches below the surface within representative test pits to evaluate soil
characteristics and hydrological conditions. The subject areas were evaluated for wetland hydrology,
including pooling, ponding, and soil saturation. Hydrological conditions were observed through surface
or soil indicators. Wetlands were rated using the current version of the Wetland Rating System for
Western Washington (Hruby, 2014). No water or signs of water were found on site
Streams were classified using WAC 222-12-32 Forest Practices and Yelm Municipal Code.
FINDINGS
No wetlands or other suspicious areas which warranted further exploration were found onsite
No streams were found on site with a bed and bank or sorted gravels signs of water flow.
No Floodways are found onsite or within 300 feet of the site.
One depressional area was found on the neighboring property which appears to be a stormwater
collection site. No water or signs of water were seen in this area and the area is populated with scotch
broom which typically is not found in wetland areas.
Land Services Northwest October 18, 2022
No other suspicious areas were found in the vicinity of the subject properties, however we, were limited
to what we could see from the property line, and aerials as we did not have permission to visit the
adjacent properties.
PROPOSED PROJECT
The project is not yet fully developed, but the memo provided by the applicant’s design engineer
indicates that
“Proposed development of the site will consist of demolition of existing structures and construction of 89
single family residences with associated roadways, utilities, stormwater management, and open space.
Stormwater management and runoff treatment for the site are proposed to be addressed through the
implementation of a bioretention facility in the northwestern portion of the site.
The subject properties drainage facilities were designed using the guidelines and requirements established
in the 2019 DOE Stormwater Management Manual for Western Washington (2019 SWMMWW) as
indicated by the City of Yelm Municipal Code.
The project is located within a critical aquifer recharge area. In order to protect groundwater from
pollution during construction, pollutants will be handles with care and disposed of through approved
methods only per the requirements of the 2019 SWMMMWW. Maintenance, fueling, and/or repair of
heavy equipment and vehicles is not anticipated to occur on site. Bulk cement and new concrete washing
or curing waters are anticipated to be present on site as pH-modifying sources. In order to protect
groundwater from these pollutants, BMP C252 (Treating and Disposing of High pH Water) of the 2019
SWMMWW will be implemented to ensure no discharge to groundwater. Additionally, concrete trucks
will not be washed out onto the ground, or into storm drains, open ditches, streets, or streams. Excess
concrete must not be dumped on-site, except in the designated concrete washout areas with appropriate
BMPs installed. In order to protect onsite soils from siltation, a lined temporary sediment pond will be
located upstream of the bioretention facility to allow for sediment to settle out of the construction runoff
prior to discharge,
REGULATORY REVIEW
The City of Yelm is in an Aquifer Recharge area covered by YMC 18.21.070 Critical aquifer recharge areas
which is covered with comments referring to the proposed development below (Comment in Italics).
A. Critical Aquifer Recharge Areas Designation. Critical aquifer recharge areas are those areas
with a critical recharging effect on aquifers used for potable water as defined by WAC 365-190-
030(2). A critical aquifer recharge area has prevailing geologic conditions associated with
infiltration rates that create a high potential for contamination of ground water resources or
contribute significantly to the replenishment of ground water.
Noted.
B. Designation of Critical Aquifer Recharge Areas. The entire city of Yelm and its urban growth
area is identified as a highly susceptible critical aquifer recharge area.
Noted.
C. Performance Standards – General Requirements..
Land Services Northwest October 18, 2022
1. Activities may only be permitted in a critical aquifer recharge area if the applicant can
show that the proposed activity will not cause contaminants to enter the aquifer and that
the proposed activity will not adversely affect the recharging of the aquifer.
The activities that will be permitted in this area would be consistent with typical residential
activities. No commercial activity is planned or expected to be associated with the residences
except for typical home based office activity business that are common these days. No
automotive repair businesses or businesses that use commercial cleaning chemicals will be
used and disposal of wastes generated by the single or multifamily residences will us typical
waste collection services.
The construction of the site will use construction bmp’s such as silt fences, straw wattles and
other stormwater BMP’s to prevent discharge of turbid waters to waters of the state using the
most recent accepted City of Yelm Stormwater Manual.
2. The proposed activity must comply with the water source protection requirements and
recommendations of the U.S. Environmental Protection Agency, Washington State
Department of Health, and the Thurston County environmental health division.
All activites that are proposed will be compliant with the water source protection requirements
and the recommendations of the US Environmental Protection Agency, Washington State
Department of Health and the Thurston County Environmental Health Division.
3. All new development, redevelopment, and small parcel development shall meet the
water quality requirements of the stormwater manual as adopted by the city of Yelm.
A Stormwater Pollution Prevention Plan will be developed that will be consistent with the most
recently adopted stowater water quality manual adopted by the City of Yelm. A memo is
attached outlining many of those features.
D. Performance Standards – Specific Uses.
1. Storage Tanks. All storage tanks proposed to be located in a critical aquifer recharge
area must comply with local building code requirements and must conform to the
following requirements:
a. Underground Tanks. All new underground storage facilities proposed for use in
the storage of hazardous substances or hazardous wastes shall be designed and
constructed so as to:
i. Prevent releases due to corrosion or structural failure for the operational life
of the tank;
Land Services Northwest October 18, 2022
ii. Be protected against corrosion, constructed of noncorrosive material, steel
clad with a noncorrosive material, or designed to include a secondary
containment system to prevent the release or threatened release of any stored
substances; and
iii. Use material in the construction or lining of the tank that is compatible with
the substance to be stored.
No underground tanks will be installed for use in the storage of hazardous
substances or hazardous wastes. No generators of toxic or hazardous wastes are
expected as the applicant proposes single family residences or multifamily
residences which do not create hazardous wastes that would need to be stored in
tanks.
b. Aboveground Tanks. All new aboveground storage facilities proposed for use in
the storage of hazardous substances or hazardous wastes shall be designed and
constructed so as to:
i. Not allow the release of a hazardous substance to the ground, ground waters,
or surface waters;
Hazardous substances will be disposed of in an environmentally responsible manner
and would not allow the release of a hazardous substance to the ground, ground
waters, or surface waters;
ii. Have a primary containment area enclosing or underlying the tank or part
thereof; and
It is not expected that any of this would be needed. No containment area would be
required as no hazardous wastes will be generated beyond the small amounts that
could be associated with a single-family residence
iii. A secondary containment system either built into the tank structure or a dike
system built outside the tank for all tanks.
No above ground tanks will be installed on site to hold or release any hazardous
substance to the ground, ground waters, or surface waters;
2. Vehicle Repair and Servicing.
a. Vehicle repair and servicing must be conducted over impermeable pads and within
a covered structure capable of withstanding normally expected weather conditions.
Land Services Northwest October 18, 2022
Chemicals used in the process of vehicle repair and servicing must be stored in a
manner that protects them from weather and provides containment should leaks
occur.
It is not expected that vehicle repair or servicing would be done at any of the newly
created residences as it is not a typical residential activity,
b. No dry wells shall be allowed in critical aquifer recharge areas on sites used for
vehicle repair and servicing. Dry wells existing on the site prior to facility
establishment must be abandoned using techniques approved by the state
Department of Ecology prior to commencement of the proposed activity.
No Vehicle repair or servicing will be conducted onsite. No dry wells for vehicle repair or
servicing will be required for these activities. No known dry wells are onsite. If any are
found they will be abandoned using techniques approved by the state Department of
Ecology
3. Use of Reclaimed Water for Surface Percolation or Direct Recharge. Water reuse
projects for reclaimed water must be in accordance with the adopted water or sewer
comprehensive plans that have been approved by the State Departments of Ecology and
Health.
a. Use of reclaimed water for surface percolation must meet the ground water
recharge criteria given in RCW 90.46.010(10) and 90.46.080(1). The State Department
of Ecology may establish additional discharge limits in accordance with
RCW 90.46.080(2).
No reclaim water for surface percolation will be done or generated onsite.
b. Direct injection must be in accordance with the standards developed by authority
of RCW 90.46.042. (Ord. 995 § 12 (Exh. A), 2015).
No direct injection will be conducted on site. If for some reason direct injection would be
necessary, it would be done in accordance with the standards developed by authority of
RCW 90.46.042.
CONCLUSION
The subject properties were reviewed using the onsite determination method for wetlands looking for
hydrologic features or signs of wetlands. No wetlands or other critical areas were found during the
literature review or onsite survey. The area lies in a Critical Aquafer Recharge area. BMP’s and project
design will maintain water quality and no discharges of untreated water to waters of the state are
expected.
Land Services Northwest October 18, 2022
LIMITATIONS
This report was created with care and best professional judgment using the current best available
science, but the report is subject to interpretation by local state and federal regulators who have the
final regulatory authority on critical areas and their boundaries. No recommendations or suggestions
should be undertaken without regulatory approval of this report.
Land Services Northwest October 18, 2022
Appendix A – PHOTOGRAPHS
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Appendix B – USFWS NATIONAL WETLAND INVENTORY
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APPENDIX C – NRCS SOIL SURVEY FOR THURSTON COUNTY
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APPENDIX D – THURSTON COUNTY WETLAND, STREAM AND WATERBODY SHAPEFILES
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APPENDIX E – USGS TOPOGRAPHIC MAP
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APPENDIX F – WADNR FOREST PRACTICES STREAM TYPE MAP
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APPENDIX G – WASHINGTON DEPARTMENT OF FISH AND WILDLIFE PRIORITY HABITATS AND SPECIES MAP
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Appendix H – Ground and Surface Water Protection Memo
Yelm Railway Road Groundwater Protection Memo
The Yelm Railway Road project is located at 16330 Railway Road SE in Yelm, Washington on two
parcels. The total project site area is 648,608 square feet (14.89 acres). Residential properties surround the
site to the northeast and southeast. Puget Sound Electric owns the parcel to the southwest of the project
site which houses a transformer, while properties to the northwest of the site are designated for industrial
use.
Proposed development of the site will consist of demolition of existing structures and construction of 89
single family residences with associated roadways, utilities, stormwater management, and open space.
Stormwater management and runoff treatment for the site are proposed to be addressed through the
implementation of a bioretention facility in the northwestern portion of the site.
The subject properties drainage facilities were designed using the guidelines and requirements established
in the 2019 DOE Stormwater Management Manual for Western Washington (2019 SWMMWW) as
indicated by the City of Yelm Municipal Code.
The project is located within a critical aquifer recharge area. In order to protect groundwater from
pollution during construction, pollutants will be handles with care and disposed of through approved
methods only per the requirements of the 2019 SWMMMWW. Maintenance, fueling, and/or repair of
heavy equipment and vehicles is not anticipated to occur on site. Bulk cement and new concrete washing
or curing waters are anticipated to be present on site as pH-modifying sources. In order to protect
groundwater from these pollutants, BMP C252 (Treating and Disposing of High pH Water) of the 2019
SWMMWW will be implemented to ensure no discharge to groundwater. Additionally, concrete trucks
will not be washed out onto the ground, or into storm drains, open ditches, streets, or streams. Excess
concrete must not be dumped on-site, except in the designated concrete washout areas with appropriate
BMPs installed. In order to protect onsite soils from siltation, a lined temporary sediment pond will be
located upstream of the bioretention facility to allow for sediment to settle out of the construction runoff
prior to discharge,
Land Services Northwest October 18, 2022