Ecology_Redondo Heights Frontage No Action for TSP Needed`
Brian Davis 5/18/2022
City of Federal Way
Community Development Department
33325 8th Ave S
Federal Way, WA 98003
Re: Redondo Heights TOD – Site C, File No. 21-104848, Ecology SEPA No. 202202324
Dear Brian Davis,
Thank you for the opportunity to provide comments on the Redondo Heights multi-use development project. The
project property is located at 27614 Pacific Hwy S in Federal Way, Washington on two King County parcels
(7204800188 and 7204800190). The proposed project is located in an area affected by arsenic and lead in the soil
resulting from the air emissions from the old Asarco Smelter in Ruston, Washington.
Mancong Lin (Mancong) proposed to develop this parcel into a mixed-use development. Ecology recommended
soil sampling to evaluate the levels of arsenic and lead in the soil prior to developing the property. Ecology also
recommended enrollment in the Voluntary Cleanup Program (VCP) with Ecology if lead, arsenic, or other
contaminants are found at concentrations above Model Toxics Control
Act (MTCA) Method A cleanup levels.
Adapt Consulting (Adapt) conducted soil sampling on the property on
behalf of Mancong on July 1, 2021. Adapt collected 27 soil samples from
22 locations on the property. They collected 22 soil samples from 0 to
6 inches below ground surface (bgs) and five samples from 6 to 12
inches bgs (Figure 2).
Adapt submitted the samples to
Friedman and Bruya analytical
laboratory in Seattle, Washington
for an analysis of arsenic and lead
concentrations with an
Environmental Protection Agency
Method 6020B. Adapt submitted
the results of the soil sampling to
Ecology for a review 1.
1 Adapt Consulting. Limited Phase II Environmental Site Assessment Screen, Redondo Heights Apartments Property. July 14,
2021.
THE MTCA SOIL CLEANUP LEVELS:
Average arsenic ≤ 20 mg/kg
Average lead ≤ 250 mg/kg
AND
Maximum arsenic ≤ 40 mg/kg
Maximum lead ≤ 500 mg/kg
Figure 1. Vicinity Map
Project Location
Ecology reviewed the report and concluded that the average soil concentrations were below the cleanup level of
20 milligrams per kilogram (mg/kg) for arsenic and 250 mg/kg for lead (Table 1). Similarly, no samples exceeded
the maximum allowable concentration for a single soil sample of 40 mg/kg for arsenic or 500 mg/kg for lead.
Table 1. Summary of Soil Sampling
Sample Depth
(feet)
Arsenic mg/kg (EPA 6020B) Lead mg/kg (EPA 6020B)
Minimum Maximum Average Minimum Maximum Average
0-6 1.4 17.1 7.1 3.1 233 50.1
6-12 1.5 9.4 4 3.3 33.9 11.7
MTCA Levels 40 207.1 500 250
Ecology does not recommend this property enter the
Voluntary Cleanup Program. No soil remediation for the
contamination associated with the Tacoma Smelter Plume is
needed for this property.
Please note, this not a “No Further Action” determination for
the property, since the property was not enrolled into the VCP.
Best regards,
Eva Barber
Technical Assistance Coordinator
Toxics Cleanup Program
Southwest Regional Office
Washington State Department of Ecology;
Phone: 360-999-9593
Figure 2. Approximate Locations of Soil Samples