Environmental during construction | WSDOT

2022-07-02 16:05:30 By : Ms. Sarah Zhu

Find out how to comply with environmental laws, regulations, and policies during construction.

If there is a non-compliance event, follow the Construction ECAP procedure in Chapter 1, SS 1-07.5, of the WSDOT Construction Manual. 

Use Ecology’s Report a spill of oil or hazardous materials website to report spills. For WSDOT projects, the contractor should fill out the Spill Report Form (DOCX 32KB) and send it to Ecology.

Contractors must report all environmental incidents including spills, contaminated soil, and discoveries of underground storage tanks (UST) during construction to the Project Engineer (PE). The Regulatory Reporting Requirements Flow Chart (PDF 111 kb) outlines the reporting process for HazMat spill, release, or encounter.

If your project encounters unknown hazardous or regulated materials, contact the Hazardous Materials (HazMat) Lead, Pat Svoboda, Pat.Svoboda@wsdot.wa.gov.

If a third party, like the traveling public, spills hazardous materials into your project area:

Check all the permit and approval conditions for additional notification requirements to other regulatory agencies if your project spills, releases, or encounters hazardous materials.

Use the following resources to track and manage commitments during construction:

If there is a change in the design, timing of work, or impacts from a project, you may need to modify your permits and approvals. If a change in the project occurs, refer to each discipline on the Environmental guidance webpage in the 'Final design' tab.

Before work begins and if your project received an Individual Section 401 Water Quality Certification (WQC) from Ecology, have the contractor prepare a final Water Quality Monitoring & Protection Plan. The contractor should use the draft WQMPP you prepared to get the WQC during final design. Find guidance on how to prepare a WQMPP on the Stormwater & water quality webpage.

Find information on how to apply for permits commonly received during construction on the following webpages:

Follow the Monitoring guidance for in-water work (PDF 692KB) and the project’s 401 monitoring plan, if applicable, to monitor water quality for in-water work. Follow the means and methods in our Temporary Erosion & Sediment Control Manual to monitor water quality for discharges from upland work. Record the sample data on our Sampling form (DOCX 29KB) or a similar form. Find information on how to submit monthly Discharge Monitoring Reports (DMRs) to Ecology for NPDES compliance on the Stormwater & water quality webpage.

Find information on how invasive species are managed during construction on the Roadside development & facilities webpage.

Projects in King, Kitsap, Pierce, and Snohomish counties must follow the Memorandum of Agreement with Puget Sound Clean Air Agency – Fugitive Dust (PDF 22KB). Projects in all other areas of the state should use the same best management practices to control dust. The Guide to Handling Fugitive Dust from Construction Projects (PDF 862 KB) from the Associated General Contractors of Washington provides additional information on fugitive dust best management practices. 

The WSDOT HazMat Program or a qualified contractor must follow the Department of Ecology’s Permanent closure instructions and submit the required forms from their Underground storage tank closures website  to remove and permanently close a UST.

When contaminated soil or water is found before or during construction, or a leaking underground storage tanks (USTs) is encountered, the WSDOT PE must coordinate with a WSDOT Hazardous Materials (HazMat) specialist to determine if the site is a Models Toxics Control Act (MTCA) cleanup site. Reporting requirements depend on the severity of the contamination and land ownership.

Contaminated soil or water must be sampled to determine if it can be reused or must be disposed of. Refer to the following documents if your project needs soil or sediment characterization or sampling:

If testing showed that your project has dangerous waste, fill out the Dangerous Waste Site Identification Form to apply for a RCRA Site ID Number.

Use Ecology’s Dangerous Waste Annual Report to submit annual dangerous waste reports to Ecology by March 1 of each year.

See Ecology's Business Hazardous Waste website for additional information about dangerous waste. 

If there are asbestos containing materials (ACM) in the project area, notify local clean air agencies and Washington State Department of Labor & Industries prior to ACM abatement and demolition. See Ecology’s Washington clean air agencies contact information.

Check with PE to verify that:

If your project needs to dispose of treated wood, contact the HazMat Program. The contractor must dispose of creosote or other types of treated wood materials at a lined permitted landfill. In rare cases, creosote treated wood may be recycled; refer to Ecology’s Treated Wood Exclusion information to determine if your creosote treated wood can be reused.

If the project requires a LOMR, after construction is finished and the as-built survey is completed, use the as-built survey to complete prepare the submittal documents for FEMA and the local agency. 

Check your permit conditions to see if you need to close out the permit when construction is complete.

Common permits and approvals that require a close-out action:

If you had a programmatic ESA consultation with NMFS, email the project completion form (PCF) from the database to the liaison assigned to your project.  Cc the Fish & Wildlife Program Manager, Jeff Dreier, Jeff.Dreier@wsdot.wa.gov and the federal lead:

Use the information below once your project completes construction of a compensatory mitigation site.

The compensatory mitigation site as-built report serves as a baseline for managing and monitoring the site. The report has different, less stringent requirements than the engineered As-Built Plans.

Show the restoration efforts with photos. Note if the final mitigation or construction work final product is different from the original plan and explain why in the reports. Find out how to prepare as-built reports in Part 2: Developing Mitigation Plans, Section 3.6.1, of the Wetland Mitigation in Washington State (PDF 1.7MB).

The plan sheets and drawings may be as simple as the original permit drawings with clear and legible hand-written notations showing the changes. It is not necessary to prepare engineered drawings for the permit as-built report.

Submit the monitoring start-up form (DOCX 39KB) and supporting documents to Sean Patrick, Sean.Patrick@wsdot.wa.gov, headquarters Wetlands program Monitoring Manager, by January of the first year of required monitoring.

Coordinate with the headquarters wetland monitoring team to schedule a site visit early in the year to discuss:

as recorded by WSDOT and partners in 2020 and 2021.

to our monitoring program in 2021 to help offset climate change impacts.

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