Environmental during construction

Report non-compliance events

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

Report spills, releases, or encounters with hazardous materials

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 (PDF 139KB) 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 Spill Prevention Control and Countermeasures Plan SPCC flowchart (PDF 54KB) outlines the reporting process for HazMat spill, release, or encounter.

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

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

1. Call the Washington State Patrol (WSP). WSP will report the spill to Ecology.
2. Gather personal information from the third party (name, license plate, insurance info, etc.).
3. Contact the Hazardous Materials (HazMat) Manager, Pat Svoboda, Patrick.Svoboda@wsdot.wa.gov

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

Manage environmental commitments

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

• Environmental Manual Chapter 590: Incorporating environmental commitments into contracts (PDF 335KB)
• Environmental Manual Chapter 600: Construction (PDF 279KB)
• Commitment Tracking System (CTS) web application - track and manage environmental commitments. Find instructions on how to use CTS in the application’s help menu.

Modify permits & approvals

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.

Prepare a final Water Quality Monitoring & Protection Plan

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.

Get construction permits & approvals

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

• Section 402 National Pollution Discharge Permits – Stormwater & water quality
• Noise variance - Noise
• Water rights permit – Wetlands & other waters
• Bird and Eagle take permits – Birds

Monitor water quality

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.

Manage invasive species

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

Ensure air quality standards are met

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 Handling Fugitive Dust from Construction Projects Guide (PDF 8.66MB) from the Associated General Contractors of Washington provides additional information on fugitive dust best management practices. 

Remove & close underground storage tanks

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.

Dispose of contaminated soil & water

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:

• Sediment Management Standards (PDF 836KB)  – Sediment sampling and testing regulations defined by Washington State Department of Ecology (Ecology).
• Dredged Material Evaluation and Disposal Procedures User Manual – Standards defined by the US Army Corps of Engineers If your project involves dredging.

Dispose of dangerous waste

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. 

Asbestos disposal

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:

• An accredited abatement contractor with certified supervisors and workers performs the abatement of ACM. 
• The contractor properly stores, transports and disposes of ACM waste generated during construction in a permitted landfill.

Treated wood disposal

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.

Prepare a Letter of Map Revision for floodplains

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. 

Close out permits & approvals

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:

• Section 404 and Section 10 discharge permits from the US Army Corps of Engineers
• Hydraulic Project Approvals from the Washington State Department of Fish & Wildlife
• Endangered Species Act (ESA) consultations with the US Fish & Wildlife Service and National Marine Fisheries Service (NMFS)

NMFS Programmatic projects

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:

• FHWA - Cindy Callahan, Cindy.Callahan@dot.gov
• Corps - the Corps liaison assigned to the project
• Other – check with the federal lead agency

Manage compensatory mitigation sites

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

Prepare as-built reports

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.

Initiate monitoring

Submit the monitoring start-up form (DOCX 41KB) 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:

• Site and zone boundaries
• Performance standards
• Problems encountered during construction
• Site access and on-site safety

Throughout the monitoring period:

• Review the Monitoring Manager’s proposed fieldwork schedule to coordinate management and monitoring activities. (For example, weed spraying shouldn’t be conducted just before monitoring.)
• Send documentation of management activities to the monitoring team for annual monitoring reports.
• Respond to feedback from the monitoring team regarding management issues.
• Review draft monitoring reports.