Environmental during construction

Environmental compliance

All phases of development must meet WSDOT's environmental commitments by adherence to applicable laws, regulations, and agreements.  All employees are responsible for implementing relevant environmental policies and procedures to support compliance and maintain environmental stewardship.

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.
• Standard Specifications for Environmental Compliance (PDF 333 KB) shows a list of standard specifications that include an environmental component.
• Common Standard Specs for Environmental Compliance (PDF 244KB) shows a list of common environmental standard specifications relevant for WSDOT inspectors.

Report non-compliance events

Environmental non-compliant work is defined as actions that violate environmental permits or authorizations, verbal or written agreements, laws, or regulations.

Washington State Law (RCW 47.85.030) and WSDOT Policy (P 1018) requires that environmental non-compliance is self-reported.

If there is a non-compliance event, follow the Construction Environmental Compliance Assurance Policy (ECAP) in Chapter 1, SS 1-07.5, of the WSDOT Construction Manual. 

Hazardous materials and solid waste

Review Spill Prevention, Control, and Countermeasures (SPCC) Plan

The contractor prepares a project-specific SPCC Plan to prevent, report, and respond to hazardous material spills in a safe and effective manner.  The Spill Plan Reviewers Guidance (PDF 1.6MB) provides information on the SPCC Plan requirements.  Be sure to use the SPCC Plan Checklist (PDF 244KB) when reviewing spill plans.

SPCC Plan reviewers must take the Spill Plan Reviewer eLearning course available through The Learning Center (See Construction Manual SS 1-07.15).  It is recommended the course be taken every two years.

Report spills, releases, or encounters with hazardous materials

Contractors must report all environmental incidents including spills, contaminated soil, and discoveries of underground storage tanks (USTs) during construction to the Project Engineer (PE) (see Standard Specification 1-07.5(1)). The SPCC flowchart (PDF 54KB) outlines the reporting process for HazMat spill, release, or encounter.

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.

If your project encounters unknown hazardous or regulated materials, 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. 

Third party spills or releases

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

1. Call the Emergency Number and they will contact 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. If the spill is an immediate threat to human health or the environment, WSDOT personnel within their limits of expertise should take action to contain the spill until Ecology or the WSP arrive on the scene.
4. Contact the Hazardous Materials (HazMat) Manager, Pat Svoboda, Patrick.Svoboda@wsdot.wa.gov.

Refer to section 447.03(4) of the Environmental Manual for additional information on responding to third party spills.

Secondary Containment

For each spill source in the SPCC Plan, install impervious containment that holds at least 110% of the largest tank. See the Secondary Containment guidance (PDF 474KB) for containment requirements.

Remove & close underground storage tanks

The WSDOT Hazardous Materials (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 webpage to remove and permanently close an Underground Storage Tank (UST).

Dispose of contaminated soil & water

When contaminated soil or water is found before or during construction, or a leaking UST is encountered, the WSDOT PE must coordinate with a WSDOT 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 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 and it cannot be treated on site, 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 webpage 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.

Stormwater and water quality

Temporary Erosion and Sediment Control (TESC) Plan

The contractor adopts and modifies or develops a new TESC Plan to manage construction stormwater risks. Use the TESC Plan Review Checklist (PDF 340KB) and Chapter 2 of the TESC Manual when reviewing Contractor-submitted TESC Plans to confirm the plan complies with contract and permit requirements.

Ensure that TESC plan updates occur as project conditions change. See the Stormwater & Water Quality webpage, TESC Manual, and Section 8-01 of the Construction Manual for TESC Plan requirements, guidance, and forms.

Staff who design, implement, or inspect TESC Plans must take the Construction Site Erosion and Sediment Control Training every three years. Staff in permitting or environmental coordination are encouraged to take the training. See the training section on the Tools, templates & links tab of the Stormwater & Water Quality webpage. 

For Design-Bid-Build projects, the National Pollutant Discharge Elimination System (NPDES) Construction Stormwater General Permit (CSWGP) is typically transferred to the contractor before construction begins. See the Instructions for processing the CSWGP TOC form (PDF 161KB).

Site inspections and Site Log Book

The CSWGP requires site inspections, adaptive management, and a maintained Site Log Book. Use Ecology’s Construction Stormwater Site Inspection Form for inspections. See Section 4-1.5 of the TESC Manual and Section 8-01 of the Construction Manual for additional information.

CSWGP discharge sampling & reporting

Find information on how to submit monthly Discharge Monitoring Reports (DMRs) to Ecology for NPDES 402 compliance on the Final design tab of the  Stormwater & water quality webpage and Section 4-1.3 of the TESC Manual.

If sampling results exceed permit reporting triggers, report to Ecology via the Environmental Report Tracking System (ERTS) within 24 hours.

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. Record the sample data on our Sampling form (DOCX 29KB) or a similar form.

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.

Cultural and Historic Resources

All projects with ground disturbance must have an Unanticipated Discovery Plan (UDP). This plan guides construction staff on what to do if they find cultural or historic resources unexpectedly. For more information and a UDP template, visit the Cultural resources & archaeology webpage.

If archaeological monitoring is required, follow the project’s contract requirements. If you discover cultural or historic resources or human remains, stop work in the area immediately and follow the project’s UDP.

For monitoring requirements and discovery procedures, see section SS 1-07.16(4) in the Construction Manual.

Permitting

Get construction permits & approvals

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

• Section 402 NPDES CSWGP from Washington State Department of Ecology
• Section 402 National Pollution Discharge Permits – See the Stormwater & water quality webpage for more information about water quality monitoring.
• Noise variance - See Section 14 of the Traffic Noise Policy and Procedures and the Noise webpage for more information about night work and noise variance requirements.
• Water rights permit –See the Ecology Washington State Department of Ecology Water Rights webpage for more information about water usage.
• Bird and Eagle take permits –See the Birds webpage for more information about migratory bird and Bald & Golden Eagle requirements.

Modify permits & approvals

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. 

Air and noise

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. 

Noise

Noise from construction during nighttime hours (typically, 10 p.m. to 7 a.m.) is subject to local ordinances and may require a noise variance or exemption. See Chapter 446 of the Environmental Manual and Section 14 of WSDOT’s Traffic Noise Policy and Procedures for additional information.

Wetlands

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.

Fish, wildlife, and vegetation

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 invasive species

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

Fish passage monitoring

Schedule the mandatory fish passage post-construction monitoring site visit once all the conditions below are met:

• Immediately after all in-water work is complete
• the Temporary Stream Diversion (TSD) is removed
• fish exclusion is removed
• the new water crossing structure(s) are in place

Contact the Fish Passage Monitoring and Performance Coordinator. See the ‘Contacts tab’ of the Fish webpage.