Bay Cleanup
Facts should shape policy
By Dan McShane in the 8/23/06 issue of Cascadia Weekly
Before tackling policy decisions, it helps to first assemble and agree on the facts.
Cleanup decisions on the waterfront have been complicated by a lack of understanding of the basic facts and by the false statements made regarding waterfront contamination issues. Most prominently, the oft-repeated statement that the lagoon is the most contaminated site on the waterfront certainly calls for a close look at the data and a better understanding of cleanup standards.
Different cleanup standards
Environmental cleanup is dictated by the contaminant, the media in which the contminat is found and the guiding principal of protection of human health and the environment. For mercury, a main contaminant at the G-P site, there are much stricter cleanup levels required for sediment in the aquatic environment than for soil on land. The cleanup levels in sediment in an aquatic environment have typically been on the order of 0.5 parts per million (ppm) or less for mercury, depending on the variety of biological actions and chemistry. This was the approximate level of cleanup for two other sites in Puget Sound with mercury-contaminated sediments. Georgia-Pacific was planning a cleanup of sediments in the Whatcom Waterway to a minimum cleanup level of 0.59 ppm.
The cleanup levels for mercury in soil in an upland setting for unrestricted land use (houses, parks, schools) are typically on the order of 24 parts per million. Again, this is dependent upon soil chemistry, land use and potential contaminant pathways. For upland sites used as industrial sites, the cleanup criteria for direct contact becomes much less stringent at 1,100 ppm and assumes little direct contact with soil. If the site has surface water that is impacted by soil contamination either through direct runoff or groundwater flow, or if the soil contacts drinking water, a more intensive cleanup may be required to 2 ppm.
It is possible to leave contamination at higher levels buried beneath the site as long as the buried contamination does not pose a risk to human health or the environment—that is, as long as it stays put. If contamination above the unrestricted land use level is left in place either on the ground surface or below, land use deed restrictions are required to be placed on the property.
Current levels of mercury
Whatcom Waterway: Currently mercury is in sediments in the Whatcom Waterway at, for the most part, less than 5 ppm with a high of 12 ppm. Hence, the mercury levels in waterway sediments will require cleanup as they are in an aquatic setting. [The log pond has mercury in sediment as high as 153 ppm.]
GP Lagoon: Much has been said about toxicity of the Georgia-Pacific Lagoon. Sampling done in 2004 shows mercury levels there similar to the concentrations in the waterway with an outlier of 20 ppm. However, because the lagoon is an upland site, 24 parts per million are allowed.
G-P Mill Site: There are sites at the waterfront with significant concentrations of mercury such as the Caustic Groundwater Plume Area with mercury as high as 12,000 ppm. Contaminated groundwater is also present beneath portions of the mill site. Any areas of the mill site not cleaned up to the unrestricted land use standards will require deed restrictions. As long as contaminated ground water remains on site, long-term monitoring will be required. Due to the proximity of the mill site to a sensitive environment, any contamination left in place will require monitoring to ensure it is not leaving the site and impacting the environment of the bay.
The Lagoon
During the past few years, the Port has argued to Ecology and stated publicly that the lagoon is aquatic. If it's aquatic, it would be considered contaminated and would require either a cleanup or capping. Ecology firmly maintains that the lagoon is an upland. When Georgia-Pacific proposed using the lagoon as a disposal site for the contaminated sediments in the bay and the waterway, Ecology wrote this: "In this instance, the ASB (lagoon) is considered to be an upland as it was legally converted to a landlocked lagoon or pond and is not a shoreline of the state."
Many have called Georgia-Pacific's proposal of using the lagoon as a confined disposal facility a "toxic waste landfill." Ecology said this regarding the toxicity and future land use: "Soil/sediment concentrations to be confined in the ASB (lagoon) under this alternative (as proposed by GP) would be below MTCA direct soil contact for unrestricted land use." In other words, that means that the lagoon could be used any purpose, including residential.
It may sound surprising to read that the lagoon may beat or even exceed Ecology's cleanup standards. We've all been told otherwise again and again. Since at least 2004, newspaper editorials in the Bellingham Herald have described the lagoon as the "dirtiest place in the bay" (Editorial December 2004 and July 2006) or as a "toxic waste dump site." (Editorial August 2006.) That's simply false.
Policy Decisions
We need to first get the facts on the table and reject efforts to misinform the public. Then, with the facts in hand, we can consider the other factors that are considered in cleanup decisions. Such factors as future land use, future land use values and the availability of tax dollars both locally and from the state and federal government as well as community values all play a role.
The key policy decision in determining the extent and the cost of cleanup is a land use decision that centers on the lagoon. If the lagoon is converted from an upland to a marine environment as the Port proposes, it will certainly need to be cleaned. Currently, the estimate of that cleanup is more than $38 million. It also changes the cleanup plan. Georgia-Pacific, in consultation with their consultants, made a corporate policy decision to favor removing the contaminated sediment permanently from the waterway, instead of placing the sediment in a buried underwater site at the end of Cornwall Avenue. GP's proposal, called Alternative J, was a plan to vacuum dredge contaminated sediments from the bay and the waterway and deposit them in the lagoon. At the time it was believed it would result in a better cleanup of the aquatic environment at less cost. The plan was supported by the Department of Fish and Wildlife and the Department of Natural Resources.
The Port prefers to convert the lagoon to a marina and follow a different alternative to clean up the waterway. That policy decision to convert an upland site to an aquatic one comes with a prices tag of a least $38 million for cleanup alone. It also means more contaminated sediments would be capped in a portion of the waterway and that sediment cleanup and removal from elsewhere in the waterway and other sites around the Bay would cost more due to disposal costs.
Half of those cleanup costs are proposed to be covered by State grants. That leads to an interesting policy question: Should State grants for environmental cleanup be directed toward a project where the landowner's decision to create a large boat marina triggers a cleanup requirement? This is a policy decision that State leaders will need to decide and defend.
Dan McShane is a geologist with nearly 20 years of geologic and environmental consulting experience. He serves on the Whatcom County Council.
Facts should shape policy
By Dan McShane in the 8/23/06 issue of Cascadia Weekly
Before tackling policy decisions, it helps to first assemble and agree on the facts.
Cleanup decisions on the waterfront have been complicated by a lack of understanding of the basic facts and by the false statements made regarding waterfront contamination issues. Most prominently, the oft-repeated statement that the lagoon is the most contaminated site on the waterfront certainly calls for a close look at the data and a better understanding of cleanup standards.
Different cleanup standards
Environmental cleanup is dictated by the contaminant, the media in which the contminat is found and the guiding principal of protection of human health and the environment. For mercury, a main contaminant at the G-P site, there are much stricter cleanup levels required for sediment in the aquatic environment than for soil on land. The cleanup levels in sediment in an aquatic environment have typically been on the order of 0.5 parts per million (ppm) or less for mercury, depending on the variety of biological actions and chemistry. This was the approximate level of cleanup for two other sites in Puget Sound with mercury-contaminated sediments. Georgia-Pacific was planning a cleanup of sediments in the Whatcom Waterway to a minimum cleanup level of 0.59 ppm.
The cleanup levels for mercury in soil in an upland setting for unrestricted land use (houses, parks, schools) are typically on the order of 24 parts per million. Again, this is dependent upon soil chemistry, land use and potential contaminant pathways. For upland sites used as industrial sites, the cleanup criteria for direct contact becomes much less stringent at 1,100 ppm and assumes little direct contact with soil. If the site has surface water that is impacted by soil contamination either through direct runoff or groundwater flow, or if the soil contacts drinking water, a more intensive cleanup may be required to 2 ppm.
It is possible to leave contamination at higher levels buried beneath the site as long as the buried contamination does not pose a risk to human health or the environment—that is, as long as it stays put. If contamination above the unrestricted land use level is left in place either on the ground surface or below, land use deed restrictions are required to be placed on the property.
Current levels of mercury
Whatcom Waterway: Currently mercury is in sediments in the Whatcom Waterway at, for the most part, less than 5 ppm with a high of 12 ppm. Hence, the mercury levels in waterway sediments will require cleanup as they are in an aquatic setting. [The log pond has mercury in sediment as high as 153 ppm.]
GP Lagoon: Much has been said about toxicity of the Georgia-Pacific Lagoon. Sampling done in 2004 shows mercury levels there similar to the concentrations in the waterway with an outlier of 20 ppm. However, because the lagoon is an upland site, 24 parts per million are allowed.
G-P Mill Site: There are sites at the waterfront with significant concentrations of mercury such as the Caustic Groundwater Plume Area with mercury as high as 12,000 ppm. Contaminated groundwater is also present beneath portions of the mill site. Any areas of the mill site not cleaned up to the unrestricted land use standards will require deed restrictions. As long as contaminated ground water remains on site, long-term monitoring will be required. Due to the proximity of the mill site to a sensitive environment, any contamination left in place will require monitoring to ensure it is not leaving the site and impacting the environment of the bay.
The Lagoon
During the past few years, the Port has argued to Ecology and stated publicly that the lagoon is aquatic. If it's aquatic, it would be considered contaminated and would require either a cleanup or capping. Ecology firmly maintains that the lagoon is an upland. When Georgia-Pacific proposed using the lagoon as a disposal site for the contaminated sediments in the bay and the waterway, Ecology wrote this: "In this instance, the ASB (lagoon) is considered to be an upland as it was legally converted to a landlocked lagoon or pond and is not a shoreline of the state."
Many have called Georgia-Pacific's proposal of using the lagoon as a confined disposal facility a "toxic waste landfill." Ecology said this regarding the toxicity and future land use: "Soil/sediment concentrations to be confined in the ASB (lagoon) under this alternative (as proposed by GP) would be below MTCA direct soil contact for unrestricted land use." In other words, that means that the lagoon could be used any purpose, including residential.
It may sound surprising to read that the lagoon may beat or even exceed Ecology's cleanup standards. We've all been told otherwise again and again. Since at least 2004, newspaper editorials in the Bellingham Herald have described the lagoon as the "dirtiest place in the bay" (Editorial December 2004 and July 2006) or as a "toxic waste dump site." (Editorial August 2006.) That's simply false.
Policy Decisions
We need to first get the facts on the table and reject efforts to misinform the public. Then, with the facts in hand, we can consider the other factors that are considered in cleanup decisions. Such factors as future land use, future land use values and the availability of tax dollars both locally and from the state and federal government as well as community values all play a role.
The key policy decision in determining the extent and the cost of cleanup is a land use decision that centers on the lagoon. If the lagoon is converted from an upland to a marine environment as the Port proposes, it will certainly need to be cleaned. Currently, the estimate of that cleanup is more than $38 million. It also changes the cleanup plan. Georgia-Pacific, in consultation with their consultants, made a corporate policy decision to favor removing the contaminated sediment permanently from the waterway, instead of placing the sediment in a buried underwater site at the end of Cornwall Avenue. GP's proposal, called Alternative J, was a plan to vacuum dredge contaminated sediments from the bay and the waterway and deposit them in the lagoon. At the time it was believed it would result in a better cleanup of the aquatic environment at less cost. The plan was supported by the Department of Fish and Wildlife and the Department of Natural Resources.
The Port prefers to convert the lagoon to a marina and follow a different alternative to clean up the waterway. That policy decision to convert an upland site to an aquatic one comes with a prices tag of a least $38 million for cleanup alone. It also means more contaminated sediments would be capped in a portion of the waterway and that sediment cleanup and removal from elsewhere in the waterway and other sites around the Bay would cost more due to disposal costs.
Half of those cleanup costs are proposed to be covered by State grants. That leads to an interesting policy question: Should State grants for environmental cleanup be directed toward a project where the landowner's decision to create a large boat marina triggers a cleanup requirement? This is a policy decision that State leaders will need to decide and defend.
Dan McShane is a geologist with nearly 20 years of geologic and environmental consulting experience. He serves on the Whatcom County Council.