NOTES
If you write Ecology, please let us know about it at info@bbayf.org. We're tracking comments.
Read the Whatcom Waterway RI/FS & EIS by going here. (Online documents lack the appendices.) You can also go to Ecology's office on Railroad Street to pick up a free CD-ROM. Compare the 2006 FS & EIS to the 2002 FS & EIS—they're both available at the link above. Tip: Closely examine the data tables.
If you write Ecology, please let us know about it at info@bbayf.org. We're tracking comments.
Read the Whatcom Waterway RI/FS & EIS by going here. (Online documents lack the appendices.) You can also go to Ecology's office on Railroad Street to pick up a free CD-ROM. Compare the 2006 FS & EIS to the 2002 FS & EIS—they're both available at the link above. Tip: Closely examine the data tables.
Healthy Bay Principles
Bellingham Bay Foundation
Principle 1
A more permanent, protective cleanup plan is required instead of the preferred remedial alternatives. More dredging and removal of contaminated sediments is needed, plus conservatively designed in situ capping for any areas of remaining contamination. Minimizing the amount of residual mercury contamination left in the waterway and using thicker caps will reduce uncertainties in the long-term performance of the cleanup actions. Thicker caps are consistent with a navigation channel, habitat improvements and land use consistency.
Objectives:
• To permanently remove the toxic legacy of mercury from the aquatic environment, as is indicated by the first three goals of the Bellingham Bay Demonstration Pilot: Goal 1-Human Health and Safety: Implement actions that will enhance the protection of human health. Goal 2-Ecological Health: Implement actions that will protect and improve the ecological health of the bay. Goal 3-Protect and Restore Ecosystems: Implement actions that will protect, restore, or enhance habitat components making up the bay's ecosystem.
• To increase confidence that mercury exposure from remaining contaminated sediments, resulting from both anticipated or unforeseen events and processes, will be effectively controlled for the long term.
• To increase the availability of healthy habitat without the risks associated with biomagnification. The goal is to develop a cleanup approach that will lead to a sustained healthy environment for the future, not just a temporary control of pollution.
• To ensure that marine life and people eating fish and shellfish are safe from mercury, a persistent and bioaccumulative contaminant.
Options for remedy and disposal:
The objective of removing more mercury from the waterway can be accomplished in several ways. Technical factors should be evaluated to select the most appropriate and beneficial approach.
Hydraulic dredging involves less resuspension of sediments than mechanical dredging and is therefore preferred where it can be used effectively. Debris, logs, and shoreline features can interfere with hydraulic dredging. It also requires a contained space for dewatering the dredged sediments. Either hydraulic or mechanical dredging can be used to remove contaminated sediments. Possible approaches include:
a. Mechanically dredge areas of contaminated sediments, especially the inner Whatcom Waterway where mercury concentrations are comparatively elevated, and send the dredged material to an approved Subtitle D landfill. Dredge the ASB sludges, dewater them as required, and send them to an approved Subtitle D landfill, or cap them in place within the ASB.
b. Hydraulically or mechanically dredge areas of contaminated sediments, route them to the ASB, and cap both the dredged materials and the ASB sludges in place.
c. Dredge the ASB sludges, dewater them as required, and send them to an approved Subtitle D landfill. Hydraulically dredge areas of contaminated sediments and route them to the ASB for dewatering, followed by removal and transport to an approved Subtitle D landfill. Initial removal of the ASB sludges is likely to damage or remove the existing bentonite liner. If technical evaluations determine that a liner is needed to use the ASB for temporary dewatering of hydraulically dredged sediments, reinstall a liner.
d. Determine dredging depths and areas based on the principle of minimizing residual mercury contamination in sediments rather than primarily on navigation channel requirements. Incorporate significantly thicker caps (6 feet or more) in areas of remaining sediment contamination to increase protectiveness. Thicker caps can also be integrated into habitat improvements and consistent waterway/nearshore development options, while reducing the amount of mercury left in the waterway.
Principle 2
An effective, long-term monitoring plan must be part of the cleanup actions, consistent with the persistence of mercury in the marine environment. Long-term monitoring should continue as long as necessary to detect mercury releases or impacts in the marine environment and to evaluate the continued effectiveness of containment measures (capping). Realistic costs for extended monitoring programs and required cap maintenance and repair actions, or other future cleanup actions, need to be included in the evaluation of alternatives. Monitoring costs should be proportionate to the contamination left behind (i.e. areas that are more contaminated need more monitoring).
Objectives:
• To confirm continued protection of human and ecological health from potential adverse impacts from residually contaminated sediments.
• To identify trends in environmental measures that could indicate ongoing releases and exposures, thereby providing an early warning system for potential future adverse impacts.
• To identify degradation in containment systems (caps) early enough to plan and carry out maintenance or remedial actions, or additional cleanup measures, to prevent releases of contaminants to the marine environment.
• To properly account for long-term monitoring costs as well as future maintenance and repair costs and avoid bias in the comparisons among alternatives.
Options for remedy and disposal:
a. Recognize that the scope and duration of monitoring activities should reflect the conditions after cleanup actions are completed. Leaving more mercury in the waterway, and relying on thinner caps, increases future uncertainties and risks and should be accompanied by an enhanced monitoring program.
b. Long term means long term. Given the persistence of mercury in the environment, the monitoring program must address a timeframe of at least decades.
c. An effective monitoring program should address multiple components of the environment. Among other things, it should monitor potential sources of contaminants to the waterway (for example, uplands ground water and surface water runoff), the mobility and flux of mercury from contaminated sediments into and through engineered or natural caps, bioaccumulation of mercury through the food web to indicator and consumed species, ecological communities in areas of residual contamination, and the physical condition and continued effectiveness of caps.
d. The number of locations monitored and the frequency of monitoring must be sufficient to provide representative information and to meet the objective of timely identification of trends or changes in conditions.
e. Criteria should be established within the monitoring plans that identify trigger levels for contingent actions. When evaluations of collected monitoring data show that such trigger levels have been exceeded, modifications to the monitoring program or the cleanup actions should be initiated. Trigger levels could be set, for example, based on upward trends in surface sediment mercury concentrations, trends in fish or shellfish tissue levels, or cap erosion and thinning.
f. Event-based triggers should also be incorporated into the monitoring plans. For example, modifications of the monitoring program may be justified after record storms or large earthquakes, especially if they approach or exceed assumptions used in design studies.
g. Monitoring isn't something that can just be considered after a cleanup approach is selected. It is an important factor for the comparison of alternatives within the Feasibility Study. Differences among the alternatives in monitoring costs-and equally critical, differences in the life-cycle costs for maintaining the effectiveness and protectiveness of caps-must be appropriately considered in comparing alternatives. Removing more mercury and using thicker caps reduces the likelihood of future deferred costs to maintain protectiveness, a cost benefit in comparison to other alternatives.
Principle 3
All Model Toxics Control Act funds should be prioritized for remediation of contamination to protect human and ecological health. With cost disproportionality a criterion for comparisons among alternatives, it is vital that funds go toward providing long-term protectiveness above all else.
Bellingham Bay Foundation
Principle 1
A more permanent, protective cleanup plan is required instead of the preferred remedial alternatives. More dredging and removal of contaminated sediments is needed, plus conservatively designed in situ capping for any areas of remaining contamination. Minimizing the amount of residual mercury contamination left in the waterway and using thicker caps will reduce uncertainties in the long-term performance of the cleanup actions. Thicker caps are consistent with a navigation channel, habitat improvements and land use consistency.
Objectives:
• To permanently remove the toxic legacy of mercury from the aquatic environment, as is indicated by the first three goals of the Bellingham Bay Demonstration Pilot: Goal 1-Human Health and Safety: Implement actions that will enhance the protection of human health. Goal 2-Ecological Health: Implement actions that will protect and improve the ecological health of the bay. Goal 3-Protect and Restore Ecosystems: Implement actions that will protect, restore, or enhance habitat components making up the bay's ecosystem.
• To increase confidence that mercury exposure from remaining contaminated sediments, resulting from both anticipated or unforeseen events and processes, will be effectively controlled for the long term.
• To increase the availability of healthy habitat without the risks associated with biomagnification. The goal is to develop a cleanup approach that will lead to a sustained healthy environment for the future, not just a temporary control of pollution.
• To ensure that marine life and people eating fish and shellfish are safe from mercury, a persistent and bioaccumulative contaminant.
Options for remedy and disposal:
The objective of removing more mercury from the waterway can be accomplished in several ways. Technical factors should be evaluated to select the most appropriate and beneficial approach.
Hydraulic dredging involves less resuspension of sediments than mechanical dredging and is therefore preferred where it can be used effectively. Debris, logs, and shoreline features can interfere with hydraulic dredging. It also requires a contained space for dewatering the dredged sediments. Either hydraulic or mechanical dredging can be used to remove contaminated sediments. Possible approaches include:
a. Mechanically dredge areas of contaminated sediments, especially the inner Whatcom Waterway where mercury concentrations are comparatively elevated, and send the dredged material to an approved Subtitle D landfill. Dredge the ASB sludges, dewater them as required, and send them to an approved Subtitle D landfill, or cap them in place within the ASB.
b. Hydraulically or mechanically dredge areas of contaminated sediments, route them to the ASB, and cap both the dredged materials and the ASB sludges in place.
c. Dredge the ASB sludges, dewater them as required, and send them to an approved Subtitle D landfill. Hydraulically dredge areas of contaminated sediments and route them to the ASB for dewatering, followed by removal and transport to an approved Subtitle D landfill. Initial removal of the ASB sludges is likely to damage or remove the existing bentonite liner. If technical evaluations determine that a liner is needed to use the ASB for temporary dewatering of hydraulically dredged sediments, reinstall a liner.
d. Determine dredging depths and areas based on the principle of minimizing residual mercury contamination in sediments rather than primarily on navigation channel requirements. Incorporate significantly thicker caps (6 feet or more) in areas of remaining sediment contamination to increase protectiveness. Thicker caps can also be integrated into habitat improvements and consistent waterway/nearshore development options, while reducing the amount of mercury left in the waterway.
Principle 2
An effective, long-term monitoring plan must be part of the cleanup actions, consistent with the persistence of mercury in the marine environment. Long-term monitoring should continue as long as necessary to detect mercury releases or impacts in the marine environment and to evaluate the continued effectiveness of containment measures (capping). Realistic costs for extended monitoring programs and required cap maintenance and repair actions, or other future cleanup actions, need to be included in the evaluation of alternatives. Monitoring costs should be proportionate to the contamination left behind (i.e. areas that are more contaminated need more monitoring).
Objectives:
• To confirm continued protection of human and ecological health from potential adverse impacts from residually contaminated sediments.
• To identify trends in environmental measures that could indicate ongoing releases and exposures, thereby providing an early warning system for potential future adverse impacts.
• To identify degradation in containment systems (caps) early enough to plan and carry out maintenance or remedial actions, or additional cleanup measures, to prevent releases of contaminants to the marine environment.
• To properly account for long-term monitoring costs as well as future maintenance and repair costs and avoid bias in the comparisons among alternatives.
Options for remedy and disposal:
a. Recognize that the scope and duration of monitoring activities should reflect the conditions after cleanup actions are completed. Leaving more mercury in the waterway, and relying on thinner caps, increases future uncertainties and risks and should be accompanied by an enhanced monitoring program.
b. Long term means long term. Given the persistence of mercury in the environment, the monitoring program must address a timeframe of at least decades.
c. An effective monitoring program should address multiple components of the environment. Among other things, it should monitor potential sources of contaminants to the waterway (for example, uplands ground water and surface water runoff), the mobility and flux of mercury from contaminated sediments into and through engineered or natural caps, bioaccumulation of mercury through the food web to indicator and consumed species, ecological communities in areas of residual contamination, and the physical condition and continued effectiveness of caps.
d. The number of locations monitored and the frequency of monitoring must be sufficient to provide representative information and to meet the objective of timely identification of trends or changes in conditions.
e. Criteria should be established within the monitoring plans that identify trigger levels for contingent actions. When evaluations of collected monitoring data show that such trigger levels have been exceeded, modifications to the monitoring program or the cleanup actions should be initiated. Trigger levels could be set, for example, based on upward trends in surface sediment mercury concentrations, trends in fish or shellfish tissue levels, or cap erosion and thinning.
f. Event-based triggers should also be incorporated into the monitoring plans. For example, modifications of the monitoring program may be justified after record storms or large earthquakes, especially if they approach or exceed assumptions used in design studies.
g. Monitoring isn't something that can just be considered after a cleanup approach is selected. It is an important factor for the comparison of alternatives within the Feasibility Study. Differences among the alternatives in monitoring costs-and equally critical, differences in the life-cycle costs for maintaining the effectiveness and protectiveness of caps-must be appropriately considered in comparing alternatives. Removing more mercury and using thicker caps reduces the likelihood of future deferred costs to maintain protectiveness, a cost benefit in comparison to other alternatives.
Principle 3
All Model Toxics Control Act funds should be prioritized for remediation of contamination to protect human and ecological health. With cost disproportionality a criterion for comparisons among alternatives, it is vital that funds go toward providing long-term protectiveness above all else.
