Bellingham Bay Cleanup: Death of Alternative J - Chapter 2

As noted in Chapter 1, Bellingham Bay Cleanup Planning 15 Years and Counting - Chapter 1, Georgia Pacific had selected an approved cleanup alternative called Alternative J in 2004 for cleaning contaminated sediments in Bellingham Bay and the Whatcom Waterway. Alternative J was derailed when the Port Of Bellingham acquired the GP property and proposed using the aerated sediment basin (ASB) as a marina. Because of that decision, the Port needed to develop a new cleanup plan. 

Sediment Cleanup and Soil Cleanup are not the same

Environmental cleanup is dictated by the contaminant, the media in which the contaminant is found and the guiding principal of protection of human health and the environment. The cleanup levels required for sediment in the aquatic environment is much more restrictive 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 a 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's proposed cleanup alternative was to cleanup the sediments in the Whatcom Waterway to a minimum cleanup level of 0.59 ppm. Again this plan was abandoned when the Port of Bellingham took over the property.

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 (ppm). 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 run off or ground water 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. These restrictions typically will require Ecology to be notified if any excavation will be done on the site.    

Current levels of mercury at the waterfront

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, these mercury levels in waterway sediments will require cleanup as they are in an aquatic setting.

GP ASB Lagoon: Sampling done in 2004 showed mercury levels similar to the concentrations in the waterway with an outlier of 20 ppm. If the lagoon is treated as an upland site, the cleanup level would be 24 ppm and it would be unlikely that cleanup for mercury would be required. However, if the ASB is used as a marina sediment cleanup will be required. 

GP 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 ground water 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.  

ASB or Marina, Upland or Aquatic

Once the Port acquired the GP site, the Port argued to Ecology and stated publicly that the ASB is aquatic. If it’s aquatic, it would be considered contaminated and would require either a cleanup or capping. Ecology shoreline staff maintained that the ASB in its current configuration as a treatment basin not connected to the waters of the state is an upland. However, because the Port proposes converting the ASB to a marina, aquatic standards would then have to be applied before the ASB could be opened up to the bay as a marina.

When Georgia Pacific proposed using the ASB as a disposal site for the contaminated sediments excavated from the bay and the waterway as part of the Alternative J Cleanup, 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”. In addition, Ecology said this regarding the toxicity and future land use in regards to the ASB site: “Soil/sediment concentrations to be confined in the ASB (lagoon) under this alternative (as proposed by GP) would be below MTCA (Model Toxic Control Act) direct soil contact criteria for unrestricted land use”.

In other words, Ecology was stating that if the ASB was used as a disposal site as proposed by GP in Alternative J, the ASB site could be used for any purpose, including residential.

But the Port did not want GP's preferred cleanup Alternative J, because Alternative J meant the ASB would not be a available for use as a marina. The Port would need to develop a new preferred cleanup plan. The Port faced a public relations problem: The preferred Alternative J cleanup plan was the best plan for getting the cleanest bay and waterway cleanup.

Things Get Weird

As the Port began the process of developing a new cleanup plan things started getting weird. The GP cleanup plan Alternative J that had been declared as the preferred cleanup plan by Ecology was made out to be not so great. Editorials in the Bellingham Herald 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) even though Ecology had clearly stated otherwise in evaluating the preferred alternative J.

Remember Ecology had concluded “Soil/sediment concentrations to be confined in the ASB (lagoon) under this alternative (as proposed by GP) would be below MTCA (Model Toxic Control Act) direct soil contact criteria for unrestricted land use”.  How could this statement be construed to "dirtiest place on the bay" and "toxic waste dump"?, when Ecology was stating that the site would meet unrestricted land use standards for direct soil contact. How did the editorials get things so wrong? That is a question I never could get answered.

It was a weird time in Bellingham.

As the Port moved towards developing a new cleanup plan they began suggesting capping the contaminated sediments in the bay and waterway with imported clean sand. They also suggested that mercury contamination at the mill site, an area that was proposed as a redevelopment area, would be left buried in the ground.

For citizens that were told that the preferred cleanup plan, Alternative J, would be create a "toxic waste dump", proposals for in place burial in the bay, waterway and at the mill site seemed to be a contradiction. Citizens concerned about mercury contamination left in the bay and on the site were told in a Bellingham Herald editorial that mercury was heavy and sinks. The desire to turn the ASB into a marina meant that Alternative J had to be killed.

Next: The Port of Bellingham's New Cleanup Plan