From Stark
The Washington Department of Ecology announces that the agency will keep the public comment period open awhile longer on changes to the Whatcom Waterway cleanup plan.
Among other things, the change involves deposit of some contaminated sediments in the old Georgia-Pacific Corp. wastewater lagoon, once the more highly-contaminated sediment inside that lagoon has been dug out for disposal in special landfills.
Those sediments would be covered with clean material while still leaving the water deep enough for eventual construction of the Port of Bellingham’s marina inside the lagoon, although the date for completion of the marina is receding deeper into the future. Under the current plan, the lagoon cleanup is not schedule to begin until 2017.
Here is the press release from Ecology:
OLYMPIA – The Washington Department of Ecology (Ecology) is extending the public comment period on proposed changes to cleanup plans for some areas of the Whatcom Waterway site on the Bellingham waterfront.
The changes are described in a proposed amendment to a 2007 legal settlement, called a consent decree, among Ecology, the Port of Bellingham and other parties. Ecology extended the end of the public comment period on the proposed changes from April 11, 2011, to April 27, 2011, because of a procedural error in publishing notice of the comment period.
Most of the Whatcom Waterway cleanup plan will remain unchanged from the 2007 consent decree, but changes are necessary to the cleanup action in a portion of the outer waterway. Ecology received new information that indicates that dioxin and furan levels in buried marine sediment in the outer waterway are likely too high to qualify for open-water disposal as originally planned.
In response to this new information, the Port of Bellingham and its consultants developed an alternative approach for managing these materials. This alternative approach also can be applied to some other areas of the site.
Ecology and port representatives held a public meeting on the proposal on March 15 at Bellingham Technical College.
Proposed changes involve moving material from portions of the outer waterway and other areas of the site into an old waterfront industrial waste treatment lagoon after the lagoon is cleaned up according to 2007 plans. Dredged material would be contained in the lagoon under a layer of clean sediment.
The clean layer would be designed to meet state cleanup standards based on the port’s plan to open the lagoon to Bellingham Bay and convert it into a marina.
Ecology evaluated the proposed changes and confirmed that the approach would meet state cleanup requirements.
Proposed changes also include adjusting the project sequencing.
Under the proposed amendment, the site would be cleaned up in two construction phases. The first phase would include cleanup of the inner waterway, consistent with the 2007 plan. Construction of the first phase of cleanup would begin in 2012. The second phase would include cleanup of the outer waterway and the treatment lagoon with construction beginning in 2017.
The Whatcom Waterway site is more than 200 acres. It includes underwater sediment and an industrial wastewater treatment lagoon.
Contamination at the site is the result of operations dating back to the 1960s at the former Georgia-Pacific pulp and paper plant. The port acquired property within the site in 2005.
Studies conducted as part of the cleanup process showed mercury and other contaminants at the site in concentrations that exceed requirements of the state’s cleanup law, the Model Toxics Control Act, and must be addressed.
The Whatcom Waterway cleanup is expected to cost about $90 million. Ecology will reimburse up to half the port’s costs through the state’s remedial action grant program, which helps pay to clean up publicly owned sites. The state Legislature funds the grant program with revenues from a tax on hazardous substances.
The site is one of 12 cleanup sites in the Bellingham Bay Demonstration Pilot, a multi-agency collaborative effort to combine cleanup, control of pollution sources, habitat restoration and land use.
The pilot program is a major step toward restoring Puget Sound, and it is a model for other large-scale cleanup initiatives.
Submit public comments to:
Lucy McInerney, site manager
Washington Department of Ecology
3190 160th Ave. SE
Bellevue, WA 98008-5452
I smell a cover-up.
April 19, 2011
I think a marina would be nice. And I think another public use for the old GP lagoon could also be nice. It appears the Port will go ahead with their agenda for the marina. In any event, I have read the amendment flier and the idea to stick hundreds of thousands of cubic yards of carcinogenic poisonous dredgings into the lagoon after removing a like volume of clean sand seem ludicrous.
Please consider my comments about the proposed amendments to the 2007 consent decree about clean up for the outer Whatcom Waterway:
1. Since the plan picks up the dioxin and furans why not just get it out of Bellingham Bay for good? I do not agree it makes any sense to put it back into the water after going to all the trouble to lift it out.
2. Is the real reason the proposal will dump the dredged dioxin and furans poison into the existing GP lagoon that advocates of this idea think it’s cheaper? I do not agree that it is cheaper if that is the assumption. If cost feasability is the issue why are cost figures not presented for public comment? Even if I could be convinced it is cheaper to put the poisons back into the water I do not agree that the poisons should be put back into the water.
3. The report says, ‘the dredged dioxin and furans materials are not suitable as structural fill ‘for buildings or roads’. The report concludes this is the reason, then, to dump the dredged dioxin and furans materials into the existing GP lagoon. I don’t get it. Can you explain why the one thing follows the other please? Another better choice would be to put the materials on land in a non-structural situation.
4. The sludge scheduled to be removed from the existing GP lagoon, like the dredged dioxin and furans, is not suitable for use as structural fill for such things as building projects and roads and will be located upland. Why not locate the dioxin and furans at the same location as the sludge at the upland location? I believe there is room somewhere for the poisons to be located upland, whether with the sludge or separately, and like the sludge not be used as a structural material.
5. I disagree with the plan concept that an underlayment of dioxin and furans is desirable for a marina, as is proposed with this amendment. Ask anybody, “What would you prefer in the water under our boats, dioxin and furans poisons or clean sand?” Who would choose dioxin and furans poisons? I believe nobody would prefer poison. I believe everybody would prefer clean sand.
6. I believe the work proposed by this amendment will likely make the existing GP lagoon earth fill dike less laterally stable due to the removal hundreds of thousands of cubic yards of settled clean sand seabed, and resultant disruption of the base bed. The existing sand settled by time and bonded to the base bed and its mass acts as a buttress against the sides of the earth fill dike providing a lateral reaction to movement and/or slumping of the dike during an earthquake. Will the dredged spoils of dioxins and furans form a replacement mass that is an equivalent buttress? No. The proposal itself says these materials are not structurally suitable for buildings or roads.
7. The likelihood of a major earthquake and resulting tsunami activity must be carefully considered.
8. The Environmental Impact Statement for this project should be revised for the proposed changes in the amendment, and earthquake and tsunami activity possibility be addressed.
9. I agree with removal of the contaminated sludge from the existing GP lagoon and disposing of it on land at a sensible location which this amendment explains is part of the work of the original consent decree. In view of the recent events in Japan however I believe that the mass of the sludge proposed to be removed be considered and I think it would be prudent and advisable to at least add back additional clean sand or other ballast of equal mass so as not to lesson the lateral structural stability of the existing earth fill GP lagoon dike.
10. I also disagree with removal of clean sand from the bottom of the existing GP lagoon because the clean sand is a good filter and can be a better base for new undersea habitat for undersea life. Certainly clean sand is a better habitat for sea life than hundreds of thousands of yards of dioxin and furans poisons.
11. I believe the amendment is correct to remove the dioxins and furans from the outer Whatcom Waterway and to not dump them into open water as originally proposed and part of the original consent decree.
12. I agree with not using the removed dioxin and furans on land for structural fill to support roads or buildings. Who would want poison under their building or road simply because it is poison? The report implies the material has been considered and determined not strong enough for construction. I agree this is another good reason not to use it for buildings or roads, of course.
13. The dioxin and furans should best be properly disposed of on land. The first step is to purchase a site. Work should be delayed until an approved site is secured. The contaminated sludge, dioxin, and furans where re-located must be contained by a permanent basin with no seepage to adjacent soils. Ground water must be protected. The deposit must be capped to prevent leaching. The basin and cap would be a containment system and it should be designed to be maintainable or maintenance free for, say, hundreds of years.
14. I’m concerned about the real risk of a devastating Earthquake and Tsunami. The proposed amendment assumes the existing GP lagoon dike is a stable structure and a suitable ‘vessel’ that will control the sides of the proposed concentrated volume of dioxin and furans dredgings.
Would the existing lagoon dike, modified as proposed, withstand an earthquake with an epicenter within a radius of say a mile or so, at a depth of say one kilometer, and with a magnitude of say 9.5 on the Richter scale?
The existing University of Washington model predicting a plausible seismic event where all the sludge in Bellingham Bay slides off of the bay shelf and down into the deep water adjacent to Lummi Island forecasts a massive tidal wave.
So, if the proposed project goes forward as presented and there is a major seismic event and resulting tsunami with a retreat of waters as at Sendai presumably emptying the marina followed by a wave of say 45 meters in height, where then will the lagoon and its contents including fills end up? Will the hundreds of thousands of cubic yards of dioxin and furan carcinogenic poisonous fills then be part of a massive overlay of mud and debris laying throughout Bellingham?