Wednesday, April 29, 2009

Check out this Week's Cascadia Weekly

Tim Johnson has written an excellent article about waterfront redevelopment. You can find the article on page 8. It's titled, "Eve of Destruction."

This week's Gristle is also good!

Thanks Tim!

http://www.cascadiaweekly.com/

Tuesday, April 28, 2009

Proposed Grant and Loan Funding for Water Quality Improvement and Protection Projects, including Federal Stimulus Money

To assist in efforts to implement the U.S. American Recovery and Reinvestment Act of 2009, the Washington Department of Ecology has reopened its application cycle for the Washington State Water Pollution Control Revolving Fund.

The lists are for the Centennial Clean Water Program, the federal Clean Water Act, Section 319 (Non-Point Source Fund) and the Washington State Water Pollution Control Revolving Fund, including recovery funds for FY 2010.

Ecology hosted a public meeting on April 24th at the Pierce County Library.

DOE is accepting public comments from April 17, 2009 through 5 pm, May 1, 2009.

Comments should be sent to Jeff Nejedly, DOE Water Quality Program jnej461@ecy.wa.gov or Fax: (360) 407-7151.

Congratulations to Whatcom County for proposing the following projects!

$184,524 Upper Silver Beach Creek Comprehensive Water Quality Improvement Project

$213,106 Whatcom County Water Quality Improvement Loan

$250,000 Whatcom Conservation District - Best Management Practices for Water Quality planning and cost sharing

Additional Information

Recommended Water Project List

Washington Recovery web site

Unfortunately, the City of Bellingham and Port of Bellingham are not on the list.

:(

Monday, April 27, 2009

Waterfront Funding?

This morning, the Washington State Legislature adjourned having completed its scheduled 105 day legislative session.

What happened with waterfront funding? It's not in this year's state budget.

However, the 2009-11 conference committee transportation document included a recommendation to modify the Burlington Northern railroad track on the Georgia Pacific site.

Initially, (2004) the project was proposed because trains must slow down at a sharp curve on the existing line at the Georgia Pacific plant.

The initial proposed project scope states the project will make minor modifications to the track in order to allow for a faster passenger train speed.

The preliminary engineering phase began on 7/1/2004. The end date was 6/30/2005.

The current project scope reads: the mainline of BNSF Railway track currently runs through a sharp curve at a Georgia Pacific plant. This project will relocate a 3/4 mile section of the track. This will allow the site to be redeveloped for recreational, residential and commercial uses.

It appears that this is a classic example of political spin.

To start, the project is proposed to increase the speed of trains through Bellingham. Then, the City and Port want to locate 3,000 people on the Waterfront and all of a sudden, the rail modification will enhance property values and allow recreational, residential and commercial development.

The end result is the same. We have trains moving faster through Bellingham population zones.

I'm not sure how this project increases our quality of life...but I bet Burlington Northern is supporting it!

Prior expenditures

Before 2007 ---$47 thousand

2007-2009 --- $448 thousand

2009 -2011--- $0

2011- 2013 ---$0

2013 -2015 ---$5 million

Total $5,495 million

http://fiscal.wa.gov/FRViewer.aspx?Rpt=Transportation+Projects+List

Sunday, April 26, 2009

Toxic Contamination --- A Ticking Time Bomb across this Nation

March 3, 2008: The Washington Post printed an article by Governor Christine Gregoire and Senator Maria Cantwell.

Apparently, some elected officials are conscientious enough to read toxicity reports and grasp the concept that toxic waste is a serious public health hazard.

Here's a link to the article.

A Toxic Time Bomb in the Northwest Buried in President Bush's proposed budget for next year is a story of broken promises. It's a story that puts our nation's honor -- and our environment, economy and families -- on the line.

____________________________________

If the City and Port partnership need money for the waterfront - clean it up.

Federal and state economic stimulus dollars will not be spent to develop paved over toxic waste dumps.

A broken thermometer on the floor of a classroom requires a Haz Mat Team to clean it up -- and the Port and City want to put hundreds of people on a property that has a minimum of 12 tons of mercury buried on it?

Across this nation, from New Jersey to the state of Washington, local governments and emergency response personnel are discovering that neglected toxic waste is a public health hazard.

Elizabeth New Jersey's story: http://www.time.com/time/magazine/article/0,9171,948856,00.html

The residents of this city should demand that the City and Port set up a trust fund to pay for future clean up projects.

Saturday, April 25, 2009

Toxic Release Inventory (TRI) for GP and other Bellingham Industries

There is nothing glamorous about EPA Toxic Release Inventory (TRI) reports.

Nevertheless, it is important for a community to know about toxic contamination that is/was released into the air, water and land where our children attend school and where we all live, work and play, regardless of social class distinctions, income or education.

Over the years, Georgia Pacific (West) released tons of toxic contaminants when it manufactured pulp and other products at the Bellingham facility.

Perhaps a talented Huxley student will take the data provided below and insert it into a single spread sheet so the public (and our elected officials) can tabulate the total toxic releases from 1988 on.

The EPA reports toxic chemical releases in pounds unless otherwise stated. Dioxin and Dioxin compounds are reported in grams.

According to the Department of Ecology, the Port of Bellingham has not completed a full inventory of the Georgia Pacific site or compiled a complete list of the toxic chemicals buried on the former G.P. site.

To date, we know that there is 12 tons of mercury buried on the site at a place called the Chemfix.

Please note that Georgia Pacific did not report Dioxin or Dioxin compound releases generated from the pulp process - since the amount of dioxin and dioxin like compounds are/were considered a "trade secret." Hence, dioxin releases into the ground, air and water were not reported. However, the reports do acknowledge dioxin and dioxin compound releases from Oeser Company.

It has been estimated that 3 ounces of Dioxin can kill in excess of a million people. http://onlineethics.org/cms/7016.aspx

EPA tutorial (How to use the site and information posted on the site): http://www.epa.gov/tri/triexplorertutorial/index.html

*The electronic EPA TRI files for Georiga Pacific in Bellingham begin in 1988 - please note the Chlorine (Chlor Alkali) Plant began operations in 1965.

EPA TRI Explorer Reports - TRI # 98225GRGPC300WL

1988 - http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1988&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1989
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1989&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1990 - http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1990&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1991
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1991&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1992
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1992&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1993 - http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1993&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1994
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1994&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1995
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1995&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1996
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1996&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E41&fld=E42&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51A&fld=E51B&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1997
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1998&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E41&fld=E42&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51A&fld=E51B&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1998
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1998&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E41&fld=E42&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51A&fld=E51B&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

1999
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=1999&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E41&fld=E42&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51A&fld=E51B&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2000
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2000&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E41&fld=E42&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51A&fld=E51B&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2001
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2001&tab_rpt=1&fld=AIRLBY&fld=E1&fld=E2&fld=E3&fld=E4&fld=E41&fld=E42&fld=E5&fld=E52&fld=E53&fld=E54&fld=E51A&fld=E51B&fld=TSFDSP&fld=TSFDSP&fld=m10&fld=m41&fld=m62&fld=potwmetl&fld=m71&fld=m72&fld=m73&fld=m79&fld=m90&fld=m94&fld=m99&fld=RELLBY&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2002
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2002&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2003
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2003&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2004
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2004&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2005
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2005&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2006 - http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2006&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

2007
- http://www.epa.gov/cgi-bin/broker?view=ZPFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=&city=&spc=&zipcode=98225&zipsrch=yes&chemical=_ALL_&industry=ALL&year=2007&tab_rpt=1&fld=RELLBY&fld=TSFDSP&_service=oiaa&_program=xp_tri.sasmacr.tristart.macro

Friday, April 24, 2009

Georgia Pacific West Upland Cleanup

Breaking news: The Georgia Pacific West site and a notice of the Agreed Order negotiations for remediation and cleanup will be in the next issue of the Department of Ecology Site Register. The document will be available for public review in June.

Ecology acknowledged in an e-mail that the former G.P. site has not been fully investigated nor remediated.

On April 13 and again on April 20, 2009, the Mayor told council and members of the public that it was urgent for the council to adopt the Framework Plan in order to ensure that state and federal funding for the partnership between the Port and City remains intact.

But a call to the Governor's office reveals that funding to move the railroad tracks on the waterfront was not restored by Mayor Pike, as allegedly claimed earlier in the month, nor is the railroad project currently included in the state Budget.

Nor is there any confirmation that Washington's federal delegation has made any financial commitments to the City or Port.

Why the urgency?

What's going on?










Puget Sound Stormwater Map shows enormity of Stormwater Problem

UW GIS students produced a map of all the public storm drains carrying pollutants into Puget Sound.

"This map shows the enormity of the stormwater problem which impacts most of Puget Sound," said Bruce Wilshart, Policy Director for People for Puget Sound. "It demonstrates that we need significant funding to address the problem."

The new GIS map can be downloaded at the People for Puget Sound website: http://pugetsound.org/programs/policy/stormwater

Stormwater related pollutants and stressors havee been identified by scientists as the most important water quality problem in the Puget Sound Basin.

Thank you, People for Puget Sound!

:)

Corporate, Governmental and Fatal Error?

In 1977, The Washington State Department of Ecology documented that 12 tons of mercury are buried in a landfill at Georgia Pacific's Chemfix site.

The Chemfix project was carried out without notification to the Department of Ecology, as a means of disposing approximately 1,500,000 gallons of mixed liquid and solid wastes that had accumulated in a storage pond of the Chlorine Plant. With a mercury concentration of about 0.17 percent, the 7,000 ton sludge deposit contains approximately 12 tons of mercury.

Meanwhile, local government is rushing forward to plan street grids and master plans without the slightest regard for the health hazards buried at the site. On April 13th, the Mayor informed the city that state and elected officials are partnering with the City and ready to commit funds to develop the site.

On Monday, April 20th, the Port of Bellingham and the City voted to accept a framework plan for the Bellingham Waterfront that includes the beginnings of a street grid configuration and other assumptions for the waterfront master plan.

No public comment was allowed.

The respective councils decided that they can solicit public input later.

The decision to adopt a master plan can only be reversed by a vote of both councils.

It is unthinkable that our local elected officials are rushing forward to spend millions of tax dollars to develop a site that is indisputably an agency documented landfill for deadly chemicals without so much as the benefit of a public discussion of the health hazards associated with developing the property.

Neither the Port or the City has indicated that they are willing to clean the site to residential standards. Yet, they propose locating WWU and residential buildings on the site.

More frightening, the Port's purchase and sales agreement prohibits Georgia Pacific from discussing potential or existing contamination that is on the property.

Apparently, Bellingham is comprised of residents who have been conditioned not to fear large toxic chemical dumps that present potential adverse health effects to the community.

Granted, the renovation of abandoned industrial sites can help communities reclaim property that would otherwise be unproductive. But the desire to "rush forth and develop" without the benefit of adequate studies does nothing to protect citizens from contamination.

Sadly, what follows will be a series of follies by local government that will threaten the health of thousands of students, residents and workers.

The City will have to penetrate existing caps in order to construct roads, stormwater sewers and drains, and to drill (set) deep pilings in order to protect structures from potential liquefaction during an earth quake.

In New York, the cost of the Love Canal waste dump is still being documented.

Many of the long term health effects due to exposure to the chemicals buried on the site are not yet known.

People say that there is a silver lining in every dark cloud. If any good came out of Love Canal, it is a public and governmental awareness that America has a serious toxic waste problem.

But it remains to be seen if Bellinghamsters have learned anything from the horrors that took place at chemical dumps like Love Canal.

The genetic mutations and birth defects will survive indefinitely, the legend will live on in history and public policy books, but who knows how long the lesson will be remembered?

In the end, the Hooker Chemical Company, despite its many warnings to the community about the hazards of development, paid for the bulk of the remediation.

And still, the citizens of Bellingham do not fear the adverse health effects of toxic chemicals and heavy metals.

A dark shadow is cast over this town.


Wednesday, April 22, 2009

Issues surrounding clean up of the former G.P. Site

1) According to DOE, Georgia Pacific drafted the 1994 RI/FS without Ecology oversight. In the Phase II Proposed Agreed Order, Ecology proposes to use Georgia Pacific's 1994 RI/FS, with the Department of Ecology's review.

Under the proposed Agreed Order, Ecology will release G.P. from liability for specific contaminants that may be subsequently discovered at the chlor-alkali plant site.

Why would the Department of Ecology enter into an agreement to release the potential liable party from cleanup responsibility for contamination it created?

2) The Port and Ecology are seeking approval to dump a portion of dredged materials from the Whatcom Waterway at the Bellingham Bay or Rosario Open Water Disposal Site.

Materials dumped at open water disposal sites are not controlled or contained. A better choice would be an approved upland toxic waste dump or a Confined Aquatic Disposal site that can be tested and monitored.

3) Across the nation, Brownfield re-development studies have demonstrated that it is very difficult for agencies and potentially liable parties to adequately assess site contamination.

What may initially appear to be a straight forward cleanup may under calculate the amount of contamination, resulting in higher cleanup costs.

Higher clean up costs can result in project delays and increased construction costs.

4) The greatest challenge for the assessing the level of contamination on the G.P. uplands is determining the actual amount of soil contamination; as levels of contamination are not uniform throughout the site.

We already know that 12 tons of mercury is buried in the Chemfix. Hence, we need to determine how much more mercury and other hazardous chemicals are hidden in the soil and groundwater; and, what health hazards they may represent to college students, workers, and proposed residents on the site?

The DOE has this site listed as a "5" on a scale of "1 to 5," with "5" being a low hazard site. I'd love to hear the state's explanation for the low rating on a site that contains at the minimum, 12 tons of mercury!

5) Traditionally, real estate market conditions play an integral role in the dynamics of the sales agreement. In hot markets, the seller is at an advantage.

This advantage, according to a 2009 DOE study, often extends to erasing clean up liability, even if the seller is the party that contributed to the contamination. (No wonder the Port doesn't support public ownership). They don't want to be liable for future claims or clean up costs!

It appears that the Port of Bellingham intends to sell the property "as is" and require indemnification from the buyer. Not only does this create a disadvantage for potential buyers, it can also create a public health hazard for members of the community who will be working or living in an environment while clean up and development takes place over the next 20 to 30 years.

When markets slow, some sellers will take some responsibility for cleanup but many others will sit on their site until market conditions improve again.

I would like this project to be successful. But successful redevelopment depends on responsible governing and clean up.

The City and Port have indicated that they are willing to invest up to $250 million in public infrastructure development for this site. I wonder, are they willing to invest half that amount in clean up? How about a quarter of that amount?

2009 WA Department of Ecology Study on Brownfield reclamation and re-development: http://www.ecy.wa.gov/pubs/0909043.pdf

Georgia Pacific West Corporation Chlor-Alkali Plant Cleanup

Remedial Investigation/Feasibility Study - Phase Two Proposed Agreed Order
(TCP Pub # 02-09-048)


The state of Washington Department of Ecology and the Georgia Pacific Corporation have proposed, under terms of the Model Toxics Control Act (MTCA Chapter 70.105D RCW), to enter into an agreed order. An Agreed Order is a legal document formalizing an agreement between Ecology and potentially liable persons (PLP's), to ensure that the proposed cleanup activities are conducted according to methods and standards prescribed under MTCA and other applicable laws and regulations.


Under the proposed Agreed Order, the corporation would conduct a remedial investigation and a clean up feasibility study on the chlor-alkali plant area at the pulp and paper mill complex in Bellingham. After satisfactory completion of the clean up, Ecology would release the corporation from liability for specific contaminants that may subseqently be discovered at the chlor-alkali plant site.

Ecology invites you to evaluate the proposed Agreed Order. We welcome your comments about the proposal through September 13, 2002. The box at the right lists where to read a copy of the draft agreed order, as well as where to submit written or spoken comments.

Site Background

In 1965, Georgia Pacific built a chlor alkali plant in the Bellingham Washington pulp and paper mill. The plant's function was to produce chlorine and sodium hydroxide (caustic) for use in bleaching and pulping wood fiber.

Process description

Chlorine and caustic were produced at the plant using the DeNora mercury cell process. Chlorine gas was generated electrolytically from a saturated solution of sodium chloride (brine). The mercury cells were rectangular steel troughs having a slight downward slope. Mercury flowed through the closed loop cell and decomposer, producing chlorine and caustic. The mercury and brine NaCI flowed parallel through the cell (the brine floated on top of the mercury). In each cell, the mercury acted as a flowing cathode, while the anodes consisted of titanium metal.

Chlorine evolved at the anodes and was extracted from the cell as a gas. As the chlorine evolved from the brine, sodium amalgamated with the mercury, leaving the cell and traveling to a decomposer. Having passed through the cell, the brine was stripped of any residual chlorine and returned to the brine saturator to be restarted with salt.

The mecury/sodium amalgam was continuously treated in the decomposer. In the decomposer the mercury acted as an anode, liberating sodium which reacted with water to form sodium hydroxide (caustic). Hydrogent gas was liberated at the cathode. The mercury was then pumped back into the cell to repeat the process. At the inlet and outlet ends of the cells the mercury was covered with a water bath to prevent volatilization at these points. The entire cell was kept at a negative pressure to prevent the loss of chlorine gas.

Page 2

Plant Closure and Cleanup

Georgia Pacific West Corporation closed the chlor alkalki plant during the summer of 1999. Planned remediation of the plant site was to occur in two phases. The first phase was conducted under an Ecology Agreed Order (DE TC99 1035) governing the shut down, decommissioning, and demolition of the the plants' processing machinery and building. That Phase of the project is complete.

The current proposed Agreed Order, phase two, will be used to direct a remedial investigation and feasibility study (RI/FS). The RI/FS will include sampling and testing of the soils and ground water on the site to identify the types and extent of contamination. The feasibility study will consider an array of containment and treatment methods and determine the best cleanup scenario for the property.

What will be done in Phase II?

In 1994 Georgia Pacific Corporation submitted an Independent Remedial Investigation and Feasibility Study (RI/FS) for the chlor-alkali plant site. The 1994 RI/FS was completed without Ecology review and input. The phase two proposed Agreed Order would have Ecology review and would require Georgia Pacific to take the following actions at the plant site to complete the 1994 RI/FS:

Submit, within 45 days, a sampling plan that completes characterization of the site. After Ecology approval, complete sampling and use final soil and groundwater analysis to determine both the area and vertical extent of mercury contamination in soil at the site.

Submit, within 45 days, a sampling plan that initiates further investigation of the Chemfix mercury sludge disposal area (12 tons of mercury).

Develop a sampling and testing protocol to determine whether mercury could leach from the solidified Chemfix sludge. Use the new protocol to sample the Chemfix sludge. Report sampling results.

Submit, within six months of the completion of the sampling programs and Ecology's approval of the results, a proposed feasibility study to finish the cleanup of the site.

What will happen next?

Ecology will consider all public comment about this proposed Agreed Order that is received during the formal comment period, and respond in a written and published report called a "Responsiveness Summary". If necessary, based upon the comments received, Ecology may modify the Agreed Order before issuing it. The work required in the Agreed Order should be completed in approximately nine months.

Final cleanup of the site will occur after Georgia Pacific submits a remedial investigation and feasibility study that Ecology can approve; and the parties draft and sign a consent decree. An additional formal public comment opportunity will occur after the Agreed Order for the RI/FS has been satisfied and before Ecology issues the Consent Decree for final cleanup.

The comment period on the proposed Agreed Order expired on September 13, 2002.

Interested parties may arrange to see the file of supporting documents that informed the drafting of this proposed Agreed Order by contacting Paul Skyllingstad at Ecology's headquarters building in Lacy, (360) 407-6949.

Original document: http://www.ecy.wa.gov/pubs/0209048.pdfDOE

Clean up schedule: http://www.ecy.wa.gov/programs/tcp/sites/blhm_bay/sites/bel_bay_sites.html#Cleanup_Progress

WA Department of Ecology Study on Brownfield reclamation and re-development: http://www.ecy.wa.gov/pubs/0909043.pdf

Tuesday, April 21, 2009

Georgia Pacific West Corporation Chlor Alkali Plant Cleanup

PUBLIC COMMENT PERIOD: 8/15/02 - 9/16/02 ===================================================


Phase II Agreed Order to Conduct Remedial Investigation/Feasibility Study Proposed and Available for Public Review & Comment - Georgia Pacific Corp Chlor-Alkali Plant, Facility Site ID No. 14, located at 300 W. Laurel St., Bellingham, 98225, Whatcom County


Ecology and Georgia-Pacific Corporation are proposing a Phase II Agreed Order to conduct a Remedial Investigation/Feasibility Study at the Georgia Pacific Corp Chlor-Alkali Plant site.

Phase I of the cleanup involved closing, decommissioning, and demolishing the plant's processing machinery and building. The site is ranked a "5" on Ecology's Hazardous Sites List (a rank of "1" is the highest assessed risk compared to other sites on the list, and a "5" is the lowest).

From 1965 to 1999, Georgia-Pacific operated a chlor-alkali plant on the property that used mercury and brine to produce chlorine and sodium hydroxide (these products were used to bleach and pulp wood fiber). In the process, mercury leaked or spilled and contaminated the site site's soil, sediments, and ground water.


The purpose of a Remedial Investigation is to determine the nature and extent of the contamination. With this information, cleanup options are evaluated and presented in a Feasibility Study report.

In 1994, Georgia-Pacific completed an independent Remedial Investigation/Feasibility Study (without Ecology oversight or approval). The Phase II Agreed Order proposes Ecology review this report and Georgia-Pacific take the following actions:

Submit a soil and ground water sampling plan.

Submit a sampling plan of the Chemfix mercury sludge disposal area (Chemfix is a solidification/stabilization treatment process).


Develop sampling and testing protocol to determine if mercury could leach from the solidified sludge area.


Within six months of completion of the sampling programs and Ecology's approval of results, submit a Feasibility Study to Ecology.


Public Meeting: A public meeting to discuss the RI/FS will be held on September 5, 7:00 p.m., at Whatcom Community College, Heiner Auditorium, 237 W. Kellogg Road, Bellingham.

The proposed Agreed Order is available for review at the following locations:

Department of Ecology, Bellingham Field Office, 1204 Railroad, Suite 200, Bellingham

Department of Ecology, 300 Desmond Drive, Lacey, (360) 407-6916

Department of Ecology, Northwest Regional Office, 3190 160th Ave. SE, Bellevue



http://listserv.wa.gov/cgi-bin/wa?A3=ind0208&L=SITEREGISTER&E=quoted-printable&P=317457&B=------_%3D_NextPart_001_01C2486B.74B56260&T=text%2Fhtml;%20charset=iso-8859-1

In the matter of compliance by Georgia Pacific Corporation


Who's afraid of 12 tons of mercury buried in close proximity to proposed schools, retail office space and condos? Certainly not the people who live and work in Bellingham!

_______________________

Department of Ecology

IN THE MATTER OF THE COMPLIANCE BY GEORGIA PACIFIC CORPORATION with Chapter 90.48 RCW and the Rules and Regulations of the Department of Ecology

To: Georgia Pacific Corporation:

Order Docket # DE 77-336

Mercury contaminated chemfix sludge material was deposited by the Georgia Pacific Corporation during July 1976 in a landfill improvised on the woodyard of their pulp mill in Bellingham.

The chemfix project was carried out, without notification to the Department of Ecology, as a means of disposing of approximately 1,5000,000 gallons of mixed liquid and solid wastes that had accumulated in a storage pond of the Chlorine Plant. With a mercury concentration of about 0.17 percent, the 7,000 ton sludge deposit contains approximately 12 tons of mercury.

Order docket No. DE 77-168 was issued by the Department of Ecology on March 2, 1977, requesting information from Georgia Pacific on measures taken to prevent mercury pollution of state waters from the sludge deposit. The Georgia Pacific response, dated April 5, 1977, to Docket No. DE 77-168 stated that the sludge deposit was on a fill site constructed behind an impervious dike in accordance with Army Corps of Engineers Permit No. 071-OYB-1-001695. A review of this permit shows that the dike is described as an earthen berm comprised of upland fill material, with no statement regarding dike permeability, and no statement regarding utilization of the fill project as a disposal site for mercury wastes.

In consideration of the above information, it is determined by the Department of Ecology that additional measures are required to insure that the chemfix sludge material or leachates from the material do not enter state waters.

RCW 90.48.120 reads in part: Whenever the Department deems immediate action is necessary to accomplish the purpose of Chapter 90.48 RCW, it may issue such order or directive, as appropriate under the circumstances.

In view of the foregoing and in accordance with the provisions of RCW 90.48.120(2):

IT IS ORDERED THAT Georgia-Pacific Corporation shall, upon receipt of this Order, take appropriate action not later than October 31, 1977 either transport the chemfix sludge deposit to a disposal site acceptable to teh Department of Ecology, such as the site operated by Chem-Nuclear Systems, Inc. near Arlington, Oregon, or construct and maintain an impervious covering over the chemfix sludge deposit in accordance with teh following requirements:

1. Submit engineering plans for the project, including a legal description of the property occupied by the chemfix sludge deposit, to the Department of Ecology for approval by July 31, 1977. The covering shall be constructed of either asphalt or concrete pavement. If asphalt is used, the surface over the chemfix deposit, including a 10 -foot border extension on all sides, shall be covered with an impervious plastic liner overlaid with sand prior to paving. The asphalt pavement shall extend at least 20 feet beyond the sludge deposit on the side toward the log pond and shall extend to join with existing paved surfaces on the other three sides. If concrete is used, either the surface area described above shall be paved or the surface over the chemfix deposit, including a 10-foot border extension on all sides, shall be paved and joined to a concrete footing wall constructed around the deposit to a depth of six feet.

2. The completed project shall be continually maintained as required to retain the impervious condition of the covering. No future project involving excavation or degradion of the covering shall be undertaken without written approval of the Department of Ecology.

Dated at Olympia, Washington, this (28th) day of June, 1977.

Signed,

Donald O Provosot
Assistant Director of Ecology


Comparisons to other well-known conatmination sites:

ABC News - Love Canal's Lethal Legacy: http://abcnews.go.com/Health/story?id=5553393&page=1

New York State Dept of Health reports: http://www.nyhealth.gov/environmental/investigations/love_canal/

Presenters discuss securing and preserving the public's legal right to access records

The Washington Coalition for Open Government and the League of Women Voters of Kittitas Valley will present a special program focusing on Washington’s Public Records and Open Meetings laws from 6:30 to 8:30 PM on Wednesday, April 22 at the Hal Holmes Community Center, 209 N. Ruby Street in Ellensburg.

A panel of expert presenters will fuel the discussion on securing and preserving the public’s legal right to access the records and proceedings of the government agencies created to serve the people of the state. The panelists include: former State Representative Toby Nixon, Assistant State Attorney General Tim Ford, former Director of the Public Disclosure Commission Graham Johnson, and Cynthia Mitchell, Central Washington University professor of Communications. Todd Schaefer, head of the Political Science Department at CWU will moderate the discussion.

The forum is free and open to all, and questions and comments from the audience are welcome. This civic event is sponsored by the Daily Record.

The Washington Coalition for Open Government is a statewide non-partisan, non profit group of individuals and organizations dedicated to strengthening and preserving the public’s right to know what its government is doing. The Coalition has presented a series of similar programs around the state to educate the citizens of Washington on their rights of access.

For more information, contact the Washington Coalition for Open Government, 6351 Seaview Av NW, Seattle, WA 98107-2664, phone 206.782.0393 or by email at
info@washingtoncog.org

Monday, April 20, 2009

House keeping questions

An anonymous visitor asked me if I have the ability to track commenter's postings and visits.

Yes, I recently subscribed to a service that keeps track of the IP numbers, etc. of all of the visitors and commenter's on Latte Republic.

Like the Bellingham Herald, I believe it is important to protect the identity of my visitors and commenter's. But it would be wrong to say that I do not have the ability to identify them.

Not everyone is capable of separating themselves personally from issues, as was demonstrated on Saturday when a man attempted to forcibly prevent my son from leaving our house to go to work.

If you disagree with me and want to say so personally - I suggest you communicate your concerns to me, via e-mail, not through my children.

I'm not that hard to get a hold of. Just post a comment in the comment section.

And, who ever it was who tried to stop my son - he now has a cell phone with a camera and he will take your picture and call the Bellingham Police if you attempt to assault him again





Preservation of Historic Industrial Buildings vs. Public Health - here's one city's Horror Story

In 1996, a Hoboken, New Jersey resident watched silently as unidentified drops of liquid slowly dripped from the ceiling of the apartment on to a counter top in his/her home.

The recently redeveloped five-story brick building was located in a heavily populated, mostly residential section of Hoboken.

In the early to mid 1990's, the historic building, (which served as a former mercury vapor lamp and connector switch manufacturing facility for General Electric from 1910 to 1965), was converted into 16 residential apartments and artist studios.

The project was permitted by the NJ Department of the Environment (DEP) and the City of Hoboken in New Jersey. Like the WA State Department of Ecology, the New Jersey Environmental Department relies on consultant studies completed by former property owners and/or other entities responsible for clean up.

After discovering the mercury, the apartment's residents asked state health officials to investigate the drops. The health inspector found liquid mercury under the building's wooden floor boards and in the walls. Mercury vapor was detected in the air with monitors.Additional tests revealed unacceptable levels of mercury contamination in children living in the area.

The Army Corps of Engineers and EPA were called in.

The Corps assisted the EPA in evacuating and relocating the 16 families and 20 businesses that occupied the contaminated area.

The Federal government purchased the property from the owners and all of the displaced residents and businesses were moved to safe locations.

The building's windows were removed and the brick walls were inspected for mercury contamination. The brick was contaminated and the entire structure had to be removed. An air handling system was set up to filter out mercury vapors during remediation. Other measures included closing surrounding sidewalks, placing a fence around the contaminated area and installing air monitors to measure mercury vapor and dust in the neighborhood.

The concrete slab and subsurface piping was removed and mercury contaminated soils were excavated from the site.

"The Mercury contamination was overwhelming and truly a health hazard to anyone on or around it." said Neil Ravensbergen, project engineer for the remediation. "It's a shame to loose a piece of history, but it was a benefit to the overall environment."

Pure liquid mercury found on the site was recycled and mercury contaminated building material was disposed of at an approved hazardous waste landfill.

Don't think it could happen here?

At the former GP industrial site, Port of Bellingham consultant studies recommend that residential occupancy be banned on the first floor of some of the proposed structures in certain areas.

The Port's consulting firm also recommended that Mercury Vapor monitors be installed around new structures to monitor mercury vapors in and around buildings on the re-developed site.

I wonder, is this the kind of "clean up" and "re-development" our community is willing to live with?

What is the definition of an "acceptable" risk in regards to public health in Bellingham?

Well, here's what a former NJ DEP official had to say about private companies conducting the environmental studies: " The system is fatally flawed. The DEP relies on private companies, who have a legal and economic stake in minimizing the cost of clean-up," said Bill Wolfe, a former DEP analyst. "This is unfreakingbelievable. The private sector makes the decisions and the DEP and the public have been cut out of the process. This is like a police chief saying that we have so much crime we are going to ask criminals to turn themselves in." http://blog.nj.com/hobokennow/2007/10/new_jersey_admits_privatized_c.html

Background:

The Grand Street Mercury site consisted of two former mercury vapor lamp and mercury connector switch production plants that were later renovated. One building was converted into apartments. The other building was to become townhomes, but had not been completed at the time contamination was found, and the townhomes were never finished, according to EPA. The surrounding area is a mix of residential and commercial properties.http://ehscenter.bna.com/pic2/ehs.nsf/id/BNAP-6PTG9S?OpenDocument

EPA orders clean up of Condos: http://yosemite.epa.gov/opa/admpress.nsf/8b75cea4165024c685257359003f022e/812e723ef644211285257266006ddf33!OpenDocument

Hoboken City website: http://www.hobokennj.org/index.html Grand rennovation project

ATSDR Study: http://www.atsdr.cdc.gov/HAC/PHA/grand/gsm_p1.html

Hobokennnow: http://blog.nj.com/hobokennow/2007/10/new_jersey_admits_privatized_c.html

Lost and Found: where did all the Mercury Go?

Tonight, the City will meet to discuss finalizing the waterfront redevelopment master plan.

What's missing from the discussion? How do we account for and clean up mercury and other toxic industrial contaminants from the site?

Mercury is an invisible, odorless poison that can pollute oceans and rivers, contaminate our food and seep into the air, potentially causing severe health problems when ingested by humans.

A major source of mercury pollution is chlor-alkali chemical manufacturing plants.

Georgia Pacific operated a chlor-alkali plant at the Bellingham pulp and paper mill site, releasing mercury-laden water into surface treatment ponds on the site.

No one disputes the fact that the ground water and soil is contaminated with significant levels of mercury. During the 1970's, in an attempt to prevent mercury from moving to the bay from the soil and groundwater, Georgia Pacific retained a company to do what is called a "chem fix." For the sake of simplicity, A chem fix is a process that "cements" the contaminants in place.

The clean up was conducted without Dept of Ecology or EPA oversight, even though the site was on the Superfund list. Georgia Pacific admits to depositing 12 tons of mercury in the chemfix.

12 Tons of Mercury...

According to a 2005 analysis of Environmental Protection Agency (EPA) data by the environmental group Oceana, the nine chlor-alkali plants in operation in 2000 reported purchasing and ostensibly using 79 tons of mercury and releasing 14 tons. The other 65 tons could not be accounted for.

The industry and the EPA have speculated that the "lost" mercury may be caught in the infrastructure inside the facilities, but EPA analyses of contamination at closed plants have not found nearly enough to account for the discrepancy between the mercury consumption and emissions.

Where did the mercury go?

The enclosed paper demonstrates that the operators of former and existing chlor-alkali plants cannot account for the tons of mercury lost each year - for mercury that winds up in the ground, air and water.

What are the health risks for Americans living near or on top of old chlor-alkali plants?

FULL ISSUE PAPER IN PDFAdobe Acrobat file (size: 5.3 MB)

OUTLINE
Executive Summary
Introduction
NRDC Investigation Uncovers Further Cause for Alarm
EPA Studies Support Findings of Elevated Mercury Levels
The EPA Fails to Address the Mercury Problem
Recommendations
Appendix:
Detailed Sampling Results
Endnotes
Sources:

http://www.nrdc.org/health/effects/chlor/contents.asp

Department of Ecology Documents (including references to dumping dredged materials out in Bellingham Bay. (PSDDA)
http://www.ecy.wa.gov/programs/tcp/sites/whatcom/fs%20part%20003%20Vol%202%20-%20FS%20(Chapter%203%20through%204).pdf

Draft Supplemental Remedial
Investigation & Feasibility Study
Volume 2: FS Report

http://www.ecy.wa.gov/programs/tcp/sites/whatcom/oct_06_docs/Draft%20Supplemental%20Feasibility%20Study.pdf

Some of the original Chemfix documents: http://www.skookum.us/fowcweb/GP/chemfix/index.htm

Sunday, April 19, 2009

Deja Vu?

"Just give the Chesapeake Bay back her 1970 water quality, and we will have plenty of crabs, and plenty of oysters, and plenty of rockfish, and we will have a good style of life again, you know. If we could get our regulators to work that out ... to improve our water quality --- the Chesapeake Bay could heal herself. But she's, she's dying daily." Don Pierce, Chesapeake Bay waterman (fisherman)

Don Pierce has been working the waters of Chesapeake Bay for 48 years. But Friday, on Earth Day, he was not feeling positive.

Too much phosphorus, too much fertilizer, too much sewage and agricultural runoff.

Pierce has observed the algae blooms in the 190 mile area of Chesapeake Bay that he works each summer and fall.

He told CNN reporter John King that there used to be 60 to 70 boats in his little town and in the 60's, the bay was teeming with clams, oysters, and striped bass. Now there are fewer than 20 boats. "My grandsons will not be watermen" said Pierce,

When asked who is trying to clean up the watershed, "We the people that live in the Chesapeake watershed mainly. We the people," he says."

Reminds me of Whatcom County. In the 60's Blaine had a fleet of fishing boats in the Harbor and fish were plentiful. Today, there are just a handful of boats left in the entire county and the shellfish have vanished from many beaches.

The State of Washington is blessed with abundant natural resources. Puget Sound and its bays are capable of generating billions of dollars in revenue for the state if we would just take care of it.

Everyone lives in a watershed. Its up to each of us as individuals to change the way we relate to the bay and the lakes, streams and rivers that support the Sound.

What did I do this weekend to celebrate Earth Day?

I filled one of those large black construction bags with garbage and refuse from the ditches in front of my house.

I will pay to have Sanitary Service haul it away.

John King, CNN Article: http://politicalticker.blogs.cnn.com/2008/12/15/patersons-office-says-snl-went-too-far/



Saturday, April 18, 2009

Not funny

To who ever it was who tried to block my son from pulling out of the driveway today.

Knock it off.

Dear Bellingham Police Department,

Please take note that we will not be threatened or harassed as we leave our home.

This is not funny nor is it ok.

Bellingham Bay Open Water Disposal Site

What is open water disposal?

Open-water disposal is a state and federal approved dredged material disposal program where unconfined dredged material is placed at designated sites in oceans, estuaries, (a bay may be a large estuary) rivers and lakes in a manner that dredged material is not isolated from the adjacent waters during placement.

Placement is generally via release from pipelines, barges or hoppers. (Dredged Sediment is released into the environment from a pipe or by opening the bottom of a barge and allowing the material to drift down to the bottom).

Open water sites can be either dispersive or non-dispersive (retentive or non-retentive) depending on whether the sediment is transported out of the site or remains within the designated boundaries. Generally, clean or mildly contaminated sediments are disposed of in open water, although the disposal of highly contaminated material can also be considered with appropriate control measures.

Regardless of the type of in-water disposal, placing dredged materials in the aquatic area raises several key concerns, including sediment and water quality, sediment transport, water circulation, impacts to fisheries, and impacts to biological communities, especially endangered/threatened species.

Sediments placed in water must meet sediment quality regulations outlined in the Dredged Material Evaluation Framework. The majority of sediment disposed in the estuary's aquatic area consists of coarse, clean sand dredged from maintained navigation channels. This material must meet the water and sediment quality standards (SQS).After sediment is placed in an open water disposal site, some or all of it is eventually transported to other areas, potentially resulting in adverse impacts to shallow productive areas and fishing areas, resulting in an increase in dredging requirements on other projects. (Creating a cycle of dredging and additional clean up).The sediment transport patterns at in-water sites need to be assessed prior to disposal.

Disposing of material in-water usually creates a mound or otherwise obstructs water flow. Consequently, water circulation patterns in the vicinity of the disposal site are altered. These changes can have detrimental effects. For instance, unexpected erosion or accretion can occur downstream from the disposal site. Conversely, the changes can sometimes be beneficial. For example, the scouring of the channel can be increased. In all cases, the potential effects that may result from circulation changes need to be assessed prior to undertaking disposal.

In-water disposal often results in the direct smothering of benthic organisms at the disposal site and indirect impacts to organisms living down current from the site. Disposal often impacts commercial fisheries by decreasing the size and depth of net drifts, potentially creating snags in fishing areas, and obstructing fishing access with dredging equipment.

As of 2003, the US Army Corps of Engineers (USACE) biennial report states that 78,883 cubic yards of dredged material has been disposed at the Bellingham Bay open water disposal site.

The USACE estimate that the site can absorb up to 181, 500 additional cubic yards over the next 50 years.

The Bellingham Bay site was closed in the 1960’s, but re-opened in the 1980s. There is no record of the contaminants that were dumped during the 1950s and 60s. Nor has the site been monitored for contaminants since it was re-opened during the 1980s. Both the tribes and the City objected to the site, but it was crammed down our throats anyway.

Who can use the site? We don’t have all of the answers, but in the I & J Waterway PSDDA Sediment Characterization Sampling and Analysis Plan, RETEC (Port of Bellinham Consultant) estimates that mercury laced dredged materials that pass chemical and biological guidelines may be disposed of at the Rosario Straits dispersive site, or the Bellingham Bay non-dispersive open water disposal site as part of the proposed clean up project for Bellingham Bay.

Additional information regarding the dredging of the I & J Waterway can be found on the Dept of Ecology website under the I & J Waterway PSDDA Characterization and Sampling Analysis Plan.

Hence, the Port of Bellingham plans to use the Bellingham Bay site, or the Rosario site to dispose of “low level” contaminated dredged materials from the I&J Waterway, the Whatcom Waterway and Squalicum Harbor clean up. All of the materials contain low to high levels of contaminants.

The Bellingham Bay disposal site has been used off an on since the 1960’s to dispose of contaminated sediments. Early dredged materials were not tested for contaminate levels prior to dumping.

To date, the site has not undergone thorough testing to determine toxicity levels or the suitability of the site for future dredged material disposal.

Local tribes have long referred to the Bellingham Bay site as a dead zone for fishing.

How can I learn more?

The USACE publishes biannual DMMP reports on the Region 10 website. The reports are easily accessed through Ecology’s Aquatic Lands Cleanup webpage. Scroll down to the bottom of the page. Click the DMMP Biennial Reports link under the “other links” heading and you will be taken to the Region 10 website with four DMMP reports for Puget Sound.Again, there is very little information published on the Bellingham Bay open water disposal site. To date, reports state that only partial monitoring studies have been completed for the Bellingham Bay Disposal site.

The WA State Department of Natural Resources (DNR) has recently placed Bellingham on a list of proposed open water disposal sites to be evaluated, tested and monitored over the next two years by a private consulting firm. By statutory requirement, DNR provides, manages, and monitors aquatic land disposal sites on state owned aquatic lands for materials dredged from rivers, harbors, and shipping lanes. Currently, permits to dispose dredged materials at the Bellingham Bay site are issued by the Army Corps of Engineers DMMP program. Federal law does not require publication of permits for open water disposal.

Bellingham is one of twelve open water dredged material disposal sites in Washington. (Six are currently in use).

An EPA diver report on Bellingham Open Water Disposal site:

Disposal of Dredged-material at Open-water Sites

What: The Region 10 Dive Team participated in an interagency effort to assess benthic conditions at dredged-material open-water disposal sites in Bellingham and Padilla Bays, located near Bellingham and Anacortes, WA, respectively.

Why: At Bellingham Bay there was concern that the 58 acre marine disposal site lacked the capacity to contain additional dredged material from Corps of Engineers and Georgia Pacific dredging projects. At Padilla Bay, state resource agencies wanted to evaluate the effect of disposing of 150,000 cubic yards of sandy Swinomish Channel dredged material on an existing silt bottom. It was believed that a sandier substrate might improve Dungeness crab habitat at the disposal site.

Where: Center coordinates for the disposal sites are: 48o 49' 40" N Lat. and 122o 31' 30" W Long. in Bellingham Bay; 48o 31' 04" N Lat. and 122o 33' 05" W Long. in Padilla Bay. When: The Bellingham Bay site was inspected in February 1979 and April 1982. The Padilla Bay site was inspected in April 1982.

How: Benthic observations were made along transects radiating out from the approximate center of the disposal areas. A buoy was located near the center of each site. Still photographs were taken. No sediment samples were taken.

Results: In 1979 at Bellingham Bay, the divers noted that 1) the bottom was composed mainly of compacted clay and silty sand, 2) the profile in the disposal area was very uneven (hummocky), and 3) some of the dredged material was located outside of the established disposal site (it was unclear whether the cause was "drift" from the site or short-dumping). *
By 1982, the profile at the Bellingham Bay site appeared to be much more even and the dredged material appeared to have settled. No evidence of erosion was observed and benthic animals were recolonizing the area. In Padilla Bay, the divers noted that despite the disposal of sandy dredged material, the dominant substrate still appeared to be silt. Based on the observations, the interagency dive teams recommended that continued dumping could occur at both disposal sites.
http://yosemite.epa.gov/r10/OEA.NSF/Investigations/Dive+Sediment

There are dozens of reports and studies on this topic.

Reference materials:

Seattle PI Article regarding disposal of PCB contaminated sediment:
http://seattlepi.nwsource.com/local/331350_port12.htmlLinks to other sediment management agency sitesUS Army Corps of Engineers Seattle District HomepageDredged Material Management Office - US Army Corps of Engineers Seattle District Dredged Material Management Program (DMMP)/Puget Sound Dredge Disposal Analysis (PSDDA) Clarification PapersDMMP Biennial ReportsEnvironmental Protection Agency Region 10 HomepageEPA Region 10 Sediment LinksWashington Department of Natural Resources HomepagePuget Sound Water Quality Action Team HomepagePuget Sound ProtocolsOpen Water Disposal Techniques (great pictures)http://el.erdc.usace.army.mil/workshops/08apr-doer/9_OpenWaterDisposal_Bailey.pdfI&J Waterway document: http://www.ecy.wa.gov/programs/tcp/sites/blhm_bay/sites/I_and_J_Waterway/I&J%20Seds%20RIFS%20App%20B%20Text.pdfMichigan Governor bans open water disposal of certain chemicals in Lake Michiganhttp://www.michigan.gov/gov/0,1607,7-168--84861--,00.htmlErosion of Cohesive Dredged Material inOpen-Water Disposal Siteshttp://el.erdc.usace.army.mil/elpubs/pdf/drp1-07.pdfToxic Contaminants of Sediments in Puget Sound http://gbic.tamug.edu/gbeppubs/T3/gbnepT3_51-56.pdfApplicable Washington Administrative Code authorizing open water disposal of dredged materials WAC 332-30-166http://apps.leg.wa.gov/WAC/default.aspx?cite=332-30-166