RANGE OF CONTEMPLATED REMEDIATON ALTERNATIVES
Clean up or Cover up?Following are excerpts from the Department of Ecology's Draft Supplemental Feasibility Study for the Whatcom Waterway site (1.2mb PDF).
That document was prepared by G-P's consultants to describe to the State what measures are implied by which standards, and what actions are appropriate according to which goals. Therefore a range of options has been proposed. This comes from a consensus-based, agency-driven process - a process characterized by conflict aversion and the stark absence of citizen or victim representation.
These "Alternatives" detail options from removing all to none of the contaminated sediment in the Whatcom Waterway project area. Despite years of participation in the Bay Action Group, the Port's proposals for the G-P acquisition project are a sudden departure from the framework developed to date. The Port's proposal removes the least amount of polluted sediment from the bay, leaving most in place, some capped and left to follow the "Natural Recovery" approach championed by G-P's Chip Hilardes. G-P's treatment lagoon, recently contemplated as contaminated sediment repository, is instead converted to a yacht basin. Uplands would be remediated according to remedial investigations underway and eventually sold off to the private sector.These documents are worth reading because they underscore several important :features of the Bellingham Bay situation, namely:
1) No agency has ever made any effort whatsoever to make G-P clean up their mercury mess for almost forty years since it started, thirty seven years since it was generally known to be harmful and twenty-some years since they claim to have "controlled" their discharges of mercury.
2) Every agency effort has been to spare costs to Georgia-Pacific, including the enablement of two different storage repository schemes on state aquatic lands, including the re-designation of former aquatic lands as "upland" - and no alternative that involves shipping wastes to existing approved landfills.
3) G-P has exploited regulatory inaction to carefully measure a long-term rate of "natural recovery", subsequently parlaying that data into a rationale for continued inaction - even oddly converting the hottest mercury hotspots, like the logpond, into "estuaries" or "habitat areas" with the simple expedient of dumping a little dirt on top of them.
The foregoing points will shed a somewhat different light on the alternatives than was originally intended.
The alternatives' summary follows: WW means Whatcom Waterway, SQS means sediment quality standards, CDF means confined disposal facility, etc. Look to see how many cubic yards are actually being removed, and where they are being put, how much is being covered up? Look also at some typical project costs.
" Remedial Alternative A: No Action (Pilot No. 1). Under this alternative, there would be no sediment cleanup, habitat restoration, monitoring activities, or land use actions. The exiting Log Pond cap would be maintained, and the existing Bay sediments would continue to recover naturally over time.
" Remedial Alternative B: Source Control & Natural Recovery with Capping. All action alternatives evaluated in the RI/FS and this Supplemental FS (i.e., Identification and Assembly of Cleanup Technologies Supplemental Feasibility Study 15 March 2002 Whatcom Waterway Site, Bellingham, Washington 000030-07 T6 Alternatives B through J) include source controls. This alternative would utilize natural recovery in those parts of the WW Area that are predicted to naturally achieve SQS criteria within approximately 3 years (by 2005), which is as rapid as biological resources could potentially recover at the site following a more active cleanup (e.g., dredging). Those areas of the site that are not predicted to recover, and which occur outside of the navigation channel, would be capped with a 1- to 3- foot sand layer. A relatively small area in the middle of the Whatcom Waterway that is predicted to recover by 2005, partly as a result of resuspension-related transport, would be left to recover naturally. Other site units within the WW Area that currently exceed the mercury bioaccumulation screening level (BSL; 1.2 mg/kg) would be capped to accelerate the natural recovery process. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. All cleanup areas of the site would be monitored to document sediment recovery using a combination of chemical and biological testing methods. No dredging would occur under this alternative. A layout of Alternative B is presented in Figure 4.
" Remedial Alternative C: Capping & Removal to Improve Navigation (Log Pond Nearshore CDF). This alternative combines capping and limited dredging within the middle of the Whatcom Waterway navigation channel to achieve SQS criteria throughout the WW Area. As in Alternative B, those areas of the site that are not predicted to recover (using conservative modeling assumptions), and which occur outside of the navigation channel, would be capped with a 1- to 3-foot sand layer. No further action would be undertaken in the outer Whatcom Waterway reach where surface sediments currently meet SQS criteria and where channel depths are consistent with the federally authorized elevations. Surface and subsurface sediments within the middle of the Whatcom Waterway adjacent to the G-P Log Pond would be dredged to a depth of at least 5 feet below the currently authorized channel depths. Since subsurface contaminants would still be present below the dredge depth, the dredge cut would be capped with a 2-to-3- foot clean sand layer, resulting in a final channel elevation at least 2 feet below the authorized depth. This dredge-and-cap action would leave sufficient tolerance to Identification and Assembly of Cleanup Technologies Supplemental Feasibility Study 16 March 2002 Whatcom Waterway Site, Bellingham, Washington 000030-07 T6 allow unencumbered future maintenance dredging of the authorized federal channel in this area, considering typical overdredge allowances. No action would be undertaken at the head of the Whatcom Waterway (i.e., above Station 15+00), as this area (currently exceeding SQS but below MCUL biological criteria) would be left to recover naturally to below the SQS by 2005. An estimated 160,000 CY of sediments would be dredged under this alternative. Dredged sediments could be reused to create a nearshore CDF in the G-P Log Pond. Excess sediments that do not fit into the nearshore fill would be disposed at an offsite upland landfill. Habitat mitigation actions including at least 6 acres of area-forarea replacement by fill removal and/or acquisition and enhancement at high priority habitat creation sites would be performed as a part of implementation of this alternative. A layout of Alternative C is presented in Figure 5.
" Remedial Alternative D: Capping & Removal to Improve Navigation (Upland Disposal). This alternative is identical to Alternative C except that all of the dredged material would be disposed at an upland landfill instead of in the G-P Log Pond nearshore CDF. The dredge material would either be reused to restore a wetland habitat at the Whatcom-Skagit Phyllite Quarry, or, alternatively, disposed at the Roosevelt Regional landfill. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. A layout of Alternative D is presented in Figure 6.
" Remedial Alternative E: Capping & Removal to Achieve Authorized Channel Depths (CAD Disposal) (Pilot No. 2A). The overall objective of this alternative is to achieve SQS criteria in the WW Area while concurrently maintaining existing navigation channels, minimizing dredging and disposal of contaminated sediment, and maximizing the areal extent and diversity of intertidal aquatic habitat by using caps and CAD facilities. Enough material would be dredged from the Whatcom Waterway to remove contaminated sediments from the existing federal channel (including overdredge allowances) in all areas of the waterway that are currently used for navigation. Except for the extreme head of the Whatcom Waterway that currently contains mudflat habitat, surface and subsurface sediments throughout Identification and Assembly of Cleanup Technologies Supplemental Feasibility Study 17 March 2002 Whatcom Waterway Site, Bellingham, Washington 000030-07 T6 much of the waterway would be dredged to a depth of at least 5 feet below the currently authorized channel depths. However, no further action would be undertaken in the outer Whatcom Waterway reach where surface sediments currently meet state standards and where channel depths are consistent with the federally authorized elevations. Other contaminated sediment areas would be capped with a 1-to-3-foot clean sand layer. In this alternative a 3-acre area of mudflat and adjacent shallow subtidal habitat would be left intact at the head of the Whatcom Waterway. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. Approximately 360,000 CY of contaminated sediment from navigation areas within the Whatcom Waterway would be dredged. In this alternative, the sediment disposal capacity would be provided by a 400,000 to 500,000 CY CAD sited in the Starr Rock/Cornwall area. The Starr Rock/Cornwall CAD could also be implemented as a multi-user disposal facility to contain contaminated sediments that may be dredged from other sites in Bellingham Bay. The CAD would provide opportunities for concurrent habitat restoration. Largely because of the CAD, approximately 42 acres of subtidal area would be converted into intertidal habitat. A layout of Alternative E is presented in Figure 7.
" Remedial Alternative F: Capping & Removal to Achieve Authorized Channel Depths (Upland Disposal) (Pilot No. 2B). The overall objective of Alternative F is to achieve SQS criteria in the WW Area while maintaining existing navigation channels and minimizing dredging and disposal of contaminated sediment. This alternative includes the same amount of dredging as Alternative E, but would dispose of the materials at one or more off-site upland landfills. Other contaminated sediment areas would be capped with a 1-to-3-foot clean sand layer. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. All dredged sediments would be offloaded on shore, dewatered as necessary to facilitate transport, and hauled by rail, truck, and/or barge outside of the Bellingham Bay watershed to upland disposal facilities. Approximately 360,000 CY of Identification and Assembly of Cleanup Technologies Supplemental Feasibility Study 18 March 2002 Whatcom Waterway Site, Bellingham, Washington 000030-07 T6 contaminated sediment from navigation areas within the Whatcom Waterway would be dredged. In this alternative, the Whatcom-Skagit Phyllite Quarry or the Roosevelt Regional Landfill would provide the sediment disposal capacity. A layout of Alternative F is presented in Figure 8.
" Remedial Alternative G: Full Removal from Navigation Areas (CAD Disposal) (Pilot No. 2C). The overall objective of this alternative is to achieve SQS criteria in the WW Area, allowing for possible future deepening of the navigation channels, and maximizing the areal extent and diversity of intertidal aquatic habitat by using caps and CAD facilities. Unlike Alternative E, minimizing dredging and disposal volumes is not a primary objective of Alternative G. Contaminated sediments that are located within the Whatcom Waterway, even if present below the currently authorized depths, would be dredged, removing potential encumbrances to channel deepening, should such a deepening project be undertaken in the future. Dredging would be performed throughout the Whatcom Waterway, including a 1-acre area at the head of the waterway. The extreme head of the Whatcom Waterway near the former Citizens Dock, consisting of a 2-acre area of mudflats that has formed naturally within this area, would be left intact. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. Approximately 760,000 CY of contaminated sediment from navigation areas within and adjacent to the Whatcom Waterway would be dredged. In this alternative, the sediment disposal capacity would be provided by a 800,000 to 1,000,000 CY CAD sited in the Starr Rock/Cornwall area. The Starr Rock/Cornwall CAD could also be implemented as a multi-user disposal facility to contain contaminated sediments that may be dredged from other sites in Bellingham Bay. The CAD would provide concurrent habitat restoration. Largely because of the CADs, approximately 63 acres of subtidal area would be converted into intertidal area. A layout of Alternative G is presented in Figure 9.
" Remedial Alternative H: Full Removal from Navigation Areas and Partial Removal from the G-P ASB and Starr Rock Areas (Upland Disposal) (Pilot No. Identification and Assembly of Cleanup Technologies Supplemental Feasibility Study 19 March 2002 Whatcom Waterway Site, Bellingham, Washington 000030-07 T6 2D). Similar in some respects to Alternative G, the overall objective of Alternative H is to achieve SQS criteria in the WW Area, allowing for potential future deepening of the navigation channels. This alternative includes dredging of those areas included in Alternative G, but also includes the dredging of an additional 300,000 CY of sediments exceeding the site-specific BSL criteria that are located offshore of the G-P ASB and at the former Starr Rock disposal site. The dredged sediments would be disposed at one or more off-site upland landfills. Other contaminated sediment areas would be capped with a 1-to-3-foot clean sand layer. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. All dredged sediments would be offloaded on shore, dewatered as necessary to facilitate transport, and hauled by rail, truck, and/or barge outside of the Bellingham Bay watershed to upland disposal facilities. Approximately 1,100,000 CY of contaminated sediment from the WW Area would be dredged. In this alternative, the sediment disposal capacity would occur at the same upland disposal facilities described for Alternative F. A layout of Alternative H is presented in Figure 10.
" Remedial Alternative I: Full Removal from Public Lands (Upland Disposal) (Pilot No. 2E). The overall objective of Alternative I is to completely remove all contaminated sediment from public lands within the WW Area, and totally avoid disposal in the aquatic environment. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. This alternative would also allow for possible future deepening of the navigation channels and state-owned harbor areas. Like Alternative H, avoiding disposal in the aquatic environment is a primary objective. With the exception of sediments located immediately adjacent to the existing G-P wastewater pipeline and at the Log Pond, dredging would be performed within all reaches of the WW Area, including the extreme head of the federal channel, encompassing the former Citizens Dock and associated mudflat areas. All dredged sediments would be offloaded on shore, dewatered as necessary to facilitate transport, and hauled by rail and/or truck outside of the Bellingham Bay watershed to upland disposal facilities. Approximately 1,900,000 CY of contaminated sediment from the WW Area would be Identification and Assembly of Cleanup Technologies Supplemental Feasibility Study 20 March 2002 Whatcom Waterway Site, Bellingham, Washington 000030-07 T6 dredged. In this alternative, the sediment disposal capacity would be provided by the same upland disposal facilities described for Alternative F. A layout of Alternative I is presented in Figure 11.
" Remedial Alternative J: Full Removal from Navigation Areas (G-P ASB Upland Disposal) (Supplemental EIS Modified Preferred Near-Term Remedial Action Alternative). Similar in some respects to Alternative G, the overall objective of Alternative J is to achieve SQS criteria in the WW Area, allowing for potential future deepening of the navigation channels, but avoiding disposal in the aquatic environment. Sediments in the navigation areas would be removed using hydraulic cutterhead dredges, and material would be disposed at the G-P ASB upland CDF. Existing habitat at the head of Whatcom Waterway would be protected, while accommodating public access improvements as proposed by the City of Bellingham. The existing sediment remediation/habitat restoration cap placed in the Log Pond as an interim action would be maintained. Whatcom Waterway would be dredged, including the maximum practicable removal of contaminated sediments from the federal channel, providing for future navigation flexibility. Steep slopes at Starr Rock would also be dredged. Where technically feasible, all contaminated sediments in the mid and outer Whatcom Waterway Federal Channel would be removed. The exception would be a relatively small volume of materials immediately adjacent to the G-P wastewater pipeline. Depending on final design, the total dredge volume from the Whatcom Waterway may approach approximately 760,000 CY. Prospective dredging areas located in the outer Whatcom Waterway navigation channel (e.g., units 1A and 1B; approximately 170,000 CY) would be evaluated during remedial design to determine whether sediments in these areas may meet regulatory criteria for unconfined, open-water disposal. Sediments meeting appropriate criteria may be beneficially reused either within the inner Bay for fills to enhance habitat function, or as ASB cap materials. Dredged material that does not meet these criteria would require confined disposal in the ASB."