The Georgia-Pacific Lagoon: Bust or Boon?

Wendy Steffensen is the North Sound Baykeeper with RE Sources.

The Georgia-Pacific (G-P) wastewater treatment lagoon is a hot commodity. One wouldn’t think it, to look at it, but it’s true. The beginning of the lagoon story starts back in 1978, when G-P was court-ordered to construct a pond to treat its mill waste. Back then, G-P’s effluent had severely contaminated the Whatcom Waterway—leaving it nearly lifeless, with sediments containing 0.5 to 37 ug/g of mercury. (For some perspective, the minimum cleanup level for mercury in sediments is 0.59 ug/g.) After 1979, the lagoon was used as a standard part of G-P’s waste treatment system, and it, too, is contaminated with mercury.

Now, in 2004, three processes are converging and attempting to claim this coveted and contaminated wastewater treatment lagoon. The processes are: the Bellingham Bay Pilot Project process to clean up contamination in Bellingham Bay; the Waterfront Futures Group visioning process to create a large-scale, future-looking, redevelopment plan; and the Port of Bellingham process to obtain the G-P lagoon for use as a marina. The players are: G-P, the Washington state Department of Ecology, the Port of Bellingham and the Waterfront Futures Group.

G-P, after shutting down most of its operations, now needs very little of the capacity of its wastewater treatment lagoon and would like to cheaply and efficiently clean up the contamination it’s responsible for. The cheapest approved place to put contaminated sediments is in its wastewater treatment lagoon. Just recently, G-P and the port have struck a tentative deal where G-P will give its land and—its contamination—to the port… free of charge. In this way, G-P will no longer be responsible for the cleanup, and therefore will not advocate for any specific cleanup plan, including the one where contaminants are placed in the lagoon.

The state Department of Ecology (Ecology) is mandated under the Model Toxics Control Act to ensure that appropriate cleanup happens and can legally require the most environmentally protective and cost-effective cleanup. In a 2002 decision-making document, the Department of Ecology stated that putting sediments in G-P’s lagoon was its preferred cleanup method.

A new Ecology decision-making document—the Supplemental Remedial Investigation/Feasibility Study (RI/FS) for Whatcom Waterway—was scheduled for release in July. This new document will incorporate the lagoon as part of the cleanup. Prior to the G-P/port land deal, Ecology’s preference was disposal of contaminated sediments in the G-P lagoon.

Now, the Department of Ecology has indicated that it will delay the release of its RI/FS, presumably until the port puts forth another alternative for cleanup. The port’s alternative will attempt to take into account appropriate cleanup, as well as its vision for future land use. Ecology will need to determine how the port’s alternative compares to the lagoon disposal option, in terms of protecting human health and the environment.

The Port of Bellingham has determined it needs an additional marina and has decided that the G-P lagoon is the perfect place and the perfect size, and has a lot fewer permitting problems than other sites would, since the breakwaters are already in place. In addition, the port has determined it no longer needs to accommodate deep draft vessels in the Whatcom Waterway, and so is advocating a less extensive cleanup, with shallower dredge depths in the waterway, making the overall cost the port might have to pay to get the lagoon substantially cheaper.

The port, being so convinced of the utility of the G-P lagoon, passed a resolution to initiate condemnation procedures to obtain the lagoon under eminent domain. The port’s move to condemn the G-P lagoon was likely a tool to push negotiations with G-P. Under the recent negotiated agreement, the port will acquire nearly all of G-P’s land in the county, including the lagoon, waterfront properties and some upland landfill sites. The port has 120 days to review and assess the contamination on all of the G-P lands it will be acquiring. The port has the option of backing out of the agreement, a likely outcome if the cost of cleanup greatly exceeds the value of the land.

The Waterfront Futures Group (WFG), the port- and city of Bellingham-appointed group charged with actually taking and incorporating public comment about what citizens would like to see for waterfront redevelopment, should be releasing their report on June 24. The public has the opportunity to comment on the report through the summer months.

The WFG members have decided they do not want the contaminated sediments stored in the lagoon. WFG members have also indicated, however, that they do not see a marina as the only possible option for the site; some members would like the site used for stormwater treatment. The ultimate decision of where sediments get disposed is not up to the WFG or the port—it’s up to the Department of Ecology.

So, what are the salient questions we should be asking ourselves at this moment in order to make an informed decision about the fate of G-P’s lagoon and the proposed G-P/port deal? There are three: Does our community need an additional marina? What should be done with the contaminated sediments? Is the G-P/port deal a good deal for our community?

According to a Port of Bellingham analysis, the demand for boating slips in 2025 will outstrip the supply by nearly 1,800. The port reasons that small boats can be dry-stacked, and large boats need slips. Converting G-P’s treatment lagoon into a marina would supply nearly 600 slips for boats that are larger than 40 feet. This is what the port intends to do.

From a community perspective, we need to ask ourselves what, if anything this would mean for our community. What would 600 large boats bring to the community? What economic benefit would their presence bring? The port would surely benefit through slip rentals, and some monies would trickle into the service and boat supply and servicing industries.

The cultural and community feel of Bellingham would also surely be altered to some degree. We can surmise that our funky little city would become a little more upscale. Would this mean a greater disconnect between the haves and the have-nots? Or would it bring a welcome economic and cultural change?

These questions are something that the community needs to actually discuss as a whole, because bringing a high-end marina to the city of Bellingham’s waterfront will surely change the character of our town. The installation of a marina should not be decided by the port without getting wide community input.

The installation of a marina would not only have economic, cultural and community impacts, but it would also have environmental effects. Boats and marinas are pollution sources. Marinas can be designed and operated to have either more, or less, detrimental effects, but they all pollute to some degree. Boaters can use good clean boating common sense or not; that is always an individual choice.

Pollutants from boats and boaters usually come from bottom paint, fuel spills, and discharge of sewage and gray water. These pollutants are not inconsequential. Copper found in bottom paint is extremely toxic in the marine environment, and the copper level in marina waters and sediments can be much higher than that allowed under Ecology standards.

Discharges of bacteria, viruses and chemicals into the water from sewage, gray water and fuel also put shellfish and other resources at risk. While these individual discharges may pale in comparison to industrial polluters, all of the discharges add up. They are especially problematic in sensitive areas, such as shellfisheries and swimming beaches, and where boats congregate.

The question of whether Bellingham should build a high-end marina should be decided on the merits of the case. A marina can never be truly needed. The community must decide whether it wants a marina, given its associated and cumulative economic, cultural, community and environmental effects.

Bellingham Bay is home to, quite literally, tons of contaminated sediments from past practices and historical discharges. As estimated in the Bellingham Bay Comprehensive Strategy (2000 and 2002), full removal of sediments contaminated above sediment quality standards would result in the removal of 2,400,000 cubic yards at a cost of $124 million. (This estimate included multiple cleanups; that at Whatcom Waterway as well as at Cornwall Avenue Landfill, Harris Avenue Shipyard and others.)

Instead of opting for full removal, the Bellingham Bay Pilot Project team opted in 2000 for removal and disposal of sediments that posed an impediment to navigation (820,000 cubic yards of sediments), into a confined aquatic disposal (CAD) site in the bay. The remaining contaminated sediments were to be capped, at an estimated total cost of $29 million.

In 2002, the comprehensive strategy was revised to include G-P’s lagoon as the preferred disposal location, at a cost of $25 million. This change was seen to be an environmentally superior disposal location. It was environmentally superior to the CAD option because capped contaminated sediments would no longer be subject to tidal action and the dredging of the contaminated sediments could occur without stirring up the sediments much, using a hydraulic dredge instead of a clamshell dredge. (See “A Critical Assessment of the Bellingham Bay Cleanup Project” by Robyn du Pré, Whatcom Watch, February 2001.)

Since the publication of the Bellingham Bay Comprehensive strategy documents in 2000 and 2002, additional sampling has been done. That sampling shows that contaminated sediments are being buried by river sediments. In some cases, contamination may be buried so deeply, that it is no longer considered “available” to the food chain.

The next Whatcom Waterway RI/FS will include various cleanup options and their estimated costs, and will indicate which option is Ecology’s preferred option. This new RI/FS will be different from the older versions because it will not only include the lagoon as part of the cleanup, but it will include the port’s alternative of less dredging combined with upland removal, and it will also include revised cost estimates.

RE Sources’ position has been that all contaminated sediments likely to have an adverse effect on the environment (roughly 1,100,000 cubic yards, according to the 2000 and 2002 documents), should be removed from the aquatic environment entirely, using the least disruptive method possible. RE Sources came to this position because, caps and CADs are not necessarily long-term solutions. They can be disrupted by vessel traffic, dragging anchors, storm events, tidal action, invertebrate burrowing and even gray whale feeding.

RE Sources also believes that the liable party must be held accountable for the costs of cleanup. If this were to entail hydraulic dredging of the contaminated sediments from the Whatcom Waterway into the lagoon, followed by upland disposal, so be it.

The Bellingham Bay Pilot Project has been going on since 1994—a full ten years. In that time, very little has been cleaned up, and progress has been slow. In that time, marine invertebrates have been incorporating the neurotoxin mercury and other contaminants into their bodies, and those contaminants have been translated up the food chain, some into the fishes that we eat. In that time, sediments from the Nooksack River have also been entering the bay and covering up some of the contamination, in what’s referred to euphemistically as “natural recovery.”

RE Sources believes that natural recovery should be looked at with a skeptical eye. When contamination is left in place, there is always the danger that it can resurface and be taken up by living organisms. We must carefully weigh the risks of dredging, capping and doing nothing. Our first priority is not to enable convenient redevelopment, but to ensure that the environment is protected.

RE Sources and the North Sound Baykeeper will be reviewing the available data with an eye on determining, once again, what is the most protective solution for the environment. That assessment will include analyzing the depth and concentration of contaminants, and the likelihood of their disruption or incorporation into the food chain.

The questions about what should be done with contaminated sediments and where should they be located if they are dredged will ultimately be decided by the Department of Ecology, the regulatory body in charge of making such decisions. The public can influence Ecology’s decisions by thoughtfully commenting on the findings, keeping in mind that Ecology must work within the framework of finding a solution that is protective of human health and the environment. Finding that environmentally protective solution is an actual “need.”

The fact that G-P property will be managed and owned by a public entity is definitely a promising development. It means that development can be better coordinated and that its design will incorporate some elements for the public’s benefit.

That said, it does not mean that the port’s vision of a marina is a worthwhile one, nor does it mean that Ecology’s vision of placing contaminated sediments in the lagoon is a poor one. I believe it will benefit us as a community to look at all of the questions separately, one at a time. We should not rush to endorse a vision, before we have thoughtfully considered the ramifications of its implementation. §

Part Two