Little Squalicum Park: Cleanup Update

Matt Krogh is the North Sound Baykeeper with RE Sources for Sustainable Communities, and has written for Sustainable Industries and Planning magazines. A 20-year resident of Bellingham, he is a repeat offender at Huxley College with a background in environmental education and geography.

As City of Bellingham road crews finish construction of the new Illinois Street connector, a new flurry of excavation and machinery will roll into Little Squalicum Park. Targeted at cleaning up the toxic legacy of Oeser Company’s pole treatment facility, the park will be closed into October as Oeser crews, supervised by the Environmental Protection Agency (EPA), excavate thousands of cubic yards of contaminated soils.

This cleanup has been years in the making. Starting in the 1940s when Oeser started treating telephone poles with preservatives, the soils, sediments, and waters of Little Squalicum park have been contaminated by a myriad of chemicals that harm people and wildlife.  Although a 2003 Superfund cleanup of the Oeser property failed to detect contamination in the park, a more recent study by the City of Bellingham and the Department of Ecology (Ecology) found sufficient levels of contamination to warrant action, leading the EPA to prepare a second plan targeted at cleaning up Oeser’s pollution of the park area.  In the short term, plans for the cleanup should improve the park to a safe standard for temporary human use and recreation; in the long term, the cleanup may not be adequate.

Under the cleanup plan decided upon by the EPA (after consultation with Oeser, the City of Bellingham, Whatcom County, and the public), Oeser staff will excavate known areas of contaminated soil as found by soil and water samples over the years. In the current creek bed, excavation will range from 1’ to 6’ deep, depending on earlier soil and water sampling results. The creek will be permanently re-routed into its historic channel before the current creek is excavated.

Contaminated spoils from excavation will be transported to Oeser’s property where it will be stored on an impervious surface and capped with 6 inches of gravel. Should there be too much volume for storage on Oeser’s site, spoils with low levels of contamination will be stored in the park in what the EPA calls a “repository,” located above the 100 year flood mark and capped with 8 inches of gravel and 2 feet of clean soil.  Excavated areas will be backfilled with clean soils and revegetated.

Here’s where the question of long-term safety gets tricky, though. Since this lower cost cleanup plan doesn’t remove all contaminants, the EPA has proposed a monitoring regime. This monitoring regime will test for contaminants from Oeser’s stormwater outfall, the stormwater outfall from the Bellingham Technical College, and at various points along the creek bed.

In theory, monitoring will be able to detect any re-contamination of surface water and soils by failing repositories at Oeser or on-site in the park, or any failure of the capped areas in the park along the current stream bed. These toxic contaminants — polyaromatic hydrocarbons (PAHs), heavy metals, pentachlorophenol (PCP), and dioxins — can pose risk to humans even at very low levels, causing cancer and harming the immune and reproductive systems.

Unfortunately, the monitoring plan derives from the hypothesis that the contamination moved primarily, or entirely, through surface water, even though movement of contaminants through groundwater has been postulated by Ecology and the City of Bellingham’s consultant to explain how some hot spots of diesel oil and pentachlorophenol have been transported through the site. In addition, the depth at which soil samples have been bored may not have been deep enough to discover subsurface movement of contaminants.

On the bright side, during their 5 August open house the EPA assured the public that excavation would be monitored closely, and that excavation would continue beyond planned depths if more contamination were to be discovered. Finding clean soil will stop excavation activity, however, even though clean soil may not indicate that the site is clean beneath that point. It may only be a layer beneath which contaminants currently in ground water or previously transported via ground water hide.

It is difficult to evaluate the EPA’s planned monitoring scheme when the scheme, unlike the rest of the cleanup plan, is not yet fully formulated. Even when the monitoring plan does become available there is no mechanism for the public to comment upon it. EPA does not have to accept or respond to public comment, because the public comment period on the draft plan ended in March, and there is no public comment period for the final plan. But if the EPA and Oeser refuse to permanently remove the contamination to a dry-area storage facility on the east side of the Cascades, the only remaining assurance of public safety is a quality monitoring plan that samples for both surface AND subsurface movement of contaminants.

The cost difference between the cleanup plan the EPA chose and the permanent removal of all contaminated soils is significant, on the order of 5 times as much if the assumptions about volume of contaminated soils are accurate. Costs are in the range of $8 million for permanent cleanup versus the approximately $1.5 million anticipated to be spent on this cleanup, with ongoing monitoring an additional expense.

But the question remains — if contaminants are found to be migrating to the surface, how much more will it cost to re-do the cleanup? The monitoring plan exists precisely because there is a chance of re-contamination. Who will pay for a second cleanup, if Oeser and the EPA are no longer involved?

Over the years, we have increasingly come to understand that traditional ways of running industry leave a toxic legacy that is extremely pricey to clean up, for taxpayers and companies both. In cases like the Little Squalicum cleanup, the EPA’s choice shows a societal willingness to defer the problem to future generations — at some time, the caps will fail. This is not a permanent solution.

With appropriate industrial management now, we can avoid making our grandchildren deal with the same sorts of cleanup choices for the industry we currently benefit from. We can require non-toxic air emissions. We can require stormwater controls that prevent contaminated runoff from industrial sites. And we can require that industry treat all emissions before discharging into surface or marine waters.

The temporary solution is to clean up the toxic legacy we already have. The permanent solution is to make sure it doesn’t happen again. §