PUBLISHED IN THE CASCADIA WEEKLY

August 30, 2006

It’s time to cleanup the mercury in Bellingham Bay

Within the next month, the decision-making document that will direct the clean up in Bellingham Bay should be released by the Washington State Department of Ecology (DOE).  This document, called a Remedial Investigation/Feasibility Study (RI/FS) will contain several cleanup options for the Bay and the ASB (Aerated Stabilization Basin or treatment lagoon), and recommend a preferred cleanup plan. Upon release of the RI/FS, the community will have the opportunity to officially comment on the adequacy of the recommended clean-up option.

I, as the North Sound Baykeeper, will ask for the most protective remedy for cleanup of mercury:  a full dredge removal of mercury in the Whatcom Waterway, ASB, and adjacent areas, and upland disposal to a certified hazardous waste landfill.

The decision to ask for a full dredge removal did not come lightly.  I, along with my Public Participation Panel, a group of learned scientists, have been meeting over several months discussing the data, asking critical questions, and considering the best solution to cleanup the mercury.  We looked at the extent of contamination in the Whatcom Waterway and ASB. We examined the evidence for the euphemistically named “natural recovery”, or burial of contamination by clean Nooksack River sediments. We evaluated the varying methods with which DOE could sanction a cleanup. After months of deliberation, we decided that the very protective approach of a full dredge removal and upland disposal is needed to protect habitat, aquatic organisms, and public health due to mercury’s nature as a persistent, bioaccumulative, and potent neurotoxin. 

Removal of Mercury in the Whatcom Waterway

What does full dredge removal of mercury really mean?  It means that mercury contamination should be removed, by dredging, wherever it occurs above the Minimum Cleanup Level (0.59 parts per million), until the contamination is fully removed.   One might think that this is what would normally occur, but that’s not the case. DOE allows cleanups to be either a cap (burial with clean sediment) or dredge solution, rarely considers contamination at depths greater than 3 feet, and can override the Minimum Cleanup Level (MCL), given results of additional tests.

By asking for complete removal of mercury where it is above the MCL, we are asking for the Department of Ecology to:

• Enforce the Minimum Cleanup Level standard for mercury in Bellingham Bay;
• Take into account the potential that buried mercury might be resuspended by storm events, biologic activity and human disturbance;
• Take into account the persistent nature of mercury;
• Act in the long-term interest of the community and environment.

Full removal of mercury is the most prudent action to take for cleanup of the environment. Its importance is illustrated particularly well at erosional sites and at the head of the Whatcom Waterway. By fully removing the mercury in the southwest  erosional corner of the Whatcom Waterway, for example, we eliminate the potential of continued mercury contamination into the Bay. Likewise, mercury at the head of the Whatcom Waterway, an extension of the Whatcom Creek Estuary, must be fully removed because it is both valuable habitat and subject to high rates of formation of methylmercury, the most toxic form of mercury.

Removal of Mercury from the ASB

We are also asking that mercury from the Whatcom Waterway, Bellingham Bay, and the ASB lagoon be removed and disposed of in a certified and protective upland landfill, designed and sited specifically for waste disposal. To be most protective of the environment and community health, containment of mercury waste should be secure, using a landfill with double-liners, leachate and off-gas collection, and minimal rain penetration.  The treatment lagoon does not offer this protection.  Engineering the lagoon to be as protective as a dry upland site will be costly and difficult at best. Additionally, the lagoon is subject to Western Washington rainy weather, wind and wave action, and potential sea level rise from global warming.

Of equal importance is our request that the ASB return to aquatic habitat, not for the purpose of a marina, but to function as land that once existed as part of the larger Whatcom Creek Estuary. We acknowledge that if the ASB returns to water, it will likely be the home of a marina and marinas are not prime habitat. Regardless, we have lost hundreds of acres of aquatic habitat by filling in tidelands of the Bay, and restoration of valuable lost habitat could be achieved by returning the ASB back to the water.

When the RI/FS comes out this next month, I will be asking for a full dredge removal of all of the contamination, and upland disposal as well as a restoration of the ASB as marine habitat. I hope that you also will weigh all of the facts and engage in asking for the best clean up possible.

 If you have been following the numbers in this series of articles, you may be a bit confused. Here are some explanatory notes:

The cleanup standard in soil for unrestricted use for mercury: There are two methods to determine cleanup levels. The most stringent and straight-forward method, states that mercury should be cleaned up to 2 parts per million. The other standard is based on a technique called risk assessment and usually is about 24 parts per million, depending on the inputs fed into the risk assessment. Risk assessments are a valuable tool, but they are only as good as the data and assumptions that go into them. When it comes to a persistent, bioaccumulative neurotoxin, I believe we should expect the highest level of cleanup, not just an adequate one. I will be arguing for the most stringent standard if we fill in the ASB.

The levels of contamination in the Whatcom Waterway versus the ASB: Currently mercury levels in the ASB range from 0.13 to 20.2 parts per million, whereas mercury in the Whatcom Waterway surface sediment ranges from 0.51 to 2.55 parts per million, based on the most recent sampling in 2002. Subsurface samples taken in 1996/1998 ranged from 0.51 to 12.  Note that cleaning up the surface sediment layer, the biological zone, is the layer where DOE  focuses their cleanup action, and that’s why everyone talks about it. Subsurface contamination, usually to a depth of 3 feet, can also get cleaned up if it is thought that it may re-contaminate the biological zone.   

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