The Custom Plywood Mill Site  Located on the shores of Fidalgo Bay,
the Custom Plywood Mill was built on fill and creosoted pilings over the
intertidal zone. Over its 90 year life, Custom Plywood was home to a sawmill,
wood-box factory, and plywood mill. Numerous leaks and spills and two fires
littered the intertidal zone. The traditional uses and history of accidents
have left the upland, shoreland, and intertidal zone contaminated with petroleum, metals, dioxin, and wood waste, and in need
of cleanup. The cleanup of the Custom Plywood site is part of the Anacortes Baywide cleanup process. Like all ecology sponsored cleanups, the public has the right to comment and affect the cleanup of this site. Background At the Custom Plywood site, the Remedial Investigation (RI) showed
that the majority of contaminants in the upland areas were petroleum products and
metals, whereas contaminants of concern in the aquatic portion were dioxins and
wood waste. Cleanup of the entire site is necessary to prevent exposure of humans, wildlife, and
fish to harmful concentrations of these contaminants. Click here to read more about why cleanup is necessary. The Feasibility Study examined a suite of cleanup alternatives
for the upland and for the aquatic portion of the site. As part of the
Feasibility Study, Ecology selected a preferred alternative for the
uplands and for the aquatic portion based on protectiveness, permanence,
and cost. For a brief synopsis of the Remedial Investigation and the contaminants present at the site, please click the link below:
A summary Powerpoint of the entire Remedial Investigation (RI)/Feasibility Study (FS), focusing on alternatives for the upland and aquatic cleanups can be found here.
Ecology
also determined that the upland cleanup should be expedited because the
uplands are eroding contamination into the water. To this end, Ecology issued
an Interim Cleanup
Action Plan
(CAP) for the upland area. This plan included more detail than the Remedial
Investigation or Feasibility Study (RI/FS) and focused solely on Ecology’s
preferred cleanup alternative. The Remedial Investigation, Feasibility Study, and Interim Cleanup Action Plan documents were released as part of the Interim Action Work Plan for the Custom Plywood site. Links to these documents can be found on the Department of Ecology's website. Why cleanup Custom Plywood?Industrial pollution on the shores of Fidalgo Bay
has contaminated the cleanup site with petroleum, metals, dioxin, and wood
waste. These contaminants can cause health problems in humans and wildlife. Contamination Exposure Pathways: (click the image to enlarge and see detail)  Dioxins refer to a group of chemicals that are bio-accumulative toxins, which
can cause a variety of ill effects in humans including; reproductive and
developmental problems, immune system damage, hormone disruption, and cancer.
Bio-accumulative means that the chemicals accumulate in organisms which are
transferred through the food-chain from the bottom up, and will eventually end
up in foods that humans consume. The risk of exposure to dioxins is especially
high for local subsistence fishermen. What are the consequences of disturbing contaminated soils & sediments on site?Contaminated soils and sediments will be disturbed during
excavation and dredging. In upland contamination removal, dust from the
excavation will need to be controlled. This is usually done by wetting down any
dry materials to suppress the dust and by covering stockpiles of materials. The
removal of contaminated sediments by dredging is a bit trickier. There will be
some suspended sediment that escapes the dredge bucket. Some of this sediment
will contain dioxins which will be redistributed to the water and the bay
floor. In any cleanup, one must ensure that the cleanup action will contribute
significantly to reducing the harm from the contamination. In this case,
removal of dioxins from the environment will result in a long term net benefit
to the health of the people and animals that use the area, despite the
potential for a short term increase in dioxin sediment suspension.
Upland CleanupEcology presented four options in the Feasibility Study for the upland cleanup. To learn about each option click here to download a poster, which explains all four cleanup alternatives. Ecology's preferred remedy (Alternative 3) for the upland area of the site includes removal of metal and petroleum contamination, up to 15’, within 75’ of the shore, and up to 6’, elsewhere.  This is a fairly protective option. However, exposure to remaining contamination is possible through exposure to groundwater, which flows through the contaminated areas seeps into fresh or marine surface waters. Groundwater will be monitored for contamination.
Ecology
has not yet responded to comments about the RI/FS and CAP for the upland cleanup
(June 2011). We believe that Ecology will proceed with its preferred option. For more information on the upland area cleanup click here to download RE Sources' fact sheet. Aquatic CleanupEcology presented 5 options in the FS for the aquatic cleanup. The proposed solutions for the aquatic lands consist of a combination of dredging and thin layer capping (TLC). Click here to view a poster, which explains each cleanup option.  In Ecology's preferred alternative (alternative 3), dredging is planned within 50' of the shore and where dioxin concentrations are high (above 25 parts per trillion(ppt)). TLC is planned where dioxin is between 10 and 25ppt. However, eelgrass is present in some of these areas and TLC presents a burial risk to them. To ascertain whether Ecology can effectively use a cap in eelgrass beds, 2-3inch placements of sediment over eelgrass will be tested in a pilot study. A CAP was not issued for the aquatic portion of the Custom Plywood site. Ecology is incorporating and addressing public comments on the RI/FS and will issue a more detailed Interim CAP for the aquatic cleanup in Spring 2012. The public will again be able to comment on this plan. For more information on the aquatic area cleanup click here to download RE Sources' fact sheet. HabitatUpland habitat consists of 3 freshwater wetlands and 2 estuarine wetlands, and the aquatic habitat consists of the shore interface and eelgrass beds. Some existing habitat at the Custom Plywood site has been harmed by the contaminants present at the site, and more habitat will be harmed by the cleanup actions themselves.  The Feasibility
Study (FS) determined that the 5 wetlands should be replaced by 1 large
estuarine wetland and that any eelgrass slated for removal during cleanup
activities would be mitigated in a 1:1.5 ratio. Restoration of the shoreline
will occur during cleanup and is proposed to include shore stabilization
measures to ensure that the shoreline does not erode any further. Click here for a discussion of habitat concerns and proposed solutions, and click here to view a poster of the three habitat cleanup alternatives. Public Involvement and Comments
The public has the right to comment on the documents released by Ecology. Your comments can affect how the cleanup happens and the outcome of the cleanup. The comment deadlines for the RI/FS and upland CAP have passed. The Cleanup Action Plan for the aquatic portion will be released in early 2012 and there will be a 30 day comment period for it, as well. Comments on the draft RI/FS and Interim CAP for the uplands are being assessed by the Department of Ecology. Many of these comments focused on the dioxin standard and the proposed habitat mitigation and improvements.Read RE Sources' Letter to the Department of Ecology. Click the following links to read the attachments to the letter: Attachment 1, Attachment 2, Attachment 3. Click here to read a letter submitted Swinomish Indian Tribal Community. And here, to read a letter by the Department of Natural Resources. Back to top Update June 2011
The public comment period for the Remedial Investigation/ Feasibility Study for the Custom Plywood site, and on the Interim Cleanup Action Plan for the uplands portion of the site has ended. Comments are now being assessed by the Department of Ecology. These will be incorporated into cleanup plans, as Ecology deems appropriate.  Preliminary work to prepare for cleanup of the uplands and to clear some of the surficial debris was done in April 2011 by the landowner of the site. For updates throughout the cleanup process stay tuned to this page, or email waters@re-sources.org to receive email updates. Ecology's response to comments will be posted as soon as they become available. Cleanup Time LineSummer 2011: Cleanup of the upland portion of Custom Plywood February-May 2012: Release of the Draft Interim Cleanup Action Plan for the aquatic portion of the site, with a 30 day comment period for the public to weigh in. Summer 2012: Cleanup of the in-water portion of Custom Plywood. Useful LinksThe Remedial Investigation, Feasibility Study, and Interim Cleanup Action Plan documents were released as part of the Interim Action Work Plan for the Custom Plywood site. These are found as links on Ecology’s Custom Plywood Page. They can also be found at the Department of Ecology repository locations in Anacortes and Olympia. The Anacortes Repository is located at the City of Anacortes Public Library, 1220 10th. St, Anacortes. For more information about Dioxin and to watch a presentation about its harmful affects on the Custom Plywood Mill site click here. For more information on specific contaminants in and around the Custom Plywood Mill Site and their health effects: 2006 Swinomish Risk Report and Department of Health 2010 Report on Fidalgo Bay |
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