by Luisa Loi
This is the chlor-alkali portion of the Georgia-Pacific West pulp mill site in 1969. These 36-acres are number eight on the dirty dozen list and where current cleanup efforts are focused.photo: Washington Department of Ecology
On a late October afternoon, Stephen Zylstra sat on a washed up tree trunk on the little pocket beach located at the northern end of Boulevard Park in Bellingham, as his dog played and greeted strangers.
Between 1890 and 1950 — before it became the peaceful corner it is today — that same spot was part of a manufactured gas plant that produced heat and light for Bellingham’s homes, leaving a legacy of contamination in the soil, groundwater and marine sediment (1).
Zylstra has lived in Bellingham for about five years. Like many locals, he’s aware of the presence of historically polluted industrial sites on Bellingham Bay. Among them, 12 are in the process of being cleaned up under the guidance of the Washington Department of Ecology.
Twenty-six years have passed since the Bellingham Bay Demonstration Project kicked off. The project is managed by the Port of Bellingham and Ecology and involves a variety of federal, state and tribal governments — plus Georgia-Pacific West, whose activity is responsible for a lot of the contamination — with the goal of controlling sources of pollution, and coordinating cleanups and habitat restoration efforts (2).
Today, some residents like Zylstra wonder what’s taking so long.
“I would like to see it done a little faster than it’s been done,” he said. “I know these things can sometimes drag on for 20 years or more. I believe they want to do the right thing, but I don’t always understand why it takes so long to assess the problem and to find the state or federal funding to clean up, especially if it’s a health hazard to marine life or people.”
No Easy Task
Addressing decades of contamination is no easy task. A few factors are to blame for this.
First, each site is unique and complex — some are bigger, others have contamination, mostly in the water, others may have areas that are too vulnerable for dredging.
Second, plans depend on the type and source of the contaminants.
Third, coordination between Ecology, liable parties and tenants is complicated, as it requires the parties involved to develop and sign different legal agreements and coordinate work. That is the case for active sites, where fieldwork needs to happen in a way that doesn’t impede business. The Potentially Liable Parties (PLPs) — which can include the City of Bellingham, the Port of Bellingham and private companies — are required to conduct the work under the guidance of Ecology.
“A lot of times the delays happen because there’s just a lot of moving parts,” said Kirsten McDade, pollution prevention specialist for RE Sources, a nonprofit environmental organization. “A lot of permits to align, different entities — you have the Port of Bellingham, the City of Bellingham, some industries that are operating on the facilities that are still working, and then you have the Department of Ecology.”
Last, but not least, the pandemic drastically changed the projects’ schedules.
The Department of Ecology oversees the cleanup at each site, following Washington’s cleanup law, the Model Toxics Control Act, and the Bellingham Bay Comprehensive Strategy, which identifies priorities in the bay to guide cleanup and restoration efforts (3).
Completing a step often requires each party to either create a new legal document or amend the existing legal document. Other steps require public feedback on planned work before moving onto the next step, said Ian Fawley, Ecology’s outreach specialist.
“I hear people complaining about the process,” McDade said when asked about the small number of comments submitted during public comment periods. “But I don’t see them using the avenues available for them to make comments. And I think that’s a missed opportunity.”
When a step needs more time to be completed, those liable may obtain extensions. “When something is done, something else has to be done by a certain amount of days or months,” Fawley said. “If there is any added time that’s needed to complete it, then you have to amend, and special permission has to be granted to be able to do it.”
Some sites may need to be addressed more urgently than others. McDade said significant damage may suddenly occur at a location, requiring the parties involved to shift their attention from the site they were working on, where the contamination poses a smaller risk to the environment.
Nevertheless, work continues at most of the sites. One day, the waterfront will look much different than now.
“I would rather have the process be delayed than have a process that’s hurried and not thorough,” McDade said. “When I moved to Bellingham in 2001, there were just very few places for a community person to access the water, it was just all industry. Seeing the transformation of the waterfront is pretty exciting.”
The Dirty Dozen
1. Eldridge Municipal Landfill
Location: Little Squalicum Park, west of the Bellingham Technical College campus parking lot
Size: 32,000 square feet
Cost: $709,137.61, according to information provided by Scarlet Tang from Ecology
Liable party: City of Bellingham
Current use: The site is part of an off-leash dog park
In 2011, the city conducted an interim action on the site, removing about 4,290 tons of waste and contaminated soil. Workers later filled up the excavated area with 4,310 tons of clean sand and gravel, covering it with a four-inch layer of topsoil. Some areas deemed to be too close to a wetland or too steep and unstable for excavation were left untouched and are protected by site use restrictions, while the excavated areas were revegetated and used to create a 750-square-foot wetland area (5).
Following the interim action, a feasibility study concluded that the cleanup work was complete. According to Ian Fawley from the state Department of Ecology, the most recent groundwater monitoring and sampling, completed in March 2017, found levels of dissolved iron to be higher than compliance levels, but attributable to natural causes. A periodic review in 2026 will determine whether more sampling is necessary.
The cleanup addressed contamination and debris that covered 32,000 square feet, which resulted from residents using the site to burn and bury trash in the 1930s. The contaminants found on the site that exceeded cleanup levels included arsenic, cadmium, copper, lead and mercury (5).
2. Weldcraft Steel & Marine
Location: Northern Corner of Squalicum Harbor, at 2651 Harbor Loop Drive
Size: 2.5 acres, 1.9 in the water and 0.6 on land
Cost: $5.2 million since 2015
Status: In progress
Liable party: Port of Bellingham
Current use: Used for boat repair and maintenance, leased from the Port of Bellingham by Seaview Boatyard North since 2004
An interim action conducted in 2004 removed about 6,800 cubic yards of contaminated marine sediment and creosote-treated timbers — creosote is a pesticide and fungicide that is toxic to fish — while also creating over two acres of shallow intertidal habitat (7).
The cleanup-action plan, while initially expected to be developed in 2016, is now scheduled to be completed and submitted for a public comment period in 2023. The delay, according to Fawley, was because the site was less of a priority compared to other sites. The cleanup planning, according to Tang, will consider redevelopment needs to keep the site operational in the future.
The site has been in use since 1946 for the fabrication, repair and maintenance of boats, resulting in the presence of copper and tributyltin (antifouling agents applied to the bottom of boats to prevent marine organisms from attaching and growing on them), diesel and gasoline compounds (introduced by leaky underground storage tanks), in the sediment, groundwater and soil (8).
3. Marine Services Northwest
Location: Squalicum Harbor, near CityMac
Cost: No estimates yet
Status: Waiting for the remedial investigation and feasibility study
Liable party: n/a
Current use: The site is a boatyard
Among the 12 sites, Marine Services Northwest is the one most behind. According to Fawley, the site did not represent an immediate concern, so a remedial investigation and feasibility study has yet to be conducted to further assess the contamination and develop cleanup options.
Due to past boatyard practices, the site contains tributyltin and likely metals, diesel and gasoline components (9).
4. I & J Waterway
Location: between Hilton Avenue and Bellwether Way
Size: 3.1 acres
Cost: Estimated $24 million for construction, $1.1 million for design cost
Status: In progress
Liable parties: Port of Bellingham (owner since 1944) and Bornstein Seafoods Inc.
Current use: Navigation channel
The site is divided in two main areas, Sediment Cleanup Unit-1 (SCU-1) and Sediment Cleanup Unit-2 (SCU-2). According to Fawley, the engineering design of the cleanup action for SCU-1 is almost done, and Ecology is expecting to reach 90 percent of completion of construction plans and specifications early in 2023.
“The next public comment period for SCU-1 will be for a legal agreement requiring construction of the cleanup action, and is currently scheduled to occur in mid-2023,” Fawley wrote in an email.
Engineering design and construction of the cleanup action for SCU-2 will take place under a separate legal agreement, which will be developed when construction of the cleanup action for SCU-1 is complete, likely in 2025, Fawley wrote. The legal agreement will be available to the public for feedback.
In 2015, the port conducted a study on the site, which has been used for industrial purposes since 1944, finding: polycyclic aromatic hydrocarbons, also known as PAHs, these chemicals can affect people’s blood and liver, and may lead to cancer; phthalates, which, according to the Centers for Disease Control (CDC), have unclear effects on human health; phenols, whose effects can range from irritation to liver and kidney damage, according to the CDC; and nickel in the marine sediment.
These contaminants were possibly introduced by lumber mill operations, rock crushing, stormwater, the Bornstein Seafoods building fire in 1985, and a food processing plant which operates to this day. Other contaminants of different origin were also found. Dioxins/furans are found across Bellingham Bay and might derive from old pulp and paper mill operations, wood treating operations, and present burning activities. Mercury was present due to the Georgia-Pacific Pulp Mill, while the source of polychlorinated biphenyls remains unknown (10).
5. Central Waterfront
Location: Between I & J Waterway and Whatcom Waterway
Size: 51 acres
Cost: The cost for design and construction, excluding long-term monitoring following the cleanup, is about $6.2 million through 2027
Status: In progress
Liable parties: The Port of Bellingham and the City of Bellingham
Current use: Several businesses occupy the area
The review of the draft engineering design report for Central Waterfront, which according to Fawley was granted an extension during the summer, has been completed. In 2020, Ecology estimated construction work to begin in 2022, but the start date was pushed back.
“This is a complicated site in terms of the variety of remedial actions, and tenant and redevelopment coordination,” Tang wrote in an email sent to Whatcom Watch in November 2022. “As a result, it is possible that we may end up sequencing engineering design and construction activities.”
Previous work at the site included the removal of contaminated groundwater, timber piles, 800 cubic yards of petroleum-contaminated sediment, restoration of a beach area, capping of contaminated soil, and construction of a boat manufacturing building. The measures are designed to cap the contamination while also presenting a system that controls the buildup of gas underneath (11).
The site was once used for various industrial purposes, such as timber operations, municipal landfilling, gas storage and fueling, ore and cement processing, coal storage and boat repairing (12).
Contaminants found on the site include metals, petroleum hydrocarbons, polycyclic aromatic hydrocarbons, volatile and semi-volatile organic compounds (11).
6. Holly Street Landfill
Location: Old Town District, by the Holly Street bridge on Whatcom Creek
Size: 13 acres
Cost: About $2 million
Status: Completed in 2005
Liable party: The City of Bellingham
Current use: The site is a partially restored habitat area with boardwalk and viewpoints
Between 1905 and 1953, residents used debris and scrap materials to fill up the tidelands and create upland areas, covering 12.9 acres of landscape with trash (6). Contaminants found at the site include copper, zinc and methane.
Cleanup work at this site consisted of removing about 12,400 tons of waste, after which the upland areas were changed to their old intertidal form. The city then reintroduced native plants and removed invasive species, capping the remaining waste to prevent copper and zinc from contaminating Whatcom Creek (6).
A review of the completed work, initially expected to happen in 2022, will likely happen later in 2023 due to staff availability, according to Ecology’s communication manager Scarlet Tang.
7. Whatcom Waterway
Location: At the mouth of Whatcom Creek
Size: More than 200 acres, this is the largest of the 12 sites
Cost: $31 million for Phase 1 areas, $63 million estimated for Phase 2 areas
Status: In progress
Liable parties: The Port of Bellingham and Georgia-Pacific Corporation
Current use: Navigation channel
The site is divided in two areas — Phase 1 and Phase 2.
The cleanup action plan and the consent decree for the Phase 2 areas will be amended because, according to Tang, the port has changed land use plans for that portion of the site. Since the consent decree was lodged in Whatcom County Superior Court, the documents need to be formally amended and issued for public review in spring, Tang wrote.
The amendments, she said, will also include work to control erosion and sedimentation on the site that will allow them to prioritize cleanup at the Bellingham Shipping Terminal, for which the port has received a federal grant. It estimates dredging could start in late summer 2023.
Phase 1 was completed in 2016, and its cleanup consisted of removing 111,446 cubic yards of contaminated sediment, 9,962 tons of soil, 265 tons of creosote-treated timber and 5,146 tons of concrete and asphalt — over 98 percent of which, according to Ecology, was recycled. Cleanup work also involved placing measures to prevent leaks, like capping contaminated sediment with 102,950 cubic yards of clean material (13).
Contaminants found on the site, which include mercury and phenolic compounds, mainly come from the Georgia-Pacific Pulp and Tissue Mill and the Central Waterfront sites, while the rest comes from creosote-treated timber and fossil fuels (14).
8. Georgia-Pacific West
Location: 300 West Laurel St., on the south side of Whatcom Waterway
Total Size: 74 acres
Size of the Lignin Operable Unit: About four acres
Cost: Estimated $8,915,000 through 2027
Status: In progress
Liable party: The Port of Bellingham
Current use: The cleaned-up G-P pulp and tissue mill area are now part of Waypoint Park, the pump track and the Granary building.
In 2013, the Port of Bellingham — which bought the lignin property from Georgia-Pacific in 2005 — and Ecology split the site into two separate areas to expedite cleanup efforts.
The 38 acres of what once was the pulp and tissue mill area of the site were cleaned in 2016 (15).
The chlor-alkali area, which is 36 acres, includes the Lignin Operable Unit, where the cleanup efforts are currently focused, to allow Mercy Housing Northwest to purchase the property and begin construction by the end of 2022. Mercy Housing is a nonprofit that develops affordable housing (14).
The site, according to McDade, should be safe for residential development. Initially, the remaining contaminants were planned to be capped, but, due to the site’s future use, contaminants will be removed and disposed of at a different location to protect the health of residents.
Cleaning up the lignin parcel involved the removal of about 13,600 tons of contaminated soil and 5,900 tons of debris (15).
As of Nov. 29, the above-ground structures have been removed from the site, and the soil removal will follow soon. According to Fawley, the cleanup of the lignin parcel is on track to be completed by the end of the year — being one of the sites that saw the fastest progress, he said. After the cleanup, the port will keep monitoring the site.
The rest of the chlor-alkali site will be addressed under a second consent-decree amendment that will likely be developed in 2023-2025, according to Fawley.
The lignin portion used to have a warehouse where the byproduct of paper-pulping processes, lignin, was stored to be converted into products like vanilla flavoring and pharmaceuticals. Tanks containing liquid waste from producing lignin were also present on the site. Investigations found the presence of metals and PAHs in the soil and metals in the groundwater. However, it does not present traces of mercury (15).
9. RG Haley
Location: At the end of Cornwall Avenue, on the waterfront
Size: 26 acres, six upland and 20 in water
Cost: Completion of the engineering design report is expected to cost about $1.5 million, while future construction work will cost about $21 million
Liable party: The City of Bellingham
Current use: The site is closed to the public and contains old buildings, wired fencing and barrels with contaminated material from past investigation work
From the mid-1800s to the mid-1900s, this site was used for lumber, coal and wharf operations. A remedial investigation/feasibility study conducted in 2016 found petroleum hydrocarbons, pentachlorophenol (PCP), polycyclic aromatic hydrocarbons (PAHs), and dioxins/furans. Other contaminants include mercury from the Whatcom Waterway site and phthalates, metals and polychlorinated biphenyls from the Cornwall Avenue Landfill site (17).
10. Cornwall Avenue Landfill
Location: Southwest of RG Haley, and at the end of Cornwall Avenue
Size: 16.5 acres, 13 upland, 3.5 in water
Cost: About $16 million. According to Scarlet Tang, costs increased from the initial $9 million estimate because designs need to be revised to address sea-level rise projections and future eelgrass mitigation requirements
Liable parties: The Port of Bellingham, the City of Bellingham and the Department of Natural Resources
Current use: The site is closed to the public, and is recognizable from the large mounds of soil covered in plastic
Starting in 1888, the site was used for sawmill operations, turning into a municipal landfill from 1953 until 1962. The contaminants identified — including metals, ammonia, petroleum compounds, PCBs and PAHs — mainly come from municipal and wood waste, but also from the RG Haley and Whatcom Waterway sites. An investigation conducted on the site found an estimated 295,000 cubic yards of municipal waste and 94,000 cubic yards of wood waste (18).
Cornwall Avenue Landfill and RG Haley will be developed into a new 17-acre waterfront park with public access and wildlife habitat (19). For this reason, these neighboring sites have “intertwined” cleanups, Fawley said.
However, Cornwall is a little ahead in the process, and is waiting for RG Haley to catch up. Cornwall’s cleanup-action plan and engineering design are complete, but the cleanup is waiting for the completion of RG Haley’s engineering design. Because they will be cleaned together, the two documents must be completed at the same time, Fawley said.
The engineering design for the in-water portion of RG Haley is expected to be completed by 2023 with the cleanup starting in 2024 (19).
11. South State Street
Manufactured Gas Plant
Location: Northern end of Boulevard Park
Size: 30 acres, six upland and 24 in water
Cost: Estimated $9.3 million
Liable parties: The City of Bellingham and Puget Sound Energy
Current use: It is part of Boulevard Park
According to Fawley, the engineering design is still in the works as of November 2022. “The Pre-Remedial Design Report is now scheduled for delivery to Ecology by the end of 2022, with the engineering design completed by the end of 2023,” he wrote in an email to Whatcom Watch.
Contamination found in the groundwater, soil and sediment comes from the manufactured gas plant that operated between the 1890s and the 1950s, the lumber mill operations and the railroad (20).
An interim action, conducted in 2017, removed creosote-treated wood structures and piles, stabilized a concrete bulkhead and placed rocks to prevent 450 feet of soil from being eroded and leaking into the bay. Future work will involve further modifications to the rock barrier and capping of contaminants (19).
12. Harris Avenue Shipyard
Location: 201 Harris Ave., between the Bellingham Cruise Terminal and Marine Park in Fairhaven
Size: 10 acres, five upland and five in water
Cost: About $28 million
Liable parties: The Port of Bellingham and Univar Solutions USA Inc.
Current use: The site still operates as a shipyard, and is used for other marine-trade purposes
According to Fawley, the pre-remedial design investigation field work is complete, with a report expected to be released before the end of 2022 — as of November 2022. The engineering design report draft is due 180 days after the report has been received, and a final copy is due 60 days following the comment period on the draft.
The site contains contamination from more than 100 years of shipbuilding and other industrial activities, which continue to this day. The port found petroleum hydrocarbon compounds, metals, polychlorinated biphenyls, polycyclic aromatic hydrocarbons, and semi-volatile organic compounds on the site (21).
Between 2017 and 2018, the port conducted an interim action on the site, removing wooden and creosote-treated structures, dredged subtidal sediment, excavated and backfilled intertidal areas, excavated soil and capped the remaining contaminated soil with gravel, and replaced the creosote-treated pier with a concrete and steel pier (20).
Some of the contaminants found on the sites are listed by the World Health Organization (WHO) as among the 10 chemicals or groups of chemicals of major public health concern.
1. Arsenic: depending on the exposure levels, inorganic arsenic may cause skin lesions, diabetes, cardiovascular diseases, cancer, peripheral neuropathy (damage to the nerves outside of the brain and spinal cord), gastrointestinal symptoms and developmental disorders.
2. Cadmium: this chemical is a carcinogen, and it can affect kidneys, the respiratory system and the skeletal system.
3. Dioxins: these chemicals accumulate in the food chain and can affect development, reproduction, the immune system, hormones, and may lead to cancer. Dioxins include polychlorinated biphenyls (PCBs).
4. Lead: depending on exposure levels, this metal can affect the nervous, cardiovascular, renal and gastrointestinal systems.
5. Mercury: a metal that affects early development, the nervous and immune systems, the lungs, kidneys, skin and eyes.
Bellingham Bay Action Team
The team, mostly led by the Department of Ecology, continues to coordinate in-water projects with the guidance of the Bellingham Bay Comprehensive Strategy.
• Port of Bellingham
• City of Bellingham
• Whatcom County Health Department
• Lummi Nation
• Nooksack Tribe
• Washington State Department of Fish and Wildlife
• Washington State Department of Natural Resources
• Puget Sound Partnership
• NOAA Fisheries
• U.S. Army Corps of Engineers
• U.S. Environmental Protection Agency
• U.S. Fish and Wildlife Service
• Community Participation: RE Sources
3. Bellingham Bay Comprehensive Strategy, Final Environmental Impact Statement
7. Remedial Investigation/Feasibility Study Report Weldcraft Steel and Marine
10. I & J Waterway Cleanup Site Fact Sheet
15. GP West Cleanup Site — Lignin Operable Unit Fact Sheet
20. South State Street Manufactured Gas Plant Site, Fact Sheet
Luisa Loi is a freelance reporter based in Bellingham with an interest in covering local environmental issues. You can learn more about Luisa through her LinkedIn (Luisa Loi), or by reaching out to luisaloi@ live.com.