by Bill Craven
I would have thought that transforming the scenic Bellingham waterfront into an industrial export hub for western Canada’s largest scrap metal company, ABC Recycling, would have generated a larger public buzz. Now, ABC has purchased 20 acres on Marine Drive from Lehigh Cement for the purpose of installing a highly polluting metal shredder, and the stakes just went up. Way up. Marine Drive is the location where cars and appliances will be shredded, trucked to the waterfront by truck after truck, then sent overseas creating a noisy waterfront operation no one expected to be so large. Probably not how you want to envision Bellingham.
Bellingham and Whatcom County will be the end point for thousands upon thousands of truckloads of scrap metal coming to Marine Drive mainly from western Canada. The port signed a lease for 15 years, with an additional 10-year option. Bellingham will bear the brunt of all the impacts from shredding, trucking, dust, pollution, and noise. It is high time before the November election for public conversations to occur about whether these particular land uses are in the best interest of the community at large.
We need some answers from county and city council candidates as well as the county executive and mayoral candidates.
These twin scourges did not even make the top 100 election issues identified by readers of the Cascadia Daily News. (1) That is how far below the radar this issue is with the public. Going forward, we ignore it at our peril.
Public Relations Staff
But ABC Recycling is not asleep. A recent Facebook post stated that a Ferndale city official has been hired by ABC to become its public relations flack here. So prepare yourself for a lot of spin about how the scrap metal business is environmentally beneficial, creates a lot of jobs, and complies with all public health, safety, and environmental regulations. Oh, if all that were only true. Incidentally, it looks like the Port of Bellingham’s PR machine has already launched a very similar misinformation effort. (2)
First year law students become acquainted with a famous U.S. Supreme Court case that was the first to uphold zoning regulations as a legitimate power of local governments. As stated by the Court, there are sometimes “right things in the wrong place like a pig in the parlor instead of the barnyard.” Bellingham and Whatcom County need to ask themselves if the scrap metal expansion here is swinish in nature. While recycling scrap metal may be noble in theory, Bellingham needs to decide if the waterfront operation should be modified. For its part, the county has to decide whether to consider a shredder at all. These operations need to find barnyards more appropriate for the work intended.
The shredder would be located just north of the Bellingham city limits on Marine Drive on approximately 20 acres of land recently sold to ABC by Lehigh Cement Company. (3) The land was never listed for sale so the transaction was between insiders. There was no opportunity for a public agency or a land trust to purchase the land for conservation or recreational purposes. The land is adjacent to access to Locust Beach. It is also adjacent to the Alderwood and Chartwell neighborhoods in the county, and the Birchwood neighborhood in the city.
Moreover, many neighborhoods across the city will be affected by the truck routes. Birchwood in particular is already home to Lehigh Cement and the Oeser Company’s telephone pole operation, both of which have issues — the shredder would make things dramatically worse, not to mention incredibly noisy, and the pollution issues have not even been addressed yet. North Bellingham neighborhoods are less affluent and more racially diverse than other areas of the city. Around the nation, these are the communities where land uses like these seek to locate.
Sweetheart Deal With Port
It’s easy to understand why ABC wants a shredder near Bellingham. It already has a sweetheart deal with the port for 15 years, with an additional 10-year option. It has a city that has been complacent while the port charges ahead. With a shredder on Marine Drive, it could create a supply stream of shredded materials for as long as it operates on the waterfront. The company has said it plans to expand into the United States. Bellingham is the target. ABC says it will generate five jobs at the waterfront Log Pond, and 20 at the Marine Drive location, truly a meager number for such a profound change to Bellingham and Whatcom County.
Reportedly, the Port Commission approved the lease without ever telling the city, its supposed “sister agency and much-touted partner” in redevelopment of the waterfront. It has also been well documented that the metal exporting activity at the waterfront and its accompanying noise and dust are inconsistent with various planning documents (4) and presumably inconsistent with the hoped-for lifestyle of those moving into the new housing within a stone’s throw of the scrap metal piles and the accompanying dust and noise.
For residents in established neighborhoods, the waterfront activity has proven to be a literal nightmare. The ships are loaded from 7 a.m. to 3 a.m. and create an unholy racket that makes normal sleeping impossible, as well as sending dust clouds along the waterfront both near the activity and some distance away. The South Hill Neighborhood has discovered that the allegedly city-approved zoning for the waterfront may not be what it seems. On Port of Bellingham land, the zoning is controlled by the city. There is considerable question whether ABC has the right to operate in open air with no enclosed containment of the scrap metal, and whether, additionally, ABC should stop work at 7 p.m. If the neighborhood is correct, ABC must also prove that it is not creating or handling solid waste which would require another permit as a solid waste handling facility. These might be good questions for voters across the entire city to ask city council and mayoral candidates at the next candidate forum headed your way.
Organic Air Emissions
So, what’s a metal shredder? The purpose of a shredder is to pulverize autos, appliances, and other materials so that the metallic substances can be separated from the nonmetallic substances to aid in recycling. A machine called a hammer mill breaks down the large metal pieces into smaller pieces, resulting in metal shredder aggregate. (There are videos of this on YouTube.) The metallic pieces are then shipped overseas. The nonmetallic pieces are further processed to sort out the nonferrous metals. Significant amounts of nonmetal materials are contained in the shredded materials, however, which can vaporize and become organic air emissions. These materials include plastics, paints, caulks, sealants, rubber, switches, fluids, and fluid residues. The remainder is residue and it is chemically treated and sent to landfills. Most shredders have permits that cover only particulate matter and fugitive emissions although, to repeat, it is not clear what permits ABC may receive.
One can peruse online industry publications to learn that “the pulverizing and shredding of scrap materials leads to the liberation of particulate emissions as well as volatile organic compounds (VOCs), hazardous air pollutants (HAPs) and nuisance odors. Scrap materials which are not completely drained of refrigerant fluids can emit chlorofluorocarbons leading to acid gas emissions. In 2021, the U.S. Environmental Protection Agency issued an Enforcement Alert because EPA and state investigations have found violations related to VOC emissions at several facilities.” (5)
This same article notes that while filtration technologies are effective for containing particulate matter, they are not sufficient to control the harmful VOCs which can pass directly through these systems and into the atmosphere. (Note: It is not clear what technologies, if any, ABC plans for its Marine Drive location. Unlike a good neighbor, ABC has thus far refused to answer any questions.) The VOCs that may be released into the air include lead, zinc, cadmium, mercury, and organic pollutants.
To achieve the industry-best “Best Available Control Technology,” a shredder must directly capture the air from a shredder to capture VOCs. This means that the shredder must be inside, preferably in a soundproofed building to ensure safety, mitigate noise, and also to capture dust, particulates, and VOCs. On top of that, the VOCs must be destroyed often through what is called a regenerative thermal oxidizer. A chemical scrubber is also necessary to remove any acid gases. (6) One example of this is a shredder in Minnesota said to be the most advanced of its kind in the world. It is fully enclosed and operates with negative air pressure. This minimizes the risk of pollutants running off material into the air or soil and contaminating the water table. Apparently, visitors can’t hear the shredder when it is running.
Concerned Readers Should Ask Questions
So, what will Whatcom County do? The short answer is that we don’t know yet, but several of us are asking the county to schedule some public meetings so that staff can answer questions from elected officials and the public can participate. The county needs to engage on three questions: What needs to happen to stop the shredder? Is a solid waste facility permit required or not for ABC’s current and future operations? And will any land use permits be required pursuant to the Whatcom County Code? It’s a confusing situation since metal shredding may be allowed in one provision of the code, while another provision may allow the county to require a conditional use permit which would allow various mitigation and public safety measures to be imposed. It seems logical that answering these questions sooner rather than later is in everyone’s best interest, including ABC Recycling. The second issue the county must confront is whether ABC needs a solid waste handling permit or not for either of its operations. The county has not yet required such a permit for the waterfront, but the law places the burden on ABC to show that they are exempt for each of their operations or go through the process for acquiring a solid waste handling permit. The County Health Department administers solid waste permits and should insist that ABC comply.
These are questions voters in the city and county might want to ask candidates for county executive and the county council.
Concerned readers can really help: First, ask city council and mayoral candidates if they support clarifying the zoning of the waterfront location and the city’s noise control ordinance to protect nearby neighborhoods. And, also ask county executive and county council candidates how they plan to stop the shredder or straighten out the county zoning code in order to authorize a conditional use permit so that mitigation measures to protect the environment and public health and safety can be developed.
This is the conversation we all deserve.
Endnotes
1. Citizen Agenda Form, Cascadia Daily News, July 14, 2023
2. https://www.portofbellingham.com/CivicAlerts.aspx?AID=392
3. https://salish-current.org/2023/05/12/b-c-metal-recycler-may-site-shredder-on-bellingham-bay/
4. Northwest Citizen, Port Priorities Subvert Their Own Plan, David Netboy, April 1, 2023
https://nwcitizen.com/entry/port-priorities-subvert-their-own-plan/search/bd1c48ad363cc6cd8edce2e2c947b695
5. For example, https://www.cpilink.com/metal-recycling-shredding-voc-control. The EPA enforcement alert may be found at: https://www.epa.gov/system/files/documents/2021-07/metalshredder-enfalert.pdf
6. https://www.cpilink.com/metal-recycling-shredding-voc-control
Background
by Bill McCallum
ABC Recycling is the largest metal recycling company in western Canada. They have nine locations in British Columbia and Alberta — their headquarters are located in Burnaby, British Columbia. They are expanding into the United States and they’ve chosen Bellingham as the main U.S. office.
2020
At the 12/8 meeting, the Port Commission passed an option agreement with ABC Recycling for 5.97 acres of property at the log pond (Waterfront District). ABC is purchasing property in Whatcom County to process recycled metal from the Vancouver area; the sale is expected to be finalized by the end of the year. The log pond will be used to collect, store and convey finished bulk scrap metal, and vessels at the shipping terminal will be loaded and unloaded with the scrap metal. The amount of scrap metal imported yearly is expected to be 40 metric tons: the first year exports are anticipated to be 60,000 metric tons, and 180,000 metric tons by the third year. Port revenue for the first year is expected to be $400,000 and increase to approximately $1 million in the third year.
2021
At the 4/20 meeting, the Port Commission authorized the executive director to purchase a crane from the Port of West Sacramento, California, for $151,000. Also included in the authorization was $834,515 to disassemble, load and transport the crane to Bellingham for a total cost of $994,515. The crane was purchased by the Port of West Sacramento in 2012 for $5,001,876. It was used briefly in 2012 and sat idle since then. It may need repairs once it reaches Bellingham. The crane is capable of lifting 124 metric tons with an outreach of 157 feet. ABC cargo was one of the justifications for the purchase.
2022
At the 6/21 meeting, the Port Commission approved a lease agreement with ABC Recycling for six acres in the log pond area and the use of the Bellingham Shipping Terminal. The lease is for 15 years, with a 10-year renewal option. The shredded and cut grade material will be stockpiled at the log pond for export from the shipping terminal. Recycled metal from western Canada will pass through the shipping terminal and be trucked to the ABC county site for processing. The amount of scrap metal imported the first year is expected to be 20 metric tons and 60 metric tons in future years. The amount exported in the first year is anticipated to be 81,000 metric tons and 320,000 metric tons in the third and future years. ABC is obligated to ship a minimum annual cargo volume of 60,000 metric tons — they are required to compensate the port if the minimum is not reached. The rent will be approximately $198,442 a year for the first five years. When the county facility is operating, ABC expects to have 26 employees at the two locations. The port estimates annual revenue from the shipping terminal and log pond at $525,000 for the first year and $1,530,000 by the third year.
____________________
Bill Craven is a retired environmental professional with more than 30 years experience as a legislative policy consultant on resource issues and as an advocate in state legislatures and for nonprofit organizations.
