Cleaning up: On Bellingham’s waterfront, a cleanup plan for the Chlor-Alkali Area

When industrial chemicals form the very name of a contaminated site, that’s a good sign that cleanup will involve some complex environmental and scientific work. The Chlor-Alkali Area of the former Georgia-Pacific West pulp mill on Bellingham Bay is a case in point.

We’re taking public comments through August 4 on a cleanup plan that will have four stages, with each one a major cleanup project in its own right. This part of the former pulp mill produced chemicals for bleaching pulp. It contains numerous areas where toxic materials from this process contaminated soil and groundwater.

The plan calls for treating, removing, and capping contaminated soil; treating and monitoring groundwater; and restricting future activities in certain areas.

The following documents are available for review:

• Cleanup Action Plan: Describes the cleanup work to address contamination at the Chlor-Alkali Area of the Site.
• Agreed Order Amendment:  Our legal agreement with the Port of Bellingham requiring design of the work described in the cleanup action plan. The port will sequence this design through four separate projects.
• State Environmental Policy Act Determination of Non-Significance: Our determination that the cleanup work is not likely to harm the environment.

Public meeting

You’re invited to an online public meeting, where we’ll explain the contamination, past cleanup work, the final cleanup plan we’re proposing, and how it will protect public health, safety, and the environment:

Wednesday, July 14, 2021

• 6:30 – 7:30 p.m.:  presentation
• 7:30  p.m.:  question/answer time (as needed)
• Register and join meeting.
• Call Ian Fawley, Outreach Specialist, 425-324-5901, for dial-in options and other online meeting support.

Online site tour

Take a virtual guided tour, with informational videos, created by RE Sources through a Public Participation Grant.

Cleanup Action Plan

In June 2018, the port — with our oversight — completed a feasibility study assessing a range of cleanup options for the Chlor-Alkali Area of the Georgia-Pacific West site. Based on this work and an environmental study (Remedial Investigation) completed in 2013, we prepared a cleanup action plan to address contamination at the Chlor-Alkali Area.

The planned cleanup actions shown on this figure include:

• Removal of below ground objects, followed by in-place treatment of mercury-contaminated soil
• Removal and disposal of approximately 7,000 cubic yards of mercury- and petroleum-contaminated soil and debris
• Capping contaminated soil to prevent:
  • rainwater from flowing through the soil and carrying contaminants to groundwater
  • people, plants, and animals from coming into contact with contaminants
  • erosion into Bellingham Bay
• Groundwater treatment to neutralize high pH (caustic) that can dissolve and mobilize contaminantsGroundwater monitoring to ensure natural processes continue to reduce levels of contamination.
  • Additional in-place groundwater treatment will be included if needed to prevent contamination from reaching Bellingham Bay
• Administrative requirements:
  • Requirements for existing and future buildings to address potential mercury and naphthalene vapors
  • Restrictions to prohibit groundwater use and disturbance of caps without prior Ecology approval
  • Requirements to inspect and maintain the cleanup elements and provide for long-term monitoring

Agreed Order Amendment

Our legal agreement amendment with the port includes an updated schedule of four sequenced engineering design projects. The figure to the right shows the project locations within the Chlor-Alkali Area:

1. Soil removal, consolidation, and capping
2. Groundwater treatment
3. Soil removal and in-place treatment
4. Site-wide capping of multiple locations (following completion of other planned cleanup actions)

Sequencing design and implementation (construction) for the four components of the cleanup action will enable construction to proceed for the more straightforward components while engineering design continues for the more complicated components.

Costs and funding

The port has already spent about $6 million on cleanup work in the Chlor-Alkali Area. The design and cleanup of remaining areas of this area is expected to cost about $13 million. The port is eligible for reimbursement of up to half of their cost from Ecology through the state’s remedial action grant program. This funding helps to pay to clean up publicly owned sites. The Legislature funds the grant program with revenues from a tax on hazardous substances.

What happens next?

• July 6 – August 4, 2021:  Hold a 30-day public comment period.
• July 14, 2021: Host an online public meeting.
• Late 2021:  Finalize the cleanup action plan and associated documents. Ecology will review and consider all comments received and respond accordingly.
• 2021-2023:  Estimated time to complete design of the cleanup action. The port will sequence completion of engineering design documents for four separate components of the cleanup action.
• 2023-2025:  Estimated timeframe for sequenced implementation (construction) of the cleanup action

Implementation of the cleanup action will occur under a future separate legal agreement, which will be issued for public review and comment.

Background

The 74-acre Georgia-Pacific West site is located at 300 West Laurel St, on Bellingham’s waterfront. A pulp and tissue mill operated on the site from 1926 through 2007. In 2005, the port acquired property within the site from the Georgia-Pacific Corporation.

In 2013, an environmental investigation (Remedial Investigation) of the site showed contamination in two separate and distinct areas — the Pulp and Tissue Mill Area and Chlor-Alkali Area.  Cleanup of the Pulp and Tissue Mill Area was completed in 2016.

The site is one of 12 sites coordinated through the Bellingham Bay Demonstration Pilot. The pilot is a bay-wide multi-agency effort to clean up contamination, control pollution sources and restore habitat, with consideration for land and water uses.

Chlor-Alkali area

A chlor-alkali plant operated in this area from 1965-1999. It used mercury to produce chlorine and sodium hydroxide for use at the pulp and tissue mill. Petroleum was also stored there. As a result, the 36-acre Chlor-Alkali Area contains mercury, high pH (caustic), polycyclic aromatic hydrocarbons (PAHs), and petroleum hydrocarbons at potentially harmful levels. These contaminants must be addressed under Washington’s cleanup law, the Model Toxics Control Act.

Previously completed cleanup work

Over the years, Georgia-Pacific and the port addressed contamination in certain portions of the Chlor-Alkali Area:

• Georgia-Pacific Corp. – In 1976-77, mercury-contaminated soil was solidified and contained in a 2-acre area. From 1993 through 2002, a number of projects included removal and proper disposal of mercury- and petroleum-contaminated soil.
• Port of Bellingham — In 2013/2014, about 2,300 cubic yards of mercury-contaminated soil with debris and a mercury-contaminated building shell and floor were removed. In 2017, an additional 430 cubic yards of mercury-contaminated soil was removed.