Friday, September 20, 2013

Call to Action: Cornwall Avenue Landfill Comments Due Today!

This report written by Baykeeper Interns Chris Armstrong and Monica Tonty.


We are currently in a key stage of the waterfront redevelopment: the comment period for the cleanup options for former Cornwall Avenue landfill ends Friday, September 20th. Once the cleanup has been completed, the site could become the location of Bellingham’s newest waterfront park. 
Location of the Cornwall Avenue Landfill,
the site of a proposed waterfront park.
On the evening of September 17th, approximately 30 community members joined RE Sources’ Baykeeper team at the Bellingham Unitarian Fellowship to learn about the current proposal. Brian Gouran from the Port of Bellingham was kind enough to attend the workshop to answer any questions that the community might have about the project. Wendy Steffensen, RE Sources' Lead Scientist, informed the attendees that during the Cleanup Action Plan there is another stage for public comments, but at that point “not much changes,” so now is the time to make your voice heard. We want a high quality, long-lasting cleanup that will be protective of public and environmental health.  The cleanup option that the Port and Department of Ecology has dubbed, “the preferred alternative” may not be the best choice.

The Dioxin-Contaminated "Cap"

In 2011, an interim action was taken to dredge 47,000 cubic yards of contaminated sediment from Squalicum Harbor to store it on top of the former Cornwall landfill site as a “beneficial reuse” material for capping the landfill. When asked whether the audience was familiar with the interim action, about half of the attendees raised their hands. The “beneficial reuse” sediment is contaminated with 14 ppt of dioxin, which exceeds the standard for open water (4 ppt) and residential standards (11 ppt). Dioxins may cause cancer, disrupt the endocrine system, and cause reproductive and developmental effects. 

The dioxin-polluted sediment was mixed with cement in order to bind up the dioxin and make an impermeable cap that would prevent water from spreading the pollutants from the underlying waste. The issue of beneficial reuse of waste material, Wendy Steffensen noted, is a philosophical issue that needs to be discussed. “Do we as a community think it is alright to use this waste material as a capping material? That’s a question that I think everyone needs to ask.”  

Cornwall Avenue Landfill site following the interim cleanup action in 2011.
When the audience was asked whether or not the dioxin should be removed, almost everyone raised their hands indicating support for removal. And then the question became, “how much more are we willing to pay to have it removed?” Alternative 4 of the RI/FS proposes this option, but the cost of moving the waste again would be costly. Instead, the waste will be dealt with on site, which raises questions about the safety of storing toxic sediments in a seismically active zone. Are there ways that the dioxin can be released? Can the dioxin material be inundated by rainwater, ground water, or sea level rise? According to Gouran, the current plan accounts for 2.4 feet sea-level rise over 100 years. Is that enough?

Protective Liner

Sample liners were passed around during the presentation and the audience got a chance to compare the liners that could be used to cap the piles of dioxin. The first liner that was passed around was the 20-mil scrim-reinforced liner that is proposed for use in Alternative 2, the Port’s “Preferred Alternative.” This is the liner that has been covering the dioxin piles for the past couple of years. The second liner that was passed around was the 60-mil high density polyethylene (HDPE) liner that is used commonly used by the landfill industry, and is the liner proposed for use in Alternative 3. 

Lee First, RE Sources Pollution Prevention Specialist, noted that the liners also come in 80-mil and 100-mil thicknesses and that from her experience the 20-mil liners are impossible to weld together. Instead, the 20-mil liners have to be sewn and taped, which creates points of weakness where water seepage could occur. It was also noted that the 20-mil liner has a relatively low protection guarantee of around 5 years compared to the 60-mil and greater liners that would last 40 to 50 years, or more. Audible gasps swept across the room when the audience learned that the liner proposed in the “Preferred Alternative” only has a guarantee of 5 years. Someone in the audience posed the question, isn’t it “irrelevant how long the liner will last when we’re going to have an earthquake or tsunami in the next few years?” 

Fish Consumption Rate

Steffensen also pointed out that with the unrealistic fish consumption rates in Washington, bioaccumulation of toxins through food is an issue for Cornwall Avenue Landfill clean-up plans. Washington currently uses one of the lowest fish consumption rates to set water pollution standards, but has one of the highest fish consuming populations.

Current Fish Consumption Rate is 6.5 grams/day for water quality standards and 54 g/day for surface water cleanup standards. 250 grams looks more like a good sized dinner.

Our Preferred Alternative: Alternative #3

Clean surface and groundwater could become polluted before entering the bay as it flows through the waste material. The preferred alternative 2 provides some protection from water flow through the site. However, alternative 3 also includes an upgradient groundwater diversion barrier which provides further protection. 

Other key issues that came up during the workshop: What about the bioaccumulation effect and the current fish consumption rates?  What will happen to dredged contaminated sediment in the future? Will habitat restoration and enhancement be included in the plan? How will pollutants in the neighboring R.G Haley site affect the clean-up process? The current preferred alternative doesn’t satisfactorily address these concerns and unless an effective clean-up plan is formed, one member of the audience commented we might be renaming Cornwall Avenue Landfill, “Dioxin Park.”

Ecology chose Alternative 2 because the “disproportionate cost analysis” tool showed a slight increase in cost for Alternative 3 in relation to its overall benefit. However this is a subjective calculation; if another team had done the calculation, the results could be different. As Steffensen pointed out, they didn’t take into account public opinion on the benefit of including things like a liner with a warranty of more than 5 years or a groundwater diversion barrier. 
A subjective "disproportionate cost analysis" is used to evaluate the four cleanup results.
This graph demonstrates the findings of the disproportionate cost analysis for the four cleanup alternatives.
Whether you want to endorse Alternative 3, or have other suggestions, join us and submit comments to Mark Adams at or 3190 160th Ave NE, Bellevue, WA 98008 by Friday, September 20th and ensure that this clean-up plan accounts for the many concerns associated with the polluted waste in the Cornwall Avenue landfill.



Background information on the hazards of dioxins:

The full RI/FS (cleanup study) is available on the Department of Ecology website:

Sample letters and the slides from the September 17th presentation can currently be found on the front page of RE Sources website:


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