It Always Comes Back to the Toxic Sludge

David Netboy contends “business as usual” is no longer acceptable, and here’s why.

David Netboy contends “business as usual” is no longer acceptable, and here’s why.

Mr. Karlberg’s speculations and insinuations about what I may or may not have read, and that I must have come from “another region,” (outer space?) disfigure his already poorly supported thesis, namely, that I’m somehow in favor of totally abolishing the Shipping Terminal and all its present and future activities from the waterfront. A careful reading of my piece should have made it clear that my complaints about the ABC Recycling contract are specific to that contract. My concern is with the potential harms of the ABC operation to the ecology of the environment and to human health. And I worry because the Port Commissioners have indicated they are in favor of soliciting other such contracts in future, irrespective of any similar hazards they may pose.

Mr. Karlberg’s assertions that, “The Port’s waterfront cleanup projects have left the water, land, and air cleaner than when Georgia Pacific operated a pulp mill and chlorine plant on this land,” are at best half true and only applicable to less than half the area sold to the Port in 2005 when Georgia Pacific terminated their activities.

The totality of the GP land acquired by the Port in 2005 was 74 acres, and showed contamination in two separate and distinct areas. In 2013, the Port and Washington’s Department of Ecology divided the site into two separate areas: the Pulp and Tissue Mill area, and the Chlor-Alkali area. The less contaminated Pulp and Tissue Mill area was cleared by removing contaminated soil and building materials. This cleanup was completed in 2016.

However, the 36-acre Chlor-Alkali Area, which includes the Shipping Terminal land, was heavily contaminated, especially with mercury and polycyclic aromatic hydrocarbons, to levels that were potentially harmful. This triggered Washington’s toxic cleanup law, the Model Toxics Control Act. This acreage is designated the “Chlor-Alkali Unit” and has required complex planning by the Dept. of Ecology and the Port before remediation can commence. It can be referenced online by the term Chlor-alkali RAU (Remedial-Action-Unit).

The subsoil in this unit is so contaminated by mercury that a Cleanup Action Plan includes the injunction that:  

The Port and Ecology will develop an Environmental Covenant
 for the RAU that includes institutional controls restricting certain activities and uses of the RAU property to protect the integrity of the selected cleanup action and thereby protect human health and the environment.

This is the area upon which ABC Recycling is conducting the operations which first brought them to our attention, namely, the accumulation of giant mountains of scrap metal and their subsequent transfer to bulk transport vessels. These activities require a significant amount of crane and bucket use, plus scraping the dislodged scrap into piles for loading onto dump trucks. The combined weight of the metal scrap is likely on the order of 30,000 tons and is sitting on an asphalt “cap” over known toxic sludge. The sludge was treated by GP in 1977 using chemical fixation and then buried in that vicinity—without reliable information about the longevity of the detoxification “treatment.”

The short messages I wanted to convey in my article were only two: 1) Given the present state of contamination of the Shipping Terminal environs, it seems ill advised for the Port to adopt a “business as usual” stance with regard to shipping operations. And 2) Given the details of the Waterfront Sub-Area Plan, that Mr Karlberg is quite certain I’ve not seen, there is a pile-up of rusted metal directly in line with one of the “view corridors” described in that document, which, at a minimum, is a thumb in the eye of the planners.

The transition from the old land use plans, in which every activity had its specific geographic area on the map, to the Urban Village plan where the designation “Industrial Mixed Use” replaces “Heavy Industrial” and “Light Industrial,” suggests the Port should adopt a more nuanced view of the kinds of shipping that are compatible. And “business as usual” should no longer be acceptable.

About David Netboy

Citizen Journalist • Bellingham • Member since Mar 09, 2023

Retired Emergency Doc with 30 yrs experience at St Joe's between 1987 and 2017.

Comments by Readers

Tip Johnson

Apr 15, 2023
Some circa 2004 (archived website, not everything works) stuff on the illegal toxic slab under the scrap metal mountain. If you look, there’s a link to the original docs. Essentially, GP illegally buried 12 tons of mercury in 1.5 million gallons of sludge on the site after the state told them to quit dumping it along Whatcom Creek, a stream designated for juvenile fishing.  DOE caught them and told them they had to dig it up and haul it away or, alternatively, cap it. GP chose to pave the area  

I too have advocated for a more working waterfront and now think, ‘be careful what you ask for’. One has only to search the waterfront plan for “log pond” to easily find all the flowery prose about habitat enhancement, public trails, taking long-term vs short-term approaches, and, yes, the area remaining industrial.

Since its inception, the Port has always flopped like a floozy for any cheap buck. It’s embarrassing.

As a closing thought: Remedial investigations of the Chem-fix slab showed substantially lower mercury concentrations than when originally tested (just like their Whatcom Creek dump), proving that illegal releases occurred from the illegal dump(s). No actions were taken. 


M. Lynda Hanscome

Apr 15, 2023

Excellent article, David Netboy.  Very informative.  Every time I hear the word “mitigation” I think “cover up for mistakes made.”  I am glad you are not a alien….Lynda Hanscome


Elisabeth Britt

Apr 16, 2023

ABC Recycling Department of Ecology Violations dated January 4, 2023. According to the Department of Ecology, the existing individual ISGP permit does not cover the type of industrial activity being conducted by ABC Recycling on Port property. Hence, DOE determined that the Port, otherwise known as the taxpayers of Whatcom County, remains responsible for the discharges from that area. I’m not sure how the Port could have overlooked this detail, before they signed a lease with ABC Recycling. But somehow it happened. 

Regarding the chemfix. Solidification and stabilization technologies are not useful for some forms of metal contamination, including mercury. Studies have determined that S/S technologies are affected by the chemical composition of the contaminated matrix. Factors such as the amount of water present, the chemical composition of that water, the complexity of metal, and ambient air temperature can interfere with the bonding of the waste to the binding material. Which can prevent the S/S from properly solidifying. In the past, there was some concern that part of the chemfix did not solidify, due to salt water intrusion. But I doubt we will ever know the truth.  Thanks for tackling this topic, David. You’re right. View corridors and concerns regarding new site contamination should have been considered prior to signing the ABC Recycling lease. 


Doug Karlberg

Apr 16, 2023

First it was noise, now it is sludge. I suspect we are bootstrapping issues to try and justify something, not sure what.

Look, if someone wants to critique or complain about the cleanup on the GP site, you are about ten years too late and the Commissioners you want to complain to are Scott Walker, Doug Smith, and Jim Jorgenson.

Many of us spoke out long and loud about the “cheap” cleanup on the GP site. You may wish to complain to DOE also, as they signed off on the cleanup. If you did not join a bunch of us to complain before the cleanup was decided, then you missed your chance. We could have used the additional voices at the time.

The Port’s use of the Shipping Terminal is in complete compliance with the Comp Plan which everyone that cares, should be aware of.

I lived for seven years in an apartment right over the train tracks on 11th St. The train was a pain, but I had a million dollar view. I never whined, because the train was there first and I rented the apartment with the full knowlege of the train’s impact.

This is the best Port Commission we have had in my lifetime. I have lived here a long time, which doesn’t suggest that I am somehow better than someone who moved here yesterday. I does mean though, as a long time Port watcher that I understand the history of how we got where we are today. Thanks for asking.

Folks there are almost 1,000 ports in the United States. I would venture to guess that every one of these ports gets complaints about industrial activity and the noise, dirt, and lighting impacts NECESSARY to accomplish their critical industrial activity. Farms deal with this across our country as folks buy cheap land, build a house next to the farm, and then want put restrictions on the farms which either cost lots of somebody elses money, or in the extrene put the farmer out of business. This behavior is self-serving and thinks nothing about the millions of people who depend upon the food produced by this smelly farm.

The Port’s shipping terminal cannot be moved. The scrap that is coming from Whatcom County is now being moved on ships. Previously it was moved by open top semis burning three times the fossil fuels that a ship burns, wearing out our roads, adding to the congestion which wastes more fuel, and leaving a trail of dust on our roads. Folks this is our waste individually. Without consumer demand you could put our waste in a wheelbarrow. 

US ports are resposible for about 25% of jobs in our country. Too often we do not recognize ports’ impact until they are curtailed. Our shipping port is important to Bellingham, Whatcom County, and to the country and without the ability to move freight affordably and expeditiously then the Port of Bellingham ceases to fulfil the intended statutory function as set out by Washington State Legislature.

The Port should mitigate impacts, but they should not give into unreasonable complaints, because the Port was here first and we need determination to keep a working port. Let me give you one example that folks don’t normally think about. Barges for decades have brought gravel across the docks at the Port of Bellignham. Unloaded by dirty blue-collar workers, with noisy machines at all hours, creating dust as they work. Every foundation for a building, school, road, or home is cheaper because of the Port of Bellingham. Not just Bellingham, but all of Whatcom County. This has been going on for a century. The reason we bring gravel especially by water is that barges burn so much less fossil fuel per ton. We not only save money but reduce consumption of fossil fuels. That is a win/win.

That is good public policy for all Whatcom County.

I have said what I need to say on this issue. If I offended someone, I appologize. I do not set out to offend anyone. I am plain spoken. If I intend to offend you, you will not need to read between the lines. 

I have my biases. One of my biggest biases is that I respect and appreciate the work ethic of all blue-collar Americans. This system would not work, if you folks did not do the physical and often dirty jobs that others will not. You are not a basket of deplorables. I will not appologize for this bias. This bias is simply respecting some of the hardest working Americans.

This is the subject for my next Northwest Citizen article.


PS-If you want to listen to the testimony of the South Hill residents and their complaints to the Port Commissioners, I encourage you too. The time of testimony is between 2:30 and 19:30 (17 minutes)



Elisabeth Britt

Apr 17, 2023

Bootstrapping? For crying out loud Doug. The author has already clarified that he is not asking the Port to shut down the shipping terminal. Nor have I asked the Port to stop using the shipping terminal. And I was once one of the blue collar workers who spent many years working at Georgia Pacific. Not in the office, but in the mill itself. Then, in 1981, barely two years after I began working at the mill, I found out that I had been exposed to toxic levels of mercury. Why do I mention this? Because the Chemfix and the cap were already in place. I did not work at the Chlorine Plant. And I wasn’t the only blue collar or white collar worker who was exposed to toxic chemicals while working at Georgia Pacific. However, I believe that every worker, regardless of the title attached to their occupation, deserves protection from exposure to toxic chemicals. The current Port Commissioners do not have the right to expose anyone to the toxic chemicals that remain on the site. DOE is requiring mercury monitoring equipment for some of the structures that will be built on the waterfront. What that tells me is that they know that there is still toxic levels of mercury on the property. In closing, I was one of the first people to advocate for a clean up, not a cover up of the site. I don’t want anyone who works or lives on that site to be exposed to mercury or any other toxic chemical. Especially unborn children. This discussion has never been about disrespecting hard working Americans. It is about the too common practice of placing innocent people on top of or near contaminated sites. And, you are ignoring the fact that ABC Recycling is already releasing new contaminates from the scrap pile. Regardless of where the scrap metal originated.  


Doug Karlberg

Apr 17, 2023

As per John Servais request.

The source of the scrap metal being shipped out, is not Canada. The company is Canadian and was picking up our scrap (mess) and taking it to lower British Columbia for shipping. Canadian Customs was unworkable, so the Canadian company opened a consolidation and shipping yard in Bellingham.

The vast majority of the scrap is from Whatcom, Skagit, Snohomish, and King Counties.

I appologize if I misled anyone into thinking that this was Canadian scrap.


Doug Karlberg

Apr 17, 2023


I never mentioned your comments. My comments are addressing the article posted above by Dr. Netboy.

These folks came in complaining about the noise loading a ship once every month or so, and now we are are dredging up the GP cleanup, that was decided a decade ago. I don’t remember any of these folks demanding a better cleanup from the Port Commissioners ten years ago. They may have and I not know about it, but if they did not comment then, why the sudden concern now?

I suspect it is about the noise and they are bootstrapping a cleanup from long ago to some how bolster their noise complaint.

In any event, I personally do not want to re-litigate the past decisions on the cleanup.

Now as to the noise complaint. I have watched and listened to these three south hill residents complaints. I don’t believe any of them agreed to be satisfied with noise mitigation. What else is left, other than shutting down the shipping terminal to loading scrap.

Now when I lived on 11th St. Not only did I get the full blast of the train, but I also got the noise from the shipyard in Fairhaven. Particularly when the shipyard was sand blasting. Now I am very familiar with shipyards and sandblasting. There is only so much mitigation that can be done, before it becomes uneconomical. You cannot run a shipyard of that size and not be able to sandblast. Much of their work was Washington State frerries which we need and use. Now this is preisely where public complaints can destroy blue-collar jobs. Just think if noise and smell complaints would have been able to close down Georgia Pacific. You would have lost your blue-collar job.

Now I am not for forcing people to work in a polluted environment, but between dedicated environmental staff at the Port, the EPA, the DOE, and OSHA I have confidence that there are people with the specific scientific skills over-seeing this operation. Suggestions otherwise without hard evidence is simply misleading the general public as to what is the truth.

I would be willing to revisit my opinions if there was some scientific evidence to support the emotional appeals, but I am not in favor of destroying good paying jobs that are reducing the carbon footprint of our wastestream, and recycling which I support, based upon rumors and speculation.

By the way, when they would sand blast at Fairhaven Shipyards I would simply close my sliding glass door, which eliminated the majority of the noise, and then crank up Waylon and Willie and rock out.

Life is pretty darn good. I have traveled the world, and even with some minor problems this is an extraordinary place to live, and I am eternally grateful to call this home.


Elisabeth Britt

Apr 17, 2023

Well, the June 21, 2022 memorandum to Rob Fix, attached to the lease agreement with ABC Recycling states under the sub-section titled BACKGROUND that ABC will be barging scrap metal for processing from Vancouver Island. The following is a direct quote from page one on the Consent Agenda Item # D:

“ABC Recycling is the largest metal recycling company in western Canada. They have nine locations in British Columbia and Alberta including their head office in Burnaby, BC. ABC is expanding and has chosen Bellingham as their American base. Their USA subsidiary will handle both shredded and cut grade recycled metal as well as process recyclable metal at a new facility under development in Whatcom County. The shredded and cut grade materials will be stockpiled at the Log Pond acreage prior to export from the Bellingham Shipping  Terminal (BST). 

In addition, ABC will also barge in recycled material from their Vancouver Island yards and truck it to their site in the county for processing. The anticipated cargo volumes that will pass through the BST via the Log Pond are:

Import (via barge): In 2022: 20,000 metric tons (“mt”) / subsequent years: 60,000 mt.

Export (via ship): In 2022: 81,000 mt/Year Two: 242,000 mt / Year Three: and subsequent years: 320,000 mt.” 

So, unless the lease agreement has recently been modified to exclude the import of scrap metal from Vancouver Island - some of the scrap metal being processed and shipped in Whatcom county originates in Canada. By the way, the Port is only charging 0.75 cents per metric ton for stormwater management. 


Elisabeth Britt

Apr 17, 2023


Those same people that you are claiming are trustworthy were once responsible for ensuring the health and safety of G.P. workers. And, yes. There is scientific evidence that has documented the adverse health effects of living or working in an environment with high mercury contamination. Email me. I’ll be happy to share my research with you. It comes from the EPA and many other state and federal agencies. I don’t have to make it up. It has existed for years. 

Half of the people that I worked with at G.P. are no longer with us. They died before they ever reached the age of 60. Yet, you are willing to trust the Port, DOE and others to protect the people currently working at the waterfront from contamination. That’s your decision. Personally, I think it’s fool hardy. 

I was one of the few women at Georgia Pacific who worked on site while she was pregnant. You have already publicly declared that you don’t care what happened to me or my baby. Nor do you believe that another woman who is working or living at the former G.P. site could possibly give birth to another child with mercury poisoning. You are convinced that the current Port Comissioners, staff and the representatives of state agencies will ensure that it doesn’t happen again. I wish I shared your enthusisam. But I don’t. I’m a realist. I’ve sat there staring at a critcial care neo-natal incubator for three weeks wondering if my baby would be alive in another hour. 

You wern’t there. So you will never understand the agony and guilt that my former husband and I were forced to endure. Sometimes, those dirty family wage blue collar jobs that you are promoting, come with a very expensive price tag.  We can change that. But it is difficult, when people have their head buried in the sand.  


Doug Karlberg

Apr 18, 2023


Thank you for the details of the Port/ABC Contract. It is always good to have accurate facts, and you have always been good digging them up.

We will host approximately 18.75% Canadian scrap metal from Vancouver Island. Considering that we have been sending some of our scrap out through Canada previously I would say that is reasonable. Canada has been a great neighbor and solving global warming may drive neighbors to work together to regionally reduce thoverall use of fossil fuels. Vancouver Island logically burns less fuel by barge. Their annual scrap pile can be transported by 3,000 trucks or a fuel efficient barge to Bellingham.

It is interesting that the annual scrap metal that we all generate is 260,000 tons annually just from less than four counties. The things we throw away really add up. Maybe if we built stuff that lasted a long time, we could reduce our waste stream. Seems like a logical goal, and would make dent in our global warming to boot.

In the 19th century most of our freight traveled by water, then rail and highways took over much of it. The transition back to water transportation is well underway, and global warming and reducing the use of fossill fuels is driving it. We should make sure we are ready to embrace this trend back to the water, becuse it significantly reduces our consumption of fossil fuels.

Here is a short article for folks who are interested in this trend which is already underway throughout our country. Link:

Now on a personal note your comments about me are not true. I never, ever said “You have already publicly  declared that you don’t care what happened to me or my baby.”

Organizations by their nature change over time, because the people that control them change over time. Georgia Pacific was the bad actor, and our Port had zero control over Georgia Pacific until 2004, when they purchase the siteand cleaned it up.

There is virtually nobody left at the Port from 2004. Same with DOE.

When I began seriously criticizing the Port in 2004 I recognized that the key to changing the direction of our Port required changing out the people at the top. It took a while, but that has been accomplished and I worked pretty darn hard to see that happen.

Being critical is easy, but criticism alone does not build anything. The folks running the Port today are light years ahead of the ones who messed this up.

A little positive reinforcement sometimes will get you a lot of results that you desire.

These three Commissioners spearheaded the drive for evening meetings so that working folks could attend. They spearheaded videotaping of the meetings, so that folks who could not attend could participate.

I remember the days when Commissioner Smith would literally turn in his chair to show you his back when he did not like what a citizen was saying.

We have made a lot of progress at the Port, and a little praise might be in order.


Elisabeth Britt

Apr 18, 2023

This discussion is not about specific individuals, their personalities or their values. So, it doesn’t matter which elected official or public employee was in charge back when my unborn child was exposed to mecury vapor via the womb. The current Port Commissioners and staff may be wonderful individuals. But even wonderful individuals who are making lots of progress can make mistakes. And some of those mistakes could have devestating consequences for blue collar workers who work near the Chemfix and cap. 

Mercury vapor is not irritating and it has no odor. So exposed individuals have no idea they are breathing it. Experts tell us that even a small amount of mercury from a broken thermometer can cause harm. Yet, the former G.P. site has tons of mercury buried beneath the surface. A pea-sized drop of undetected mercury can take up to 385 days to vaporize. In that amount of time, it can cause severe neurological damage - especially in the unborn, infants and children. 

The Department of Ecology is requiring mercury monitors on some of the structures that will eventually be built on the waterfront. Again. Mercury vapor is not irritating nor does it have any odor. The major route of exposure to elemental mercury is inhalation of mercury vapor. In other words, a person can be exposed to high levels of vapor and not even know it. That is what happened to me. 

The sitting Port Commissioners made a decision to place a business on top of a highly contaminated site. The ABC lease states that they expect to hire six full time employees. They have also retained a local stevedore company for ship loading arrangements. My concern is that any one of the new employees could be exposed to mercury vapors and not even know it. Has anyone warned them that they could be exposed to mercury vapors? If not, then nothing has changed at the local, state or federal regulatory level. If some of those employees are women of childbearing age, they may be playing Russian Roulette with their unborn child’s life. A mercury vapor respirator may or may not offer adequate protection. We had plenty of respirators when I worked at G.P. And I used them on a daily basis. 

The Department of Ecology has already issued citations to ABC And the Port for stormwater violations. The lease states that ABC has a responsibility to comply with all the applicable rules and regulations, including the implementation of environmental stormwater management requirements and permits. Permits that they do not currently have in the their possession. I find it difficult to place trust in any business or government agency that fails to obtain the proper permits to conduct business on a risky portion of the waterfront. 

Yet, you tell me it’s okay. Everyone is so nice. Everyone is making good progress. I should just overlook the lack of proper permits and other niggling details. Because, you see, they are doing the right thing. They couldn’t possibly do something wrong. The problem is with me. An ungrateful, skeptical former blue collar worker. An individual who was once a young mother who watched in horror as her new born child struggled to live. Those struggles can continue throughout adulthood. But you don’t want to discuss the scientific evidence surrounding mercury vapor posioning and new borns. You just want to keep telling me that I’m the problem, because I don’t trust the Port to tell future workers and residents about the potential dangers mercury vapor. 

That’s okay Doug. I’m used to being vilified and dismissed for using my hands to make a living. 


George Dyson

Apr 19, 2023

Just a note of equal appreciation here, to thank both Elisabeth Britt for all her years of work pushing to clean up contamination on our waterfront, and Doug Karlberg for all his years of work pushing to clean up the leadership at our Port. Elisabeth’s comments and testimony remain part of the public record, and without them the outcome might have been even worse. Doug’s efforts (like his personally hiring a light plane to fly over Ski-to-Sea towing a banner reading “Commisioner _______ Must Go”) are less recorded, but not forgotten by those who now benefit from a more functional Port.


Elisabeth Britt

Apr 19, 2023

Thank you, George.

You are correct, all three of us (and many more tireless volunteers) have worked hard to make the Bellingham Waterfront a better place for the community. A place where people can work, play and live safely. 

I understand Doug’s concern about creating family wage jobs. And I hope he understands my concern about the health and safety of the people who are currently working on the waterfront. 

Thanks again for your words of appreciation and encourgagement. 


Dick Conoboy

Apr 28, 2023

I discovered this video on NextDoor where I posted these recent articles on the port and the scrap and the sludge. 


Doug Karlberg

Apr 30, 2023


Mr. Dyson gives me credit in his comment above for something I do not deserve credit for. Mr. Dyson asserts that I paid for a banner towed by a plane that said ” COMMISSIONER WALKER MUST GO”.

I did not pay for that palne to fly this banner over Belingham. I did not even know this was planned, but I was on the ground cheering, and would have happily contributed. This act of public protest over Port of Bellingham Commissioner Scott Walker was brilliant and heralded in major changes at the Port of Bellingham, that got our Port on a path of actually listening to the public.

I believe a fellow commercial fisherman paid for this banner. This banner changed the Port of Bellingham for the good of all Whatcom County citizens.

Along with this fisherman’s protest banner, theree is a long list of people who fought and won major changes at the Port of Bellingham. Mr. George Dyson is one of those people. His public aurguments at Port meetings were so carefully crated with accurate facts and bulletproof reasoning that it left Port Commissioners speechless, while being on public display.

Elisabeth Britt and Mr. John Servais were tireless in taking a cattle prod to prior Port Commissioners that were real estate developers in disguise doing backroom deals out of the public eye.

All of that has changed now, and the current Commissioners have diligently worked to be transparent and genuinely listen to the public. All three of them deserve praise for the changes they made from when Port Commissioner Walker and Smith ran the Port of Bellingham.

I remember what the Port was. I remember the changes that have been made, and I remember all the people who contributed and fought for these changes.

Context and history matters.

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