I am opposed to a policy in the Waterfront Sub-Area Plan that allows “beneficial reuse" of toxic materials in waterfront redevelopment projects. The public is unaware of this policy, but it could have important impacts on public health and safety. This is a matter that should be highlighted and discussed as part of the waterfront redevelopment process.
Beneficial reuse of MTCA (Model Toxic Control Act) cleanup materials is listed as an environmental policy, requiring the city to "evaluate the beneficial reuse of dredge materials that meets Ecology standards for fill material and as raw material for construction projects." (Page 22, Sec. 3.1. of Sub-Area Plan.) Sustainable development policies in the Sub-Area Plan encourage re-use and recycling of materials on site. (Page 29 of Sub-Area Plan.) There was also reference to this policy in one of the numerous EIS documents for the waterfront. Few members of the public understand the consequences of these provisions.
The public has consistently requested the highest level of environmental clean-up for the waterfront. It is not surprising, therefore, that this policy has not been highlighted or discussed in the waterfront documents that have been provided for public review. The city and the port have already established dangerous precedent for beneficial reuse after dumping dioxin at the Cornwall Landfill.
Dioxin contaminated sediment, exceeding state exposure levels, was dumped and left as a large mountain covered with a while plastic sheet. The dioxin sediment was mixed with concrete, a process that slows down, but does not eliminate mobilization of dioxin into the environment. The toxic sediment will be spread across the site for construction of a shoreline park, and residential and commercial buildings. It will be capped with more soil, which again, slows down but does not eliminate dioxin mobilization.
The dioxin levels in the sediment dumped at the Cornwall Landfill can not meet the clean up standards applicable for unrestricted upland use, necessitating the use of a lower clean up standard applicable to industrial use. A reduced clean-up standard would increase permitted dioxin soil contamination from 11 parts per trillion to 1500 parts per trillion. This is a 100 fold increase in carcinogenic exposure, one of the highest exposure rates in the nation. Beneficial reuse of dioxin is extremely controversial and the public has a right to informed that this is occurring.
Tell the city to remove all policies from waterfront documents that favor beneficial reuse of persistent bioaccumulative toxins, unless and until there is full disclosure and public approval. I am troubled that the city and port have failed to disclose an issue so important to public health and safety, in contradiction of strong public input requesting the highest standards for waterfront cleanup and development.
For further discussion of the dioxin problem at the Cornwall Landfill, and the city’s numerous violations of public due process, please review my article published in the Whatcom Watch at http://www.whatcomwatch.org/php/WW_open.php?id=1521.
