Friday, June 17, 2016

LCC Discusses Serious Health And Safety Impacts Of SR520 Bridge Demo To King5 News


On Tuesday evening, the Vice-President of the Laurelhurst Community Club (LCC), Colleen MacAlleer, was interviewed on KING 5 News regarding the issue of how, where and the impacts of demolishing the old SR520 bridge.  

Currently it is being broken apart and put onto barges in the middle of Lake Washington, which many are concerned can result in health, safety and environmental impacts including liquid runoffs, hazardous substances in dust emissions and potential toxins and materials emitted that are contained in the concrete that could contaminate the lake.

Details on the demolition and decommissioning work can be found here.

King 5 reported that "The demolition work was originally supposed to be done on land, at an industrial site in Kenmore.  It was moved onto Lake Washington after Kenmore city leaders made it clear they did not want the demolition done in city limits."

Colleen told the Laurelhurst Blog Staff that the "goal should be the safe removal of the old bridge using the least harmful methodology, and the rubblization (grinding up) at a safe facility that encapsulates the potential hazardous toxins from reaching the air or water in Lake Washington."

In the King 5 interview Colleen  expressed concerns "about the health of the Lake Washington, the health of the children/people who use it for in -water recreation, the wildlife, all of the food chain creatures, and the air quality of all citizens who could be adversely impacted by the hazardous potential toxins in the water and in the air."

She said "We can do better. This is a key opportunity to do it right, and it's obvious that we don't know how the process can be done differently or if it was vetted in a way that they could find a better place to do it.  So we want information, and we want it to be stopped until we get that information."

On June 10th,  LCC and numerous other Lake Washington organizations, signed on in support of Representative Gerry Pollet's letter to Jay Inlsee (below) to temporarily halt the SR520 demolition until public records, permits and tests could be reviewed.

LCC "presses WDOT daily for information, request testing, and monitor the work with the coalition of community councils from Kenmore, Lake Forest Park, Sheridan Beach, Medina, Yarrow Bay, Hunts Point, Madison Park and Portage Bay and Roanoke Park," Colleen said.

LCC met with  City Council member Rob Johnson, State Representative Gerry Pollet and Bernard van de Kamp with Seattle Department of Transportation (SDOT) on May 24th,  shortly after the 520 demolition process was made public. 
LCC then followed up with letters (below) and emails to City Council, SDOT and the Mayor requesting that the City ask WSDOT to halt the demolition until the process was evaluated for safety of potential toxins, and the public records could be examined.

Colleen said:
To date, no action has been taken by the City of Seattle by either Councilman Johnson nor the Mayor's Office to ensure this safe demolition.   Fortunately, State Representative Gerry Pollet from the 46th continues to advocate for the environment and health of his constituents, and is pressing for transparency about the process.   He has been vocal for the 46th District neighborhoods as well as reached out to the Eastside.

Colleen said as stated in the letter to the Governor (below) from Gerry Pollet and the coalition of Community Councils and organizations):
There are legitimate concerns that WSDOT and its contractor ( KGM) do not have adequate permits from the Department of Ecology  to perform this type of barge demolition of the old SR520 on Lake Washington. WSDOT and KGM claim that they do have needed permits from previous , similar permits that they claim "cover" this work process. The Coalition is requesting that more testing for these possible toxins be completed first, and that they be monitored.
As you can see from Greg's analysis of the process, KGM may likely be falling short of the requirements, but without access to the public records that have been delayed, citizens do not know for certain . That is why Rep Gerry Pollet , and the coalition asks for a temporary halt to the demolition until that can be done.

Regarding testing, below describes the technical details that residents would like performed and monitored as the bridge is demolished, Colleen said:
They should be looking for copper.  PCB's can also be found in paint from a certain era, though they claim the painted and asbestos laden parts of the bridge aren't being demolished.
The requirements per state and federal standards allow for a mixing zone on the turbidity of 150'.  For pH there is no mixing zone, so they need to sample at the point of discharge, at the 150' boundary and at a "background" location not influenced by demolition or other bridge project activities.  So the monitoring plan requires ongoing collection of baseline data, for the parameters limits have been set for, for this project.  That appears to be limited to pH and turbidity.   
There was some limited testing done, which you are likely referring to below, but those were run based on a TCLP method, which is specific to determining if a waste may pose a long term hazard of leaking out of a landfill.  It is also used for making a determination under the Resource Conservation Recovery Act as to whether a material is a federally listed hazardous waste.   
The information that was released was absent most the descriptive information as to what was sampled from where, and how the samples were prepared for the analytical procedure.  In most cases where a specialized analytical procedure like TCLP is being used it would be in conjunction with a total metals test so you can compare the results and have some idea of the context of the information you are looking at.  Apparently, at least from the information provided to date, that wasn't done here. 
Other than description of the measures taken to control the release of dust (water based suppression), there is no description of any standards for release of dust or description of monitoring. 
Details on the process for demolition are available, and varied dependent on component.  Most columns will have sediment removed from around the bottom and will be cut at around 2' below sediment surface.  The side cast material is stockpiled an will be used to fill in the holes as much as possible.   
Some of this will be in water work where the cement structure will actually be demolished in place, including below the water line.  They will use a number of measures to control both pH and turbidity in that circumstance.  It is still somewhat disturbing that in the text they don't discuss the cement that is demolished in terms of being a pH hazard, just the green cement (uncured), and cement slurry, even though cured cement when pulverized will be a pH problem as well.   
So in the case of the cut columns those will be lifted by crane and put on a barge for demo.  In the case of in water demo that will be retrieved from the lake with a clamshell, and placed on the barge for transport.  So dust will be generated on the bridge, in the water (is it dust if made in the water?) and on barges.  There is no monitoring plan in place, in terms of actual sampling, for dust in air.  As set that will make it impossible to determine, or at least easily determine if they are meeting or not meeting air quality, or human health based standard. 
Copper is conspicuous by its absence from the list of metals tested.  Similarly, there are a lot of compounds they could have tested for that are not on this list, such as PCBs. 
Baseline turbidity measurements are required to determine whether they are releasing sediments into the water unlawfully.  Other requirements may look only at the endpoint, and determine whether that is acceptable.  E.g., contact with concrete tends to raise the pH of water, but since organisms can tolerate a range, the increase would need to be substantial to be biologically significant.  However, baseline data would help determine whether demolition is responsible for unacceptable levels. 
Dust in the lungs is a health hazard.  How severe a hazard depends on what the dust is made of.Details of the procedure would be helpful to know.  E.g., if bridge segments are lifted onto a barge, in principle they could contain the dust within the barge.  However, if the barge is partially submerged so bridge segments can be floated in, it's likely that dust from the previous segment would enter the water.


Protect Lake Washington's Air and Water Community Coalition Statement
The demolition of the 53 year old SR520 Bridge will soon occur as part of the Washington State Department of Transportation (WSDOT) HOV SR520 Replacement Bridge Project.
The communities, cities and townships in the proximity of Lake Washington, especially along its shoreline, request that federal, state and local regulatory agencies deny any permits or permissions to KGM and/or  WSDOT that would allow the demolition/reduction  of the old bridge components on Lake Washington, on barges, its bays, or in its ports and harbors. 
Fracturing  these components will release into the water and air contaminants that have accumulated in, under, and throughout the old bridge surfaces, over its decades of use. Specifically, asbestos, lead, copper, arsenic, oil, tributylene tin, PCBs and petroleum products will enter the atmosphere and the water.   
Experience has already shown that promises by WSDOT and KGM (the contractor)  for careful planning and diligent adherence to best practices fall short in actual practice.  And here careful planning, due diligence, and transparency  to the public are already lacking.  There are major shortcomings in the plan for the demolition, storage, transportation and transfer of these materials containing hazardous waste. Spillage of these toxins present a threat to the health and safety  of  fish, wildlife, nearby wetlands, and persons in the Lake Washington, and Union Bay waters and shorelines, and to surrounding, densely populated residents and park users. 
Translocation of these materials in such an unsafe manner is against the public interest, and should not be allowed. The demolition process should take place instead in a location that is designed to capture, neutralize, and dispose of any potential hazardous materials without emitting them to the public in the air or clean water. Lake Washington   is not “designed” for that purpose.   
The risks and harm inherent in using  Lake Washington’s waters as a workshop for construction  waste demolition  is completely at odds with the health and safety of the Lake environment.  That environment should be a  top priority  in accordance with EPA, Clean Water Act,  and Washington State Department of Ecology standards and should not be compromised for the sake of expediency  or shortsighted economy.  
The budget for the new HOV SR520 Bridge is over $4.5 billion. It can surely bear the relatively  small cost to barge and properly dispose of the old toxic bridge in an appropriate facility. The consequences of taking a less rigorous approach to water quality in the name of “economy” or “efficiency”   have recently been tragically, vividly revealed in Detroit. We should all -- particularly  agencies with jurisdiction and/or involvement in the process --  take care to avoid an analogous situation here for a lake which so many enjoy and depend upon. 
We respectfully request that WSDOT require that their contractor, KGM,  find a safe, alternative location for the demolition (or “rubblization”) of the old bridge, and not perform that process on Lake Washington, or on its shorelines and connecting waterways.

Letter To Governor Jay Inslee:
Regarding: Request to temporarily halt barge-based “rubblization” on Lake Washington for Highway 520 bridge demolition until records are disclosed and a process for dialogue occurs
Thank you for acknowledging in Ecology Director Bellon’s letter of June 7, 2016 to Representative Pollet that “breaking down concrete is an activity better suited to be done on land...” (Emphasis added). This reflects one of the fundamental concerns of tens of thousands of residents, local governments, local officials and community groups.
We are very concerned that your letter seeks to justify this as a pre-approved activity, despite acknowledging that there are better alternatives with lower risks.
Therefore, we urge Governor Inslee, Transportation Secretary Millar and Ecology DirectorBellon jointly halt this activity until all relevant records are available for public review and a clear timeline for discussion as to why reasonable available alternatives are not being utilized; and, to enable the public to have confidence that all appropriate reviews of detailed plans were conducted and incorporated all reasonable efforts to avoid or mitigate potential impacts.
1. There is no explanation of why Ecology has been unable to immediately disclose/post online the reviews and comments on work plans leading to the approval for work to proceed on May 27 and March 28.
a. Asking Rep. Pollet to meet with the Ecology 520 bridge team to identify responsive records belies the fact that the administrative record of reviews should be immediately available clearly showing what new reviews enabled Ecology to approve this work or work plans on May 27. The records request submitted by numerous parties is very clear: provide the public with the reviews completed prior to approving work to proceed on May 27.
b. A meeting between local governments, citizen group experts and interested public officials, including Rep. Pollet, will be productive if the public has access to these records in advance, with a brief but adequate time to review how Ecology conducted its review and approval.
c. We look forward to scheduling such a meeting as soon as we have a schedule for receiving the requested records. Until that time, we urge that the Departments and Governor place the “unusual” activity of rubblization of the materials on barges in the middle of Lake Washington on hold.
2. Ecology acknowledges that there was no public process associated with the modification of the work plans to increase rubblization on barges in Lake Washington from the prior anticipated work on-land (Attachment Page 2). The fact that Ecology believes that this did not “require” public process does not make it a good government decision to not open this up for public review and comment. Clearly, this is an example of how going beyond the minimum legal requirement would have led to better governmental decisions and avoided significant controversy.
3. Until the public can review these records for a reasonable period, we continue to urge that work be halted. When the records are posted on line or provided, a short review period with dialogue between state agencies, local governments and citizen groups would be advisable.
a. We appreciate the assurance that there are no significant levels of hazardous substances in the material to be broken up (although concrete dust itself is a significant pollutant and hazard for dust emissions or if it lands on, or is released into, the Lake).
However, this is an example of why the public should have access to all relevant records in order to enable citizen group and local government experts to have the same confidence which you express in this determination.
4. There has been no environmental review for barging material from demolition north to Kenmore through the navigation and berthing channels, which are far more heavily contaminated with dioxins and other contaminants than was known at the time of the original project EIS. That original EIS, in any event, never considered barging material north to Kenmore. Kenmore businesses and residents had a reasonable expectation that there would be no further barging from the 520 project.
a. Barging impacts include significant disturbance of the contaminated sediments,
b. There has been NO supplemental environmental analysis or other analysis of the
c. The most recent contaminant sampling shows levels significantly above those
d. The lack of analysis and consideration of alternatives for this piece of the new significant turbidity, and major sedimentation reducing draft depths for businesses. Impact of barging on disturbing the sediments, impacts on fish, health, etc....previously known. The work plan leaves the State open to significant risk that the courts would enjoin the work to review how the State considered impacts and alternatives for barging through Kenmore.
We specifically request, in addition to the environmental impact analysis, that there be no barging North through contaminated sediments without actual turbidity monitoring and enforcement in place.
5. The letter acknowledges that the additional breakup of the bridge materials on barges is “unusual”: “Normally, ‘coarse’ breakdown occurs on the barge, then the material is taken on land for further breakdown into pieces that fit on trucks. Doing the further breakdown on a barge is unusual, but possible, and involves the same water quality standards already required in the permit.”
This fundamentally fails to recognize the concerns of local governments, public officials and residents. While acknowledging this work is “unusual” and that there are readily available alternatives, Ecology and WSDOT do not recognize that they have a duty to review impacts and seek to choose methods which prevent potential significant impacts to Lake Washington or human health – regardless of whether the basic standards will be met.
However, there is no transparency allowing the public to see how Ecology reviewed the work plan to ensure that impacts were mitigated or prevented, or for the public to understand why the available alternative which avoids all further risk from the “unusual” breakup of coarse material on barges in the middle of Lake Washington.
Assuming that the basic water quality standards will be met does not assure the public that the activity will not have a significant risk of impacting health from dust, or impact Lake Washington due to dust or liquid runoffs (with dust, debris or hazardous contaminants).
6. The letter cites the proposal to move “rubblization” to Kenmore as an example of the ten additional NEPA reviews which have occurred since the original EIS. However, that proposal – now withdrawn – would have been an example of a significant change in plan for which there was no supplemental NEPA or SEPA review. The attachment to the letter  acknowledges what we already knew: there was NO public process for the claimed reevaluation of the work which involves significantly more rubblization on barges than was previously disclosed.
a. Where is the WSDOT and Ecology review of impacts from barging north to b. Ecology cannot defer its review of impacts from barging (discussed in the Kenmore and comparison with available alternatives? Prior barging for construction had significant impacts which mitigation plans did not prevent. Ecology and WSDOT have an obligation under SEPA and other statutes to review the barging plan in regard to those impacts and reasonable alternatives – particularly in light of the acknowledgement that there is a readily available alternative to barging the materials north through the contaminated, shallow Kenmore channel at the north end of Lake Washington.
7. The attachment with specific responses to Rep. Pollet’s letter states that there will be NO runoff (emphasis added). However, there have been numerous admissions that dust  suppression will be necessary. Unless 100% effective, it would seem that there would be dust releases to the water, even if all dust suppression liquids were captured on the barges. This is an example of records which were requested to enable independent review and confidence in this claim.
8. How could Ecology’s approval on March 28, 2016 of the Water Quality Monitoring and Protection Plan have covered all the activities for the new rubblization on barge plan, when the plan as of March was to do the majority of the rubblization on land in Kenmore? (Attachment to letter at page 4 says Ecology issued that approval on March 28). Ecology acknowledges that the new rubblization plan involves much more rubblization work on barges than the prior plan.
a. How can the public be assured that there will be no accidents or unplanned releases?
b. The potential for unplanned releases is one reason why SEPA requires review of alternatives, which might avoid those impacts.
c. How can Ecology respond effectively to unplanned releases when WSDOT is only required to notify Ecology within 24 hours of a release – long after it has dissipated in Lake Washington and conditions have changed?
We look forward to having an informed dialogue on an accelerated timeline that is enabled by a pause in the activity.
Rep. Gerry Pollet King County Councilmember Claudia Balducci Rep. Patty Kuderer
46th District District 6 48th District
Lake Forest Park Stewardship Foundation
People for an Environmentally Responsible Kenmore
Laurelhurst Community Club
Roanoke Park Portage Bay Community Council
Madison Park Community Council
Save Union Bay Association
Sheridan Beach Community Club
Northwest Toxic Communities Coalition

And here is an WSDOT notice sent out yesterday:

Bridge decommissioning continues on Lake Washington

Now that the new SR 520 floating bridge is open, we’ve begun to remove its aged predecessor from Lake Washington. All 33 pontoons from the old bridge have been sold and will be reused elsewhere. They represent a significant majority of the bridge’s total bulk. Other bridge structures will be broken apart and trucked away, mostly for reuse in other construction projects.
Key bridge-removal activities include:
  • Removing asphalt overlay from the whole structure.
  • Removing the pier columns and metal trusses at the east and west high-rises.
  • De-tensioning and separating the old pontoons so they can be towed off the lake intact.
  • Breaking up high-rise columns, girders and cross-beams on barges; Department of Ecology permits prohibit any discharge into the lake.
  • Removing old anchor cables for recycling.
  • Hauling broken down materials through approved truck routes in Medina and Kenmore to a recycling facility or landfill.
Want to know more about decommissioning activities? Check out our blog post, folio, and recent fly-over video to learn more.

No comments: