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Creosote-treated pilings in the marine and freshwater environments of Metro Vancouver : risks, financial… Younie, Tamara May 31, 2015

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    Creosote-Treated Pilings in the Marine and Freshwater Environments of Metro Vancouver: Risks, Financial Impacts, and Alternatives     Tamara Younie, University of British Columbia May 2015       Report prepared at the request of Port of Metro Vancouver in partial fulfillment of UBC Geography 419: Research in Environmental Geography, for Dr. David Brownstein  Table of Contents 	  1.0 Executive Summary .....................................................................................................1 2.0 Introduction ..................................................................................................................2 3.0 Method ..........................................................................................................................3 4.0 Background Information ............................................................................................3 4.1 Creosote Use ..............................................................................................................3 4.2 Creosote Characteristics .............................................................................................4 4.3 Creosote In The Environment ....................................................................................4 5.0 Regulation .....................................................................................................................6 5.1 Canada ........................................................................................................................6 5.2 Other Jurisdictions .....................................................................................................6 6.0 Removal ........................................................................................................................7 7.0 Alternatives ...................................................................................................................8 7.1 Treatments ..................................................................................................................8 7.2 Materials ....................................................................................................................9 7.2.1 Concrete ..................................................................................................9 7.2.2 Steel .......................................................................................................10 7.2.3 Plastic ...................................................................................................10 7.3 Financial Impacts .....................................................................................................11 7.4 Coverings .................................................................................................................12 8.0 Conclusions, Recommendations and Further Research.........................................13 9.0 References ...................................................................................................................15 	            Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 1 1.0 Executive Summary The goal of this report is to investigate the use of creosote-treated pilings by considering policies practiced elsewhere, risks and financial impacts of removal, and potential alternatives to creosote-treated piles.  By completing a literature review and a series of interviews, the following conclusions and recommendations were proposed: • The use of creosote should be phased out in the marine and freshwater environments of Metro Vancouver • Environmentally friendlier alternatives should be used, wherever possible • Alternatives are generally more expensive, yet may be cost effective when considering long-term use and number of pilings required • In some situations there may be no alternatives to treated-wood pilings • Existing pilings should be covered in order to prevent leaching if in vulnerable environments such as freshwater environments, areas with limited water flow, or areas with large concentrations of creosote-treated pilings • Removal of pilings can be detrimental to the environment and disposal of contaminated materials can be expensive • Due to lack of alternatives that are both environmentally friendly and economically feasible, further research needs to consider other viable options     Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 2 2.0 Introduction The purpose of this research is to make recommendations to Port of Metro Vancouver for the use of creosote-treated pilings in the marine and freshwater environments.  My research will consider current regulations and practices for use of creosote-treated piles, while investigating policies implemented elsewhere on the Pacific Coast, financial impacts and risks associated with removal, and alternatives that may be applied in the aquatic environments. Timber pilings are often treated with chemicals to extend the lifetime of the structure.  The use of creosote to preserve wooden piles in aquatic environments is prevalent across Metro Vancouver.  Creosote, made from distilled coal tar, is composed of a variety of chemicals including polycyclic aromatic hydrocarbons (PAH).  PAHs make up the greatest portion of creosote and are a cause for concern, as some are known to be carcinogenic, mutagenic, and toxic to both humans and aquatic organisms (Smith 2008).   The Western Wood Preservation Institute (WWPI) and Wood Preservation Canada (WPC) published the Best Management Practices (BMPs) for use of treated wood in order to reduce the amount of contaminants released into the environment (2011).  These practices have been recognized as useful by Environment Canada (Hutton & Samis 2000).  However, the BMPs are in a constant state of evolution as new research is conducted.  Despite best efforts to minimize chemicals entering the environment, contamination is still possible.  Although creosote-treated timber was once the predominate material for pilings, its use is now decreasing, and alternative materials that are less environmentally harmful are gaining greater acceptance (NOAA 2009).   Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 3 3.0 Method In order to conduct my research, an extensive analysis of peer-reviewed literature, as well as grey literature in the form of government documents and reports was completed.  Alternative materials and policies implemented in areas along the Pacific Coast, such as California, Washington, and Squamish, British Columbia, as well as policies implemented in the European Union were investigated.  A series of interviews from experts in the field was conducted.  I spoke with Bernie Jebson from Fraser River Pile and Dredge, Ute Pott from Environment Canada’s Federal Contaminated Sites Action Plan, John Matsen from Squamish Streamkeepers, and Reidar Zapf-Gilje from GeoEnviroLogic Consulting Limited.  After compiling this data, the findings were compared with current practices and regulations already established in order to make recommendations to Port of Metro Vancouver. 4.0 Background Information 4.1 Creosote Use The use of creosote to preserve wooden structures dates back to the middle of the 19th century (Zapf-Gilje, Patrick & McLenehan 2001).  Timber pilings require treatment in aquatic environments to prevent decay and attack from organisms.  While untreated wood has a life expectancy of less than ten years, creosote-treated wood may last in aquatic environments for over fifty years (Jebson 2015).   Treatment of wooden piles is especially important in marine environments to deter marine borers, such as molluscan teredos (Bankia setacea) and isopod crustacean (Limnoria), which are prevalent along British Columbia’s coast (Groyette & Brooks 2001.  Due to its toxicity to borers, relative insolubility, and low cost, creosote has been considered an effective wood preservative (Duncan 2014).  However, these characteristics that make creosote an ideal wood preservative also make the substance a threat to the environment. Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 4 4.2 Creosote Characteristics Creosote has a complex composition, which varies between batches, making it difficult to analyze how it will interact with the surrounding environment (Duncan 2014; CCC 2012).  Creosote as a whole is insoluble in water, yet individual components vary from soluble to insoluble (Environment Canada & Health Canada 1993).  Creosote is a dense nonaqueous phase liquid, which allows the substance to sink in water and accumulate in sediment, causing concern for aquatic life (Zapf-Gilje, Patrick & McLenehan 2001; Duncan 2014; NOAA 2009).  It is composed of between 200-300 chemicals, of which about 85% are PAHs (Duncan 2014; Bestari et al. 1998).  PAHs come in two forms: low molecular weight, which are more soluble in water, and high molecular weight (Zapf-Gilje, Patrick & McLenehan 2001).  Both low molecular weight PAHs, which can be acutely toxic to aquatic organisms, and higher molecular weight PAHs, which can be carcinogenic over the long term, are present in creosote, suggesting that use of this substance has the potential to cause both acute toxicity and chronic toxicity to aquatic organisms (Duncan 2014).  At high concentrations in aquatic environments, some PAHs have the ability to cause cancer, developmental concerns, behavioural changes, skin lesions, tumours, reproductive harm, immune dysfunction, habitat destruction, as well as reduce growth and survival (Duncan 2014; Zapf-Gilje, Patrick & McLenehan 2001). 4.3 Creosote in the Environment Groyette and Brooks’ 1998 study looked at creosote-treated pilings in the Sooke Basin of Vancouver Island, British Columbia.  After one year, this study showed that from the BMPs creosote-treated structure, contamination of PAHs were found 7.5 meters downstream, considerable biological effects were seen 0.65 meters from the perimeter of pilings, and minimal sediment toxicity was observed 2.0 meters from the pilings.  They propose the particulate Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 5 creosote transport theory, in which PAHs are transported in particulate form from the treated pile, allowing chemicals to accumulate in the sediment.  PAHs can accumulate from the formation of surface sheen, and from surface heating, which causes creosote to expel from the wood and can cause PAHs to significantly increase in toxicity (NOAA 2009; Washington Department of Natural Resources 2014).  Although the industry suggests that surface sheen dissipates within forty-eight hours after installation, a study in San Francisco Bay showed that surface sheen was seen around pilings that were treated over fifteen years prior (WWPI & WPC 2011; Werm et al. 2011).  After time and exposure to sunlight, a “tar like residue” often appears on the surface of the piling above the water line, which can continually produce surface sheen (Groyette & Brooks 2001, p. 39) (see figure 1).  Creosote leaches faster in freshwater than in marine, making these environments more vulnerable to the chemicals that leach from creosote-treated pilings (Hutton & Samis 2000). PAHs degrade slowly, which allows sediment to act as a “major environmental sink” for these contaminants (Environment Canada & Health Canada 1994, p. v).  Since PAHs have a long lifetime in the environment, the chemicals can leach from wood for the life of the pile, allowing them to accumulate in sediments, and bioaccumulate in organisms (Smith 2008).  While some organisms can metabolize PAHs, others, such as some invertebrates, may be unable to effectively metabolize and excrete the chemicals (Smith 2008; NOAA 2009). Although effects to Figure 1: Tar like residue seen on creosote-treated piling in False Creek, Vancouver. Source: Younie, T. (2015). 	  Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 6 aquatic organisms may not occur instantly, these chemicals may accumulate in some species, which has implications for higher trophic levels (Washington Department of Natural Resources 2014).  5.0 Regulation 5.1 Canada When chemicals have the potential to be released into aquatic environments, such as when creosote leaches from pilings, this may be considered deleterious to fish habitat and is subject to regulation under the Fisheries Act, which is enforced by the Department of Fisheries and Oceans (Province of British Columbia 2013; Hutton & Samis 2000).  “Creosote-contaminated sites” and PAHs associated with such sites, are listed under Environment Canada and Health Canada’s First Priority Substances List, which identifies substances that may be harmful to the environment or human health (Environment Canada & Health Canada 1993; Environment & Health Canada 1994).  Although the Government of Canada has acknowledged that creosote may cause harm to the environment or to human health, in 2011 the Pest Control Products Act granted continued registration for sale and use of creosote in Canada (Health Canada 2011).  Zapf-Gilje suggests that there should be tougher regulations for creosote in Canada (2015). 5.2 Other Jurisdictions  Since 2003, consumer use of creosote has been banned in the European Union.  Tougher restrictions were implemented in 2013, which has disallowed creosote from being placed on the European market, unless authorized by the European Commission.  The European Commission suggests that creosote poses unacceptable risks to future generations, however they acknowledge that in some situations there are no alternatives (European Commission 2011).   Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 7 California Fish and Game have banned the continued installation of creosote-treated structures in the state’s marine environments since 1993 (Werme et al. 2011).  The U.S. Army Corps of Engineers, Los Angeles district requires any existing creosote-treated pilings to be wrapped in plastic in order to prevent leaching (NOAA 2009).  The Washington Department of Natural Resources has an ambitious creosote-treated pile removal plan and have disallowed the use of creosote-treated piles in freshwater lakes and state owned aquatic environments in order to reduce long-term harm to the environment and the food web (NOAA 2009; Washington Department of Natural Resources 2014).  In British Columbia, the Squamish Streamkeepers have been wrapping creosote-treated and concrete pilings since 2006 to aid in herring spawning.  They used roughened Enviro Liner, which was found to be attractive to the spawning herring (Matsen 2015).   This practice has been so successful that similar projects were also implemented in False Creek in Vancouver, and Cowichan Bay on Vancouver Island.  Ambitious plans to restrict the use of creosote have been implemented in the European Union and the United States, and mitigation plans have been used in British Columbia.  Although the risks of creosote have been acknowledged, it is still accepted as a viable wood treatment in Canada. 6.0 Removal Removing creosote-treated structures can cause adverse effects to the surrounding environment by disturbing habitats and releasing previously sequestered chemicals (Werme et al. 2011).  Cutting the piling at the mud line may be more cost effective than removing the whole piling (Werme et al. 2011).  This method causes less of a disturbance of sediments than a direct pull, yet a stump is left in place, which will continue to leach into the surrounding sediment and may cause problems for future development (Werme et al. 2011; Zapf-Gilje 2015).  The use of Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 8 water jets, which often accompanies this method, is discouraged, as too much contaminated sediment is disturbed (Washington State 2013; Smith 2008).   The direct pull method has the potential to release more chemicals, however the whole piling is removed, which prevents future leaching.  Zapf-Giljie suggests that removing the whole piling leaves holes in the sediment, creates pathways for other contamination, and reduces sediment stability, so this method may not be the safest (2015).  In order to reduce the amount of chemicals released into the environment, the Washington State Department of Natural Resources suggests that the vibratory method should be employed (2013).  This method may result in fewer disposal costs than a direct pull because less material is attached to the piling (Werme et al. 2011).  The use of absorbent pads should be used during installation and removal of treated woods until there is no evidence of chemicals visible in the water (Hutton & Samis 2000; Werme et at. 2011; Zapf-Gilje 2015).   Once removed, disposal of the material from creosote-contaminated sites can be expensive (Jebson 2015).  One estimate suggests disposal can cost $40-60 per ton (Werme et al. 2011).  Because this material is considered a hazardous waste, it cannot be burned, but instead needs to be buried in a landfill, so Jebson suggests that there should be a better way to dispose of this hazardous material (2015). 7.0 Alternatives 7.1 Treatments Although treated-wood is known to be harmful to the environment, it has been suggested that in some situations there are no alternatives to treated wooden piles and the structural characteristics of timber may be required for certain projects (Jebson 2015; European Commission 2011).  In cases such as these, there are other wood treatments that can be used that Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 9 are less environmentally damaging, yet retain the characteristics of wood.  Zapf-Gilje recommends the use of cooper-based treatments over creosote, which he suggests is less toxic to many aquatic organisms (2015). The California Coastal Commission (CCC) suggest that because the composition of metal arsenate treatments is better known, its use is more predictable in aquatic environments, and so is recommended over creosote (2012).  Since creosote may have different compositions for each batch, it may have varying effects on the environment, which the CCC suggests, makes it less predictable in aquatic environments (2012).  Use of any kind of chemically treated wood can cause adverse effects to the environment, so alternative materials should also be considered. 7.2 Materials Although alternatives are generally more expensive, Hutton and Samis suggest that the use of alternatives may be justified (2000).  Due to lifetime, strength and more benign characteristics, alternatives are often preferred over treated wood (Stratus 2006). However, it is important to note there is no perfect alternative, and each has advantages and disadvantages. 7.2.1 Concrete Jebson suggests that concrete is heavy and expensive, so it is not used often in Metro Vancouver (2015).  However, concrete may be applicable for large-scale industrial and commercial projects due to its weight and strength (Stratus 2006).  Due to these characteristics, fewer piles may be required, which will cause less destruction to surrounding habitats (Hutton & Samis 2000).  Although this material is expensive, concrete pilings may be cost effective over creosote-treated pilings when considering the long-term use of concrete and the number of pilings required (NOAA 2009; Stratus 2006).  When concrete pilings are first installed, there may be an initial increase of pH in the surrounding water, however chemicals do not leach for Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 10 the lifetime of the structure, like creosote-treated piles (Hutton & Samis 2000).  Matsen suggests that concrete pilings do pose adverse affects to herring eggs that are spawned directly on the concrete piling, so they should be covered (2015).  7.2.2 Steel Most creosote-treated structures in Metro Vancouver are now being replaced with steel pilings, which is a step in the right direction (Jebson 2015).  As with concrete, steel is also a very strong material so it is able to support large structures and fewer piles may be required.  Although steel pilings are relatively environmentally friendly, these structures rust in aquatic environments (CCC 2012).  In order to reduce corrosion of steel pilings, coatings can be used, however it is essential to select a coating that is environmentally inert to reduce further chemical exposure to the environment (CCC 2012; Hutton & Samis 2000).  Most new projects that use creosote-treated pilings are quite small scale, whereas larger projects generally use steel or concrete due to the stronger load-bearing capacity (Brooks 2005).  Although both concrete and steel may be less environmentally damaging than creosote-treated pilings, both materials do pose environmental concerns.  Cost is also an issue, as these materials are generally more expensive than timber, which may make them economically unfeasible for smaller stakeholders.  Concrete and steel also do not have the same structural characteristics as timber, such as its higher energy absorption, however alternatives such as plastic do possess similar characteristics to timber (Hutton & Samis 2000).  7.2.3 Plastic Plastic pilings, or recycled fiber reinforced polymer composite pilings, offer another option that is environmentally friendlier.  These pilings, which generally use recycled high-density polyethylene reinforced with steel or fiberglass, are treated to improve durability, Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 11 mechanical properties and UV protection (Iskander & Hassan 2001).  This prevents leaching, making them chemically inert, and safe for even sensitive aquatic environments (Iskander & Hassan 2001; Stratus 2006).  These pilings are strong, low density, and have desirable structural characteristics similar to timber (Stratus 2006).  However, copper has been shown to leach from recycled pilings at low levels, suggesting that the composition of recycled materials is unknown and may pose concerns for the surrounding environment (Stratus 2006). It has also been suggested that plastic pilings are susceptible to creep, which is a barrier for use of this material (Stratus 2006).  Despite plastic pilings being a potentially viable alternative, this material has not been used much in British Columbia, possibly due to high cost, which could be three times as expensive as creosote-treated timber (Stratus 2006).   7.3 Financial Impacts A comparison of cost, spacing, and lifetime between the above materials is summarized below (see table 1).  Although differing estimates for cost and lifetimes of pilings have been suggested, the data summarized by Stratus was used in this table to allow for easy comparison between materials.  Table 1: Cost estimates for alternative piling materials Material 80 foot piling Cost per foot Installation cost Spacing intervals Lifetime (years) Treated Wood $750-1000 $9-12.5 $500-770 10 foot  15 Steel $2400 $30 $794 20 foot 20 Concrete $2800 $35 $953 20 foot 20 Plastic (fibre reinforced) $3200 $40 $635 20 foot 20 Plastic (steel reinforced) $4000 $50 $635 10 foot 10      Source: Stratus Consulting. (2006). Treated Wood in Aquatic Environments: Technical Review and Use Recommendations.       Note: Estimated prices are in US$. These prices do not include removal or disposal costs. Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 12 Although alternatives are more expensive than treated wood per piling, they may be spaced further apart so fewer pilings may be needed, and alternatives may last longer.  Due to this, steel, concrete, and plastic reinforced with steel may be environmentally friendlier and economically feasible alternatives.   7.4 Coverings Since wooden pilings are preferable in some situations, wrapping allows for structural characteristics of timber, while limiting adverse effects to the environment (CCC 2012).  Finding an appropriate material and technique for installing the wraps is important to ensure that the wrapping is not breached, allowing the accumulation of PAHs to be released into the environment (Hutton & Samis 2000).  Matsen suggests that an appropriate material is not yet known, which will require further research (2015).  Currently Matsen and the Squamish Streamkeepers are wrapping pilings with Enviro Liner, a linear low-density polyethylene material (see figure 2).  Although this acts as an effective barrier between the herring egg and the creosote-treated pile, current practices by the Squamish Streamkeepers do not fill the gap between the wrap and the piling, nor does the covering reach below the mud line, so chemicals are still able to leach from the piling. The CCC suggests the use of polyvinyl chloride, or fiberglass reinforced plastic with an epoxy to fill the space between the pile and the plastic (2012). Such wrappings should be used to cover the entire pile and reach below the mud line, and should be used in sensitive ecosystems (Hutton & Samis 2000).  Although utilizing plastic to wrap creosote treated pilings may be Figure 2: Creosote-treated piling wrapped in Enviro Liner in False Creek, Vancouver Source: Younie, T. (2015) 	  Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 13 advisable to prevent contamination, materials and installation can be quite expensive.  Enviro Liner costs $15 for a five by eight foot piece, and requires a fair amount of work to install (Matsen 2015).  However, once installed, the material can last for 80 years, and will be less expensive and less environmentally damaging than removing the piling and replacing it with an alternative. 8.0 Conclusions, Recommendations and Further Research  Although other jurisdictions are banning the use of creosote, a full ban of creosote may not be advisable.  Zafp-Giljie suggests that banning implies that all creosote-treated pilings need to be removed, which would cause significant environmental damage (2015).  Instead, he suggests that the use of creosote should be phased out, and replaced with more environmentally friendly products.  However, Jebson proposes that in some situations there are not any suitable alternatives to treated-wood pilings (2015).  Matsen recommends that since creosote leaches and causes detrimental effects to the surrounding environment, its use should be banned, but he also acknowledges that alternatives, such as steel and concrete, are only slightly better (2015).  Pott suggests that ideally creosote should be banned, but there will be financial impacts, especially for small stakeholders, which may make a ban of the substance economically unfeasible (2015).    Considering these opinions, the literature, and policies implemented elsewhere, I will suggest that Port of Metro Vancouver should implement policy to phase out the use of creosote.  This can be done by limiting new construction of structures using creosote, and by opting for more environmentally friendly alternatives, wherever possible.  For existing creosote-treated structures that are in sensitive aquatic environments, such as freshwater areas, areas with limited water flow, or large projects with high concentrations of creosote, the creosote pilings should be wrapped in order to prevent leaching of chemicals from the piling.  Since there is a lack of viable Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 14 alternatives, further research should investigate alternatives that are both environmentally friendly and economically feasible.                      Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 15 9.0 References Bestari, K., Robinson, R., Solomon, K., Steele, T., Day, K., & Sibley, P. (1998). Distribution and composition of polycyclic aromatic hydrocarbons within experimental microcosms treated with creosote-impregnated Douglas fir pilings. Environ Toxicol Chem, 17(12), 2369-2377. doi:10.1002/etc.5620171202 Brooks, K. (2005). Creosote treated piling - Perceptions Versus Reality.  Retrieved from http://www.wwpinstitute.org/documents/PugetSoundCreosoteReport.pdf California Coastal Commission. (2012). Pilings – Treated Wood and Alternatives. Retrieved from http://www.coastal.ca.gov/nps/Pilings-Treated_Wood.pdf  Duncan, D. (2014). The toxicity of creosote treated wood to pacific herring (Clupea pallasi) embryos and characterization of polycyclic aromatic hydrocarbons near creosoted pilings in Juneau, Alaska. (Masters). University of Alaska Fairbanks. Environment Canada and Health Canada. (1993). First Priority List, Creosote-Impregnated Waste Materials. Environment Canada and Health Canada. (1994). First Priority Substance List, Polycyclic Aromatic Hydrocarbons. European Commission. (2011). Environment: Tighter restrictions on industrial creosote use.  Groyette, D., & Brooks, K. (1998). Creosote evaluation: Phase II Sooke Basin study. Retrived from http://www.wwpinstitute.org/documents/01Creosote98.pdf  Groyette, D., & Brooks, K. (2001). Continuation of the Sooke Basin creosote evaluation study. Retrieved from http://www.wwpinstitute.org/documents/SookeBasinRprt.pdf  Health Canada. (2011). Heavy Duty Wood Preservatives: Creosote, Pentachlorophenol, Chromated Copper Arsenate (CCA) and Ammoniacal Copper Zinc Arsenate (ACZA). Hutton, K., & Samis, S. (2000). Guidelines to protect fish and fish habitat from treated wood used in aquatic environments in the pacific region. Vancouver. Retrieved from http://www.dfo-mpo.gc.ca/Library/245973.pdf  Iskander, M. & Hassan, M. (2001). Accelerated Degradation of Recycled Plastic Piling in Aggressive Soils. Journal Of Composites For Construction, 5(3), 179-187. doi:10.1061/(asce)1090-0268(2001)5:3(179)  Jebson, B. (2015). Fraser River Pile and Dredge. New Westminister. Interview. Matsen, J. (2015). Squamish Streamkeepers. Vancouver.  Interview.  Creosote-Treated Pilings: Risks, Financial Impacts, and Alternatives 	  Younie 16 National Oceanic and Atmospheric Administration. (2009). The use of treated wood products in aquatic environments. Retrieved from http://www.westcoast.fisheries.noaa.gov/publications/habitat/treated_wood_guide lines_final_2010.pdf  Pott, U. (2015). Environment Canada. Vancouver. Interview. Province of British Columbia. (2013). Guidelines for Use of Treated Wood In and Around Aquatic Environments and Disposal of Treated Wood. Retrieved from http://www.th.gov.bc.ca/publications/eng_publications/environment/references/G uidelines-Treated_Wood.pdf  Smith, P. (2008). Risks to human health and estuarine ecology posed by pulling out creosote-treated timber on oyster farms. Aquatic Toxicology, 86(2), 287-298. doi:10.1016/j.aquatox.2007.11.009  Stratus Consulting. (2006). Treated Wood in Aquatic Environments: Technical Review and Use Recommendations. Washington Department of Natural Resources. (2013). Derelict creosote piling removal best management practices for pile removal & disposal. Retrieved from https://salishsearestoration.org/images/f/f9/WDNR_2013_piling_and_creosote_re moval_BMP.pdf  Werme, C., J. Hunt, E. Beller, K. Cayce, M. Klatt, A. Melwani, E. Polson, and R. Grossinger. (2010). Removal of Creosote-Treated Pilings and Structures from San Francisco Bay. Prepared for California State Coastal Conservancy. Contribution No. 605. San Francisco Estuary Institute, Oakland, California.  Western Wood Preservation Institute and Wood Preservation Canada. (2011). Best practices for use of treated wood in aquatic and wetland environments. Retrieved from http://www.wwpinstitute.org/documents/BMP_Revise_4.3.12.pdf  Zapf-Gilje, R., Patrick, G., & McLenehan, R. (2001). Overview of the remediation process at sites with creosote related contamination in soil, groundwater and river sediment. Canadian Journal Of Civil Engineering, 28(S1), 141-154. doi:10.1139/cjce-28-s1-141  Zapf-Gilje, R. (2015). GeoEnviroLogic Consulting Ltd. Vancouver. Interview. 

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