oEPA
     United States
     Environmental Protection
     Agency
 Share your opinions
 If you are interested in the proposed
 Waukegan Harbor cleanup plan, please
 attend the upcoming public meeting on
 Thursday, Nov. 13, at the Waukegan Park
 District's Jane Addams Center from 6 to
 8 p.m. (details on back page).
 Written statements on the proposed plan
 can also be submitted during the public
 comment period that runs Nov. 3, 2008 -
 Jan. 5, 2009, through these methods:
  • Orally or in writing at the public
   meeting.
  • By mail (see enclosed comment
   form).
  • Electronically via the Web at
   epa.gov/region5/publiccomment/.
  • Via fax to Kevin Adler at 312-353-
   5541.
 For more information
 Mike Joyce
 EPA Community Involvement
 Coordinator
 800-621-8431, Ext. 35546
 8:30 a.m. - 4:30 p.m., weekdays
 j oyce .mike@epa.gov
 Kevin Adler
 EPA Remedial Project Manager
 800-621-8431, Ext. 67078
 8:30 a.m. - 4:30 p.m., weekdays
 adler.kevin@epa.gov
 Tammy Mitchell
 Illinois EPA Community Relations
 Coordinator
 217-524-2292
 tammy.mitchell@illinois .gov
 Erin Rednour
 Illinois EPA Project Manager
 217-785-8725, Tuesday through Friday
 erin.rednour@illinois.gov
EPA  Proposes  Cleanup  Plan
For Harbor Pollution
                                       Outboard Marine Corp. Waukegan Harbor Site
                                       Waukegan, Illinois
                                                      October 2008
U.S. Environmental Protection Agency proposes to dredge contaminated
sediment from Waukegan Harbor and store it in a special containment area on
the former Outboard Marine Corp. Plant 2 site. EPA's recommended cleanup
option is one of five alternatives considered to remove PCB-contaminated
sediment (mud) left behind from a 1992 project. The sediment PCBs are a
potential human health risk because they are accumulating in harbor fish. People
are then catching and eating these fish. PCBs, or polychlorinated biphenyls,
were once a common industrial compound. The compound usually is found as
an oily liquid that does not dissolve very well in water. When this oily liquid
is spilled, it tends to cling tightly to clay particles in mud, and therefore it can
contaminate bottom feeders such as carp as they forage in the sediment for food.
The PCBs also accumulate in game fish and their predators.
EPA has concluded the proposed cleanup techniques will protect human health
and the environment, provide long-term effectiveness, comply with federal
and state environmental regulations, and will be cost effective. The preferred
cleanup plan will also preserve the present commercial, navigational and
recreational uses of Waukegan Harbor as well as restore an important natural
resource for the citizens of Waukegan and state of Illinois.
Before EPA makes a final decision it will accept written public comments
on the cleanup plan from Nov. 3, 2008 - Jan. 5, 2009. EPA will hold a
public meeting from 6-8 p.m., Thursday, Nov. 13, at the Waukegan Park
District's Jane Addams Center to present the proposed plan. Written and oral
comments on the proposed plan will be accepted at the meeting. Your opinion
counts. Based on public input EPA could modify the  preferred cleanup plan or
pick another option.
This proposed plan fact sheet provides background information about the OMC
Superfund site, describes the various cleanup options  considered, and identifies
EPA's recommended cleanup option. The public is encouraged to review
the supporting information for the OMC site. The information includes the
remedial investigation, the feasibility study and the site-wide human health and
ecological risk assessment report. The remedial investigation studies the nature
and extent of contamination at the site, while the feasibility study evaluates
different cleanup options. The risk assessment looks at potential health risks to
people and wildlife due to contamination at the site.
EPA's preferred cleanup plan includes using a hydraulic dredge to remove
sediment from the harbor that contains PCB levels at  1 part chemical per
million parts sediment and above. A part per million or ppm is a tiny amount,
equal to one second in 12 days, but even small amounts of hazardous substances

^Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA,
known as the Superfund Law) requires publication of a notice and a proposed plan for the site remediation.
The proposed plan must also be made available to the public for comment. This proposed plan fact sheet is a
summary of information contained in the remedial investigation, feasibility study, and other documents in the
administrative record for the OMC Plant 2 site. They are available for review at the Waukegan Public Library,
128N. County St.

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can cause health problems for people and animals. Under
EPA's preferred cleanup alternative, the dredged sediment
would be pumped to the nearby OMC Plant 2 site into
a containment area to be dewatered and then covered
with clean soil. Water removed from the sediment would
be filtered and then discharged back into the harbor. As
effective as this method is, however, not all PCBs can be
removed this way. So, after the dredging step is completed,
a thin layer of clean sand will be placed on the bottom
of the harbor to dilute the very small amounts of leftover
PCBs. For safely reasons, dredging will also avoid areas too
close to the harbor walls to avoid the potential for collapse.
Instead, a thick, armored cap (layer of rocks) will  be placed
on the sediment near the walls to prevent contact with the
PCBs by bottom-feeding fish.

About the OMC site
The OMC Supcrfund site is located on Seahorse Drive and
Waukegan Harbor in Waukegan, Lake County, 111.
(Figure  1, Page 3).  EPA sometimes divides complex
cleanup sites into smaller parts called operable units.
or OUs. The OMC  site contains four OUs. OU1 is
the Waukegan Harbor site;  OU2 is the Waukegan
Manufactured Gas and Coke Plant site; OU3 is the  PCS
containment cells; and OU4 is the  OMC Plant 2 site. The
city of Waukegan now owns much of the OMC property.
EPA began cleanup work at the OMC Superfund site in the
early  1980s. The  state had documented PCS contamination
in Waukegan Harbor in the mid-1970s, and the site was
placed on the first Superfund National Priorities List in
October 1981. After studying area PCS levels in sediment
and soil, EPA issued a document called a "record of
decision" in 1984 that selected the  first harbor cleanup
action using a 50 parts per million PCB cleanup level. OMC
then spent about $21 million to clean up the harbor during
1990 - 1992 by dredging the north harbor area and placing
the dredged material into former Boat Slip #3 after it was
converted into a containment cell.
OMC also dug up PCB-laden soil on the north side of
its Plant 2 property and placed it into two newly created
containment cells located on the north side of Plant 2.
OMC thermally treated some of the dredged sediment prior
to placement into the containment cells and was able to
recover more than 30,000 gallons (about 300,000 pounds)
of PCB-tainted oil from the sediment. The PCB-oil was
trucked off-site for destruction.
As part of the harbor cleanup, OMC constructed Boat
Slip #4 to replace former Boat Slip #3 for Larsen Marine
Service. Some of the soil excavated from Boat Slip #4
contained creosote, leading to the discovery of the long-
forgotten Waukegan Coke Plant site. The coke plant area is
being cleaned up by several  former owner/operators under
EPA supervision and is not the subject of this proposed
cleanup plan.
Until it declared bankruptcy in 2000, OMC was in charge of
inspecting and maintaining the three PCB containment cells.
EPA and then Illinois EPA performed these tasks until mid-
2005 when the city of Waukegan assumed responsibility
for this work. The city purchased the Waukegan Coke Plant
property- from OMC in 2002. After OMC legally abandoned
OMC Plant 2 in 2002, the city' acquired this property' in
2005. Waukegan wants to redevelop these former OMC
properties in accordance with the lakefront redevelopment
plan it completed in 2003.
The  OMC Plant 2 building was a 1-million-square-foot
facility7 where the company made outboard motors from
about 1948 until 2000. The building was abandoned in
2002. From 1961 until 1972, the production lines of Plant
2 used hydraulic and lubricating oils containing PCBs.
OMC discharged waste oils from Plant 2 through its
sewer line into the harbor, which was the source of the
PCB contamination in Waukegan Harbor sediment. OMC
plugged the sewer line in 1976.
In 2004 EPA began to study  the nature and extent of soil
and ground-water contamination at the OMC Plant 2
facility. EPA issued a record of decision for cleanup of the
contaminated soil and building in September 2007 and also
issued a proposed cleanup plan for contaminated ground
water this August. EPA's first cleanup plan for the OMC
Plant 2 site addressed the contaminants (mostly PCBs)
found within large portions of the OMC Plant 2 building
and in soil and sediment outside the facility'. The plan
called for EPA to demolish and dispose of the contaminated
building and to excavate and dispose of contaminated soil
and sediment. EPA has completed the design plans and
specifications for this work.


In 2003, EPA began to study the nature and extent of
remaining PCB contamination in Waukegan Harbor
sediment. A pair of pollution reports called the "'remedial
investigation and feasibility  study'' were completed this
summer. Sample results indicate the harbor contains about
220,000 cubic yards of sediment, with average PCB levels
at 2 to 3 parts per million. Figure 2, (Page 4) presents
the locations and results of the recent harbor  sediment
sampling for PCBs. While PCB levels in harbor-caught
fish went down after the first cleanup action, recent fish
sampling results show PCB concentrations in fish are still
above acceptable levels.

             Of
EPA also completed a study  at the Waukegan Harbor
site of potential risks to public health, wildlife and the

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                        Former
                        Oval Lagoon
North Shore Sanitary District
         North Ditch
          Former
          Crescent Ditch
    St. Mary
    Cement
                                                          Waukegan Coke
                                                             Plant Site
                                               Bombardier Facility
                                             (Former OMC Plant 1)
                                                                 ity of Waukegan
                                                                  Water Plant
          Waukegan Port
             District
                                  Operable Unit- Number
                                   \f~^\  Waukegan Harbor - #1

                                   22  Waukegan Coke Plant - #2

                                   253  PCB Containment Cells - #3

                                   I     I  OMC Plant 2-#4
Figure 1 - OMC Super fun d site and area features

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environment. PCBs are suspected of causing cancer,
but they can also trigger non-cancerous health issues.
EPA calculated that eating harbor-caught fish containing
elevated PCB levels would pose unacceptable, non-
cancerous health risks to people. Currently, as little as one
meal per week of harbor-caught fish could lead to PCB
exposures in adults that are 3- to 11-times higher than
thought to be safe. Infants and children are more sensitive
to PCBs so  if they eat one meal per week of harbor-caught
fish the PCB exposures would be 8- to 28-times higher than
safe levels.

Cleanup goals
Based on cleanup work done at similar sites, EPA expects
if PCB levels in Waukegan Harbor sediment are reduced
to one-tenth their current levels, then concentrations of
the toxic compound in harbor-caught fish would begin to
decline to safe levels. EPA recognizes Waukegan Harbor
has certain commercial, navigational and recreational uses
that any cleanup plan should try to preserve.

Summary  of cleanup options
EPA considered five cleanup options or alternatives for
the PCB-contaminated harbor sediment.  Each option was
evaluated against nine criteria as required by Superfund
law (see Page 5). The five cleanup options  are summarized
below. Full details are available in the technical documents
on file in the OMC site administrative record that EPA
established at the Waukegan Public Library.
                                                                                       Maximum PCB Cone, (ppmj
                                                                                       For Each Sampling Location
                                               Harbor    Wauke9an Harbor
                                                               re


                                       Harbor Extension
                                              ^"_ _ «..„„»,,, ,fy
   Figure 2 - PCB concentrations in Waukegan Harbor

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   Evaluating the options
   EPA used the following nine criteria to evaluate each of the five cleanup options. The table on Page 7 compares
   each one against these criteria:
   1. Overall Protection of Human Health and the Environment addresses whether an option adequately protects
   human health and the environment.  This criterion can be met by reducing or eliminating contaminants, or by
   reducing people's exposure to them.

   2. Compliance with Applicable or Relevant and Appropriate Requirements, referred to as ARARs, ensures
   that each project complies with federal, state and local laws and regulations.

   3. Long-term Effectiveness and Permanence evaluates how well an option will work in the long term,
   including how safely remaining contaminants can be managed.

   4. Reduction of Toxicity, Mobility, or Volume through Treatment addresses how well the option reduces the
   harmful effects, movement and amount of contaminants through permanent treatment methods.

   5. Short-term Effectiveness evaluates how quickly the cleanup can be done,  as well as its potential impacts on
   cleanup workers, area residents, and the environment.

   6. Implementability evaluates the technical difficulty in building and operating the cleanup system and whether
   materials and services  are routinely  available to complete the project.

   7. Cost includes estimated capital or startup costs. An example is the cost of buildings, treatment systems
   and monitoring wells. It also considers cost to implement the cleanup and operate and maintain it over time.
   Examples include laboratory analysis, repairs, and personnel hired to operate equipment. A cleanup is considered
   cost effective if its costs are proportionate to its overall effectiveness.

   8. State Acceptance is whether the  state environmental agency, in this case Illinois EPA, agrees with EPA's
   recommended option.

   9. Community Acceptance evaluates how well the community near the site accepts the option. EPA and Illinois
   EPA will evaluate community acceptance after the public comment period.
The five harbor cleanup options are explained below:
Option Dl: No further action
EPA uses the no-action option as a basis for comparison
with other cleanup options. Under this option, EPA
would take no action to remove or contain the PCBs in
the harbor sediment. The potential health risks due to
people eating PCB-contaminated, harbor-caught fish
would remain for at least 100 years. The state-issued fish
consumption advisories for the harbor would also stay in
effect. Cost: $0
Option D2: Environmental dredging with residual sand
cover (EPA's recommended cleanup option)
Under Option 2, EPA's recommended cleanup option, the
harbor would be hydraulically dredged to remove PCB-
contaminated sediment at levels of 1 part per million and
above. The dredged sediment would be pumped to the
OMC Plant 2 property to be dewatered where it would
then remain, covered with a clean soil layer. The water
derived from the dredged sediment would be filtered
and then discharged back to the harbor. After dredging
is completed a thin, clean sand layer would be placed in
the harbor to allow for mixing with remaining sediment
to achieve the final PCB cleanup goal. Sediment very
near to the sidewalls of the harbor cannot be removed
and would be capped with armored materials. After EPA
completes the design stage and when funding is available,
construction activity for Option 2 could be completed
in about 12 months. EPA estimates the PCB levels in
harbor-caught fish will begin to fall to safe  levels within
five years of completion. The estimated cost to implement
this option includes periodic monitoring and maintenance
expenses related to the soil cover and demonstrating that
PCB levels in fish are falling. Cost: $34.9 million
Option D3: Environmental dredging with sand cover,
cap north harbor and Slip #4
Under this alternative, the harbor would be  hydraulically
dredged as described in Option 2 except for the northern
harbor extension and Slip #4. Instead of dredging, a 2-
to 3-foot sand and gravel cap would be placed over the
PCB-tainted sediment in these areas to create a barrier

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between the PCBs and bottom feeders. Institutional
controls would be placed on the capped area so that
future uses of the harbor would not interfere with the cap.
After EPA completes the design stage and when funding
is available, construction activity for Option 3 could be
completed in about 12 months. EPA estimates PCB levels
in harbor-caught fish will begin to fall to safe levels
within five years of completion. The cost includes periodic
monitoring and expenses related to five-year reviews at
the site. Cost: $33 million
Option D4: Environmental dredging with cap
Under Option 4, the harbor would be hydraulically
dredged only in areas that exceed the 1 part per million
cleanup level. An armored cap would then be placed into
the channel to isolate remaining PCB-tainted sediments.
Current harbor depths would not be affected after the
cleanup is completed. Placement of the armored cap,
however, would tend to discourage future dredging
activities to increase harbor depths. Institutional controls
would be placed on the capped area so that future uses
of the harbor would not interfere with the cap. After EPA
completes the design stage and when funding is available,
construction activity for Option 4 could be completed
in about 12 months. EPA estimates PCB levels in
harbor-caught fish will begin to fall to safe levels within
five years of completion. The cost includes periodic
monitoring and expenses related to five-year reviews at
the site. Cost: $24.4 million
Option D5: Cap entire harbor
With this alternative, nearly the entire harbor would be
covered with a 3- to 5-foot sand and gravel cap or an
armored cap to isolate the PCB-tainted sediment. The
current depths would not be maintainable. Institutional
controls would be placed on the capped area so that
future uses of the harbor would not interfere with the cap.
After EPA completes the design stage and when funding
is available, construction activity for Option 5 could be
completed in about 12 months. EPA estimates that PCB
levels in harbor-caught fish will begin to fall to safe levels
within five years of completion. The cost includes periodic
monitoring and expenses related to 5-year reviews at the
site. Cost: $9.6 million

How do the options compare?
EPA evaluated the cleanup options against seven of the
nine cleanup criteria. The state and community acceptance
criteria will be evaluated after EPA receives public
comments. The degree to which the cleanup options meet
the evaluation criteria and how they compare to other
cleanup options are discussed below and illustrated in the
table on Page 7.
Option 1 (no action) does not protect human health and
the environment and was rejected. Options 2, 3, 4, and 5
 Review OMC site-related documents
 Waukegan Public Library
 Reference Desk
 128 N. County St.
 EPA Region 5 Record Center
 77 W. Jackson Blvd., 7th Floor
 Chicago, 111., weekdays 8 a.m. - 4 p.m.
 Certain EPA information, including this fact sheet, can
 be reviewed electronically at: www.epa.gov/region5/
 sites/outboardmarine.
 An administrative record, which contains detailed
 information upon which the selection of a cleanup plan
 will be based, is also located at the Waukegan Public
 Library and at the EPA Chicago office.
protect human health and the environment because EPA
estimates PCB levels in harbor-caught fish will begin to
fall to safe levels within five years of the completion of
any of these cleanup actions.
Although Option 5 is the least expensive cleanup method,
it would tend to make the harbor channel too shallow for
industrial users to cost-effectively bring  in raw materials
needed to manufacture their products. Option 4 is the
second least expensive method and would maintain
the current harbor depth. However, because much of
Waukegan Harbor is a federally-authorized channel, EPA
would likely be legally prevented from conducting either
Option 4 or Option 5 if future depth maintenance activities
cannot be performed.
Option 2 and Option 3 would cost nearly the same
amount to conduct and are the most expensive cleanup
methods that were evaluated. Each would allow continued
commercial, navigational and recreational use of the
harbor and future depth maintenance or dredging actions
because the bulk of the  PCB-tainted sediment would be
removed. EPA believes  Option 2 is superior over Option 3
because that alternative allows more PCB-tainted sediment
to be permanently removed from the harbor with reduced
capping or cover maintenance. Full dredging of Waukegan
Harbor could also have  important redevelopment benefits
for the community
Waiver issue
All dredging options would require waiver of the state
ammonia discharge standard to allow in-harbor discharge
of water derived from the dredged sediment. The dredge
water will contain levels of ammonia that are typically
considered too high to discharge directly into Lake
Michigan without treatment. The ammonia results when
naturally-occurring organic material in the sediment
breaks down. It is not practical to eliminate ammonia

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from the estimated 5,000 gallons of water per minute
that will be removed from the dredged sediment prior
to discharge. However, EPA plans to filter the water to
remove any solid particles before the water is discharged
through a difluser into the harbor. The diffuser will dilute
the ammonia in harbor water so that little or no harm to
aquatic life in the harbor would occur while dredging is
ongoing.

EPA's
Based on the analysis completed to date, EPA believes
the best cleanup alternative for the harbor sediment
          contamination is Option 2: environmental dredging with
          residual sand cover. The total cost of conducling this cleanup
          option is an estimated at $34.9 million.

          After the public comment period and meeting EPA will make
          a final decision on the cleanup option. The Agency will
          publish its decision in a newspaper announcement and in a
          record of decision, which will be available for review at the
          Waukegan Public Library.

          After selection of the harbor cleanup option, EPA will put
          together the design plans and specifications for bidding the
          work. This step could take about 9 to 12 months to complete
          before actual cleanup work begins.
Evaluation           for the            of      under the OMC Plant 2
Criterion
Overall protection of human
health and the environment
Meets ARARs
Long-term effectiveness and
permanence
Reduction of toxicity, mobility, or
volume through treatment
Short-term effectiveness
Implementability
Cost (Present worth)
State acceptance
Public acceptance
Option 1
No Action
D
Not Applicable
D
D
D
•
$0
Option 2
Complete
Dredge**
•
•
•
D
12 months to
complete
•
$34.9 million
Option 3
Combination
Dredge plus
Cap
•
•
•
D
12 months to
complete
•
$33 million
Option 4
Partial Dredge
Cap
•
•
•
D
12 months to
complete
•
$24.4 million
Option 5
Complete Cap
•
•
•
D
12 months to
complete
•
$9.6 million
Will be evaluated after the public comment period
Will be evaluated after the public comment period
                     •Fully meets criteria
  DPartially meets criteria
*EPA's recommended option
DDoes not meet criteria

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      You're Invited to a Public  Meeting  about  the

   Proposed Cleanup of the Waukegan  Harbor Site
                             Thursday, Nov. 13, 2008
                                   6 - 8 p.m.
                  Waukegan Park District - Jane Addams Center
                               95 Jack Benny Drive
                               Waukegan, Illinois
 At the meeting, EPA will present the proposed cleanup plan, and you will have a chance to comment for the record.
 You also may submit your written comments at the meeting.

 If you need special accommodations for the public meeting, contact EPA Community Involvement Coordinator,
 Mike Joyce at 800-621-8431, Ext. 35546, 8:30 a.m. - 4:30 p.m., weekdays, ore-mailjoyce.mike@epa.gov.

 If you have scientific and technical questions about the proposed cleanup, you may contact EPA Remedial Project
 Manager Kevin Adler at 800-621-8431, Ext. 67078, 8:30 a.m. - 4:30 p.m., weekdays, or e-mail adler.kevin@epa.gov.

 Comments may be faxed to Kevin Adler at 312-886-4071 or submitted via the Web at:
 epa.gov/region5/publiccomment/.

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Fold on Dashed Lines, Tape, Stamp, and I
Name  ______________
Address 	
City   	State
Zip 	
                                          Kevin Adler
                                          Remedial Project Manager
                                          EPA Region 5 (SR-6J)
                                          77 W. Jackson Blvd.
                                          Chicago, IL 60604-3590

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Comment Sheet
U.S. Environmental Protection Agency is interested in your comments on the proposed cleanup plan for the OMC
Waukegan Harbor site. EPA will consider public comments before selecting a cleanup action for the Waukegan
Harbor. Please use the space below to write your comments, then fold and mail this form. Comments must be
postmarked by Jan. 5. 2009. If you have general questions, contact EPA Community Involvement Coordinator,
Mike Joyce at 312-353-5546, or through EPA's toll-free number at 800-621 -8431. You may also submit your
comments to EPA via the Web at epa.gov/region5/publiccomment.
                                                  Name
                                                  Address
                                                  City                                State_
                                                  Zip

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