xvEPA
United States
Environmental Protection
Agency
For more information
If you are interested in the Burnham
Canal site cleanup, please attend a
public meeting:
Cafe el Sol, United Community
Center
1028 S. 9th St., Milwaukee
Tuesday, June 28, 6 p.m.
EPA will explain the proposed plan
and give you an opportunity to ask
questions and make comments
orally or in writing. If you need
special accommodations to attend
the meeting, contact Heriberto Leon
by June 21 (see below.)
EPA is accepting comments on the
proposed plan from June 15 through
July 15. Submit comments
on the proposed plan:
• Orally or in writing at the June 28
public meeting.
• Via the Web at www.epa.gov/
regionS/cleanup/burnham/
pubcomment.html.
• Fax to Heriberto Leon at
312-697-2754.
Contact EPA
Nefertiti Simmons
Remedial Project Manager
312-886-6148
simmons.nefertiti@epa. gov
Heriberto Leon
Community Involvement
Coordinator
312-886-6163
leon.heriberto@.epa.gov
Call toll-free: 800-621-8431,
weekdays, 8:30 a.m. - 4:30 p.m.
EPA Proposes Cleanup Plan
for Burnham Canal
Burnham Canal Superfund Site
Milwaukee, Wisconsin
June 2011
The U.S. Environmental Protection Agency is proposing a plan1 to clean up
contaminated sediment and soil at the west end of Milwaukee's Burnham
Canal. EPA encourages you to comment on the proposed plan at a public
meeting June 28, or any time by July 15 (see box, left). A more detailed
version of the proposed plan is available online and at the information
repositories.
The plan calls for digging up highly contaminated sediment and disposing
of it off-site; placing a 12-inch clean cover over remaining contaminated
sediment in the canal up to the 11th Street bridge; digging up contaminated
soil on the west bank, disposing of it off-site and replacing it with clean
soil; placing fencing and signage around the sediment cover and the paved
soil cover areas to ensure that it remains in place and effective; and placing
industrial land use restrictions on the property.
EPA, with input from the Wisconsin Department of Natural Resources, will
select a final cleanup plan for the sediment and soil after considering
comments from the public. The final plan could differ from this proposed
plan, depending on information or comments EPA receives during the
public comment period. EPA will announce the final plan in a local
newspaper.
About the Burnham Canal site
The Burnham Canal Superfund Site is in an industrial area 0.4 miles south
of the Menomonee River. It is bounded on the west by South Muskego
Avenue, on the east by South 11th Street, on the south by Bruce Street,
and on the north by a rail yard.
Burnham Canal provided river access to industries in the southern part of
the Menomonee River Valley. A federally authorized navigation channel,
it was dredged and maintained by the U.S. Army Corps of Engineers.
In the mid 1980s, a street-level fixed bridge was constructed across the
canal at 11th Street, blocking large ship traffic from moving upstream.
Since that time, navigation in the west end of the canal has been limited
to small watercraft (e.g., canoes, fishing boats, etc.). Navigational use of
the canal is limited. The canal is still a federally authorized navigation
channel east of the 11th Street Bridge, but it has not been dredged since
the fall of 1987 and no future dredging is anticipated.
1 Section 117 (a) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) 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 is a summary of information contained in the remedial investigation,
feasibility study, and other documents in the administrative record for the Burnham Canal
site. Please consult those documents for more detailed information.
1
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Burnham Canal in a satelllite image.
Miller Compressing Co. operated a wire reclamation
furnace for copper wire recycling about 75 to 100
feet from the west end of Burnham Canal. It operated
from the early 1970s until 1986 or 1987, and is the
likely source of high copper and Poly cyclic Aromatic
Hydrocarbon (PAH) concentrations detected in canal
sediment. Other Miller operations in the area
included non-ferrous recycling, and shearing and
baling activities. The company consolidated
non-ferrous operations to other areas of its property
and discontinued shearing and baling.
Summary of site risks
Miller conducted a study in 2010 of the risks posed to
people and the environment by the concentrations of
contamination on the site. The risk assessment
indicated there is a significant risk to benthic
organisms in the canal exposed directly to the high
levels of metals and PAHs, in their environment.
Miller's study did not investigate the ground water
because of the heavy industrial setting of the facility,
and the inability to distinguish Miller's ground water
contamination from that of other area industries.
Ground water contamination from Miller
Compressing Co. activities, as it potentially affects
the canal sediment, is being addressed with complete
excavation of all contaminated site soils which may
be transported to the canal sediment.
To evaluate the risk from soil, regional screening
levels for industrial soil were compared to the
concentrations of metals and PAHs found in the west
end soil and under the paved portion of the site.
Sample results above the regional screening levels of
copper, lead and PAHs were found. Exposure to high
levels of contamination in the west end soil could
occur by ingestion, skin contact and inhalation
(workers only). This is mostly a concern for
trespassers and on-site workers.
The risk assessment conducted as part of the study of
the contamination on the site indicates that the majority
of the canal sediment and west end soil exceed their
respective screening values. Sample results above the
risk-based screening values indicate that the sediment
and soil at the Burnham Canal site present an
unacceptable risk to people and the environment.
Cleanup options
EPA considered four options to clean up the sediment
and five options to clean up the soil. Each option was
evaluated against seven criteria, as required by the
federal Superfund law (see box, Page 6). They have
not yet been evaluated for state and community
acceptance because these criteria are typically judged
after EPA proposes a cleanup plan and holds a public
comment period.
2
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Soil Options
Soil Option 1 - No further action
This option is a baseline scenario to which other
options may be compared. Under this option, EPA
would take no action at the site to prevent exposure to
soil contamination. Cost: $0
Soil Option 2 - Land Use Restrictions, Pavement
and Engineered Cover (Geosynthetic Clay Liner)
Paved Soil: A pavement cover presently exists at the
west end of the site. This existing cover is composed of
five inches of asphalt and four inches of sub-grade
material. The cover would not require additional
thickness, although it would require inspections and
maintenance. The cover meets the requirements for an
engineered cover and would be maintained for future
site activities. In addition, land-use restrictions would
be put in place to ensure the land is used only for
industrial or commercial purposes and the existing
cover remains in place. This component is a part of all
the soil cleanup options.
Unpaved Soil: This option consists of placing a
geosynthetic clay liner cover (a GCL is a woven fabric-
like material with thin layers of clay sandwiched
between them, primarily used for the lining of landfills)
in the unpaved area to serve as an engineered barrier.
This option would include the removal of the top six
inches of material and excavation of an anchor trench
to install the GCL. Excavated soil would be disposed of
off-site. A 6-inch layer of imported clean material
would be placed over the GCL, compacted and graded
to protect GCL integrity. To complete the installation,
the unpaved area would be covered with a 6-inch layer
of topsoil and seeded, along with riprap at the
soil/water interface to prevent future erosion.
Cost: $282,000
Time to implement: 1 month
Soil Option 3a - Land Use Restrictions, Pavement
and Soil Cover
Unpaved Soil: This option includes placement of a 2-
foot thick cover of clean material over the entire
unpaved area. Prior to placing the cover, the top six
inches of material would be excavated and disposed of
off-site. Eighteen inches of imported clean material
would be placed, compacted and graded over the entire
unpaved area, along with additional material at the toe
for transition into the canal. To complete the cover, the
unpaved area would be covered with a 6-inch layer of
topsoil and seeded, along with riprap at the soil/water
interface to prevent future erosion.
Cost: $279,000
Time to implement: 1 month
Read the documents
You may inspect site-related documents and files at
these Milwaukee locations:
Forest Home Library
1432 W. Forest Home Ave.
United Community Center
1028 S. 9th St.
An administrative record, which contains detailed
information that EPA considers before selecting the
cleanup plan, is located at EPA's regional office at
77 W. Jackson Blvd., Chicago.
On the Web:
www. epa. gov/region5/cleanup/burnham/
www.epa.gov/reg5sfun/sfd/npl/sas_sites/
Soil Option 3b - Use Restrictions, Pavement,
Excavation (2 feet) and Soil Cover
Unpaved Soil: Same as Option 3a, except the excavation
depth is two feet instead of six inches, and the resulting
surface grades and finished slope would be similar to the
existing conditions.
Cost: $299,000
Time to implement: 1 month
Soil Option 4 - Land Use Restrictions, Pavement,
Excavation to Water Table and Backfill
Unpaved Soil: This option includes excavation of the soil
down to the water table from the unpaved area to remove
more contaminants close to the canal and reduce future
adverse affects to ground water and/or the canal. The
excavation would consist of a 7-foot cut (sloped as
required for stability) on the west side of the unpaved
area east to the soil/water interface. The soil in the soil
boring 1 area would be excavated to one foot because
contamination is present only to that depth. Excavated
soil would be disposed of off-site and the area will be
reconstructed with clean backfill. Backfill would be
placed, compacted and graded to maintain a natural slope
to the canal. To complete the cover, the unpaved area
would be covered with a 6-9 inch layer of top soil and
seeded, along with riprap at the soil/water interface to
prevent future erosion.
Cost: $345,000
Time to implement: 1.5 months
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Sediment Options
Sediment Option 1 - No further action
This option is a baseline scenario to which the
other options may be compared. Under this option
EPA would take no action at the site to prevent
exposure to sediment contamination.
Cost: $0
Time to implement: 0 days
Sediment Option 2a - West End Dredge and 6-
Inch Cap
This option includes dredging 200 cubic yards of
sediment from the west end of the canal. The material
in this area contains the highest concentration of
copper. The material would be dredged and disposed
of off-site. Depth and area for the removal are based
on a goal of removing the area with the highest
copper concentration and removing the shallowest
near-shore sediment to accommodate the placement
of a cover.
This option also includes placing a 6-inch sand cover
over the canal up to the 11th Street Bridge and
placing armor stone at the combined sewer outfalls.
The sand cover would be evenly distributed over the
entire sediment area of concern. Prior to sand cover
placement, an easement or equivalent approval
mechanism would be obtained from landowners
along the south boundary of the canal.
This cover would separate the underlying
contaminated sediment and reduce the potential
exposure to the plants and animals living in or on the
bottom of the canal. The cover would be designed to
reduce direct contact with these plants and animals
and minimize the ability for burrowing organisms to
move contaminated sediment from underneath the
cover to the top of the cover.
Riprap paired with geotextile (tightly woven fabric
used to restrict the flow of fine particles and
contaminants while allowing water to pass through
freely) would be placed at two outfalls along the
canal to prevent future erosion. In addition, to ensure
that the sand cover remains in place and is not
disturbed, the area would be fenced and zoning and
deed restrictions would be implemented.
Cost: $1.3 million
Time to implement: 3 months
Sediment Option 2b - West End Dredge and 12-
Inch Sand Cover
This option is the same as option 2a, except the
thickness of the sand cover for Option 2b would be 12
inches instead of six inches.
Cost: $1.9 million
Time to implement: 4 months
Sediment Option 3 - Full Dredge and 6-inch
Sand Cover
This option involves dredging about a 22-foot depth at
the west end and a 15 -foot depth at the east end near
the 11th Street Bridge. The amount of material to be
dredged for this option is about 60,000 cubic yards of
sediment. This option requires significant structural
support of surrounding seawalls. For purposes of
estimating the cost, it is assumed that permanent sheet
piling with tie-backs would be required along 50
percent of the shoreline. Temporary stabilizing sheet
piles would also be needed on the west end due to the
depth of the cut. Once the sediment removal is
completed, backfill would be necessary at the west end
of the canal to recreate a stable slope, as well as riprap
at the face for shoreline erosion protection. After the
dredging is complete, a 6-inch sand cover would be
placed over the sediment, similar to the 6-inch sand
cover presented in option 2a.
Cost: $22 million
Time to implement: 12 months
EPA's proposed cleanup plan
EPA's recommended option is Alternative 4 for the soil
and Alternative 2b for the sediment. The cleanup plan
consists of soil excavation and backfill, west end
sediment removal, a 12-inch sand cover over the
remaining canal sediment to the 11th Street Bridge, and
restrictions on how the land can be used.
Soil Alternatives:
All soil alternatives, except the "No Action"
Alternative are protective and meet applicable or
relevant and appropriate federal, state and local
requirements, known in EPA terms as "ARARs."
None of the soil alternatives employ treatment to
reduce toxicity, mobility or volume of hazardous
substances. There are no possible treatment options
for this soil contamination. All alternatives are
readily implementable and have manageable
short-term impacts. There is not a significant cost
difference among the protective alternatives.
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Therefore, Alternative 4 is the recommended soil
alternative because it provides the greatest long-
term effectiveness and it significantly reduces the
potential movement of contamination from the
upland soil into the canal sediment by erosion and
the movement of contaminants to canal sediment by
ground water from the contaminated soil.
Sediment Alternatives:
All sediment alternatives, except the "No Action"
Alternative, are protective of human health and the
environment and meet ARARs. None of the
alternatives employ treatment to reduce toxicity,
mobility or volume of hazardous substances. There
are no possible treatment options for this sediment
contamination.
Alternatives 2a and 2b are similar in terms of short-
term effectiveness and implementability, and they are
relatively close in cost. The 12-inch cover of
Alternative 2b is preferable to the 6-inch cover of
Alternative 2a because it is longer lasting and better
able to withstand sediment disturbance.
The full dredge option, Alternative 3, is very
disruptive in the short term. It costs over 10 times
more than Alternatives 2a and 2b without providing
significantly greater effectiveness.
Therefore, Alternative 2b is the EPA's recommended
sediment cleanup alternative.
How do the options compare?
The nine criteria required by the federal Superfund
law are described in the box on Page 6.
The chart on Page 7 shows how the various options
compare to one another for the seven criteria already
evaluated. The remaining two criteria - state and
community acceptance - will be evaluated after EPA
receives public comments.
Next steps
EPA, in consultation with WDNR, will evaluate
public reactions to the recommended cleanup
options during the public comment period before
deciding on a final cleanup plan for the sediment
and soil.
Based on new information or public comments,
EPA may modify its recommended options or
select others. EPA encourages the public to
review and comment on the cleanup options.
EPA will respond in writing to public comments
in a document called a "responsiveness
summary," which will be attached to the
document detailing the final cleanup plan, called a
"record of decision."
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Evaluating the options
EPA uses nine criteria to evaluate and compare cleanup options. See the table on Page 7 comparing
the options 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 cleanup option meets federal, state and local laws and regulations.
3. Long-term effectiveness and permanence evaluates how well a cleanup 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 cleanup
option reduces the harmful effects, movement and amount of contaminants.
5. Short-term effectiveness compares how quickly the cleanup can be completed and the
health risks posed to cleanup workers and nearby residents while the option is being completed.
6. Implementability assesses how difficult the cleanup option will be to construct and operate, and
whether technology, materials and services are readily available.
7. Cost compares the expense of each option over time, including costs for buildings, machines and
wells, plus operation and maintenance costs. 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, Wisconsin Department
of Natural Resources, agrees with EPA's recommended option. EPA evaluates state acceptance after
it receives public comments.
9. Community acceptance evaluates how well the community near the site accepts the option. EPA
and WDNR will evaluate community acceptance after the public comment period.
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Evaluation Criteria for the Burnham Canal Site
Evaluation Criteria
Overall Protection Of Human
Health And The Environment
Compliance With ARARs
Long -Term Effectiveness
And Permanence
Reduction Of Toxicity,
Mobility, Or Volume Through
Short -Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Soil Options
1
D
D
D
D
•
•
•
2
•
•
D
D
•
•
•
3A
•
•
D
D
•
•
•
3B
•
•
D
D
D
•
•
-
•
•
D
D
•
•
Will be evaluated after the public comment period.
Evaluation Criteria
Overall Protection Of Human
Health And The Environment
Compliance With ARARs
Long -Term Effectiveness
And Permanence
Reduction Of Toxicity, Mobility,
Or Volume Through Treatment
Short -Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Sediment Options
1
D
D
D
D
•
•
•
2A
•
•
D
D
D
•
•
2B
•
•
•
D
D
•
•
3
•
•
•
D
D
D
D
Will be evaluated after the public comment period.
I Fully Meets Criteria
I Partially Meets Criteria
Does Not Meet Criteria
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Public Meeting
Burnham Canal Site Cleanup
Tuesday, June 28
6 p.m.
Cafe el Sol, United Community Center
(Centro de la Comunidad Unida)
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1028 S. 9m St., Milwaukee
EPA cleanup experts will explain the proposed plan and give you opportunity to ask
questions and make comments orally or in writing.
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EPA is interested in your comments on the proposed cleanup plan for the Burnham Canal site. EPA will consider public
comments before selecting a final cleanup plan. Please use the space below to write your comments, then fold and
mail this form. Comments must be postmarked by July 15. 2011. Comments may also be faxed to Heriberto Leon at
312-697-2754. If you have general questions, contact Heriberto Leon at 312-886-6163 or through EPA's toll-free number
at 800-621-8431. 8:30 a.m. to 4:30 p.m.. weekdays. Comments may also be submitted to EPA via the Internet at:
www.cpa.gov/rcgion5/cleanup/bumham/pubcomment.html.
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Fold on Dashed Lines, Tape, Stamp, and I
Name ______________
Address
City State
Zip
Nefertiti Simmons
Remedial Project Manager
EPA Region 5 (SR-6J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
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