U.S. EPA Superfund Program ^to sr/)
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Proposed Plan for the Soil and Sediment •
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Burnham Canal Site
Milwaukee, Wisconsin ^ PRO-^
EPA ANNOUNCES PROPOSED PLAN June 2011
The United States Environmental Protection Agency (EPA) is issuing the Proposed Remedial
Action Plan (Proposed Plan) to present EPA's preferred remedy for addressing contaminated soil
and sediment at the Burnham Canal Superfund Alternative Site (Site). The investigative work
conducted to date has been performed by the potentially responsible party (PRP). EPA is the
lead oversight agency for the Site, and the Wisconsin Department of Natural Resources (WDNR)
is the support oversight agency. This Proposed Plan summarizes information from the Remedial
Investigation (RI), completed in December 2010, and the Feasibility Study (FS) report, which
was completed in May 2011. The RI/FS, prepared by the PRP and approved by the EPA, is part
of the Administrative Record for the Site.
The Burnham Canal Site is located in Milwaukee, Wisconsin. The Site consists of Miller
Compressing Company's (Miller's) former wire reclamation furnace area and a portion of the
canal from the western terminus to the federal navigation channel located at the 11th Street
Bridge. The Site includes the sediment in the canal and the contaminated soil at the western
terminus of the canal. The Site extends approximately 1,500 feet from its west end to the 11th
Street Bridge, and ranges from 95 to 125 feet wide.
EPA is issuing this Proposed Plan to solicit public comments on the remedy. EPA is proposing
to address the contaminated sediment and soil at the Site. The Proposed Plan is being issued as
part of EPA's public participation requirements under Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended, 42
U.S.C Section 9617, commonly known as Superfund, and Section 300.430 (f)(ii) of the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP). After the close of the public
comment period, EPA will announce its selection of the remedy for the sediment and soil
remediation at the Site in a document called the Record of Decisi on (ROD). The public's
comments will be considered and incorporated into the ROD as part of the Responsiveness
Summary. EPA encourages the public to review the documents that make up the Administrative
Record to gain a more comprehensive understanding of the Site and the Superfund activities that
have been conducted at the Site.
The Administrative Record for the Site can be found at the following locations:
Forest Home Library United Community Center EPA Region 5
1432 West Forest Home Ave 1028 S 9th St. Record Center, room 711
Milwaukee, WI 53204 -3228 Milwaukee, WI 53204 77 West Jackson Boulevard
Phone: (414) 286-3083 Phone: (414) 384-3100 Chicago, JL 60604
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The alternatives that EPA evaluated include the following:
• Soil Alternative 1 - No Action
• Soil Alternative 2 - ICs, pavement, and engineered cover
• Soil Alternative 3a - ICs, pavement, and soil cover
• Soil Alternative 3b - 1C, pavement, limited excavation, backfill, and soil cover
• Soil Alternative 4 - ICs, pavement, excavation of unsaturated soil, backfill, and soil
cover
• Sediment Alternative 1 - No Action
• Sediment Alternative 2a - West End Dredge and 6-inch Sand Cover with ICs
• Sediment Alternative 2b - West End Dredge and 12-inch Sand Cover with ICs
• Sediment Alternative 3 - Full Dredge and Sand Cover
The preferred remedy discussed in the Proposed Plan will address contamination in the soil and
sediment. The goals of the preferred remedy are to: (1) minimize exposure of sediment
dwelling organisms to contaminants; (2) minimize the potential human exposure to contaminants
from the soil; and (3) mitigate the potential for contaminants to move from upland soil to the
canal sediments. EPA's preferred remedy to meet these goals is identified in the Proposed Plan
and includes Alternative 4 for the soil and Alternative 2b for the sediment. The preferred
remedy includes the following components:
• In the paved area, rely on the existing pavement to minimize infiltration and prevent
direct contact to the contaminated soil beneath.
• Excavate and dispose off-site contaminated soil down to the water table in the unpaved
area. The area will be backfilled with clean soil, vegetation, and rip-rap. The area
around soil boring (SB) 1 will only be excavated to one foot because COCs do not
exceed screening levels beyond that depth.
• Dredge and dispose off-site about 200 cubic yards of highly contaminated sediment at
the west end of the canal.
• Place a 12-inch thick sand cover over the contaminated sediments in the canal up to the
11th Street Bridge. Surround the sewer outfalls with geotextile fabric and rip-rap.
• Implement Institutional Controls (ICs), including zoning restrictions, deed restrictions,
and the use offences and signs to preserve the integrity of the remedy.
The proposed remedy would be the final remedy for the soil and sediments at the Site. EPA has
determined that preferred remedy will effectively address the contaminated soil and sediment.
EPA is issuing this Proposed Plan to solicit comments on the preferred remedy for the
remediation of contaminated soil and sediment at the Burnham Canal Site. EPA will select the
remedy for the Site after the public comment period has ended and comments received during
the comment period have been reviewed and considered. Comments should be submitted in
writing or emailed to:
Nefertiti Simmons (SR -6J)
Remedial Project Manager
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Region 5 EPA
77 West Jackson Blvd
Chicago, IL 60406
simmons.nefertiti@epa.gov
Or
Heriberto Leon (SI-7J)
Community Involvement Coordinator
Region 5 EPA
77 West Jackson Blvd
Chicago, IL 60406
leon.heriberto@epa.gov
The Proposed Plan includes the following sections:
• Site Background - Presents facts about the Site which provide the context for the
subsequent sections of the Proposed Plan;
• Site Characteristics - Describes the nature and extent of contamination at the Site;
• Scope and Role - Describes how the response action fits into the overall Site
strategy;
• Summary of Site Risks - Summarizes the results of the screening level risk
assessment;
• Remedial Action Objectives - Describes what the proposed Site cleanup is expected
to accomplish;
• Summary of Alternatives - Describes the options for attaining the identified
remedial action objectives;
• Evaluation of Alternatives - Explains the rationale for selection of the Preferred
Alternative;
• Preferred Remedy - Describes the preferred remedy and affirms that it is expected
to fulfill statutory and regulatory requirement; and
• Community Participation - Provides information on how the public can provide
input to the remedy.
I. SITE BACKGROUND
Site Location and Description
The Site consists of Miller Compressing Company's (Miller's) former wire reclamation furnace
area and a portion of the canal from the western terminus to the federal navigation channel
located at the 11th Street Bridge. The Site is located in Township 7 North, Range 22 East,
Sections 31 and 32. The canal is located east and south of the Miller's metal recycling facility.
Land adjacent to and north of the canal are owned by Miller and are currently used for trailer and
container storage. The south part of the canal is partially owned by Miller; other portions of the
south bank are occupied by a foundry and an automobile junk yard.
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The Site extends approximately 1,500 feet from its west end to the 11th Street Bridge and ranges
from 95 to 125 feet wide. Water depths for the Site generally range from 11 to 15 feet deep; in
some areas it is up to 17 feet deep (with the exception of the west end which is very shallow).
The canal banks, with the exception of the west end, are generally reinforced with seawall made
from steel, concrete, or wood timbers. In addition to the seawalls, there are three large combined
sewer outfalls located along the canal. Approximately 20 to 25 feet wide, the west end of the
canal is covered with rock and rip-rap with patches of exposed soil, weeds, and brush.
Figure 1. Site Location
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Site History
Historically, the Burnham Canal was constructed to provide river access to numerous industries
located in the southern portion of the Menomonee River Valley. The Burnham Canal was a
federally authorized navigation channel dredged and maintained by the United States Army
Corps of Engineers (USAGE). In the mid 1980s, a street-level fixed bridge was constructed
across the canal at 11th Street, blocking large ship traffic from moving upstream. Due to the low
clearance provided by the 11th Street Bridge, navigation in the west end of the canal is limited to
small water craft (e.g. canoes, fishing boats, etc.). The canal is still a federally authorized
navigation channel to the 11th Street Bridge, but has not been dredged since the fall of 1987.
From the early 1970s through the mid 1980s, Miller operated a wire reclamation furnace
between 75 to 100 feet west of the terminus (west end) of Burnham Canal for copper wire
recycling. Operation of this furnace ceased in 1986 or 1987. The furnace is likely the source of
the high copper and polycyclic aromatic hydrocarbons (PAH) concentrations detected in canal
sediment. Other historic Miller operations in the area included non-ferrous recycling operations
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and shearing and baling activities. The shearing and baling activities were discontinued and non-
ferrous operations were consolidated to other areas of Miller Compressing property.
Historic land uses in the immediate area surrounding the canal included the Barnett Woolen
Mills, that was once located on Miller's property; Advanced Chemical; the Gebhardt Vogel and
Blackhawk tanneries; lumber operations; a building materials company; a smelting company; a
foundry; a meat packing company; a grease company; and three cement companies. Remnant
structures of some of these operating facilities remain along portions of the canal.
Previous Environmental Investigations
On May 30, 2008, Miller Compressing Company entered into an Administrative Settlement
Agreement and Order on Consent (AOC) to conduct an RI and FS for the Burnham Canal Site.
From 2006 to 2008, prior to entering this AOC, Miller conducted an investigation of the Site soil
and sediment. Shortly after the signing of the AOC, Miller submitted a report to EPA called the
"Completion Report" (CR). This report summarized all the environmental data available for this
Site, including data collected as early as 1986. The CR focuses on data collected in 2006
through 2008 because previous data, while qualitatively helpful, did not have the Quality
Assurance/Quality Control (QA/QC) documentation needed to be used in decision making.
In July 2009, Miller collected an additional eight soil samples from the paved and unpaved areas
west of the canal to verify the breadth and depth of the soil contamination. The data collected
from this event, along with the data collected from 2006 through 2008, were compiled into the
RI report for the Site. Miller completed the RI report in December 2010. Information on the
nature and extent of the contamination is presented in Section II of this document.
II. SITE CHARACTERISTICS
Remedial Investigation and Feasibility Study
The FS is based on sampling data presented in the RI report for the Site; the FS was completed in
May 2011. The RI and FS reports identified the types, quantities and locations of contaminants
at the Burnham Canal Site and developed ways to address the contamination problems. The RI
concluded that:
• The contaminants of concern (COCs) for the Site are copper, lead, and polycyclic
aromatic hydrocarbons (PAHs).
• Sediment contamination is highest at the west end of the canal and decreases toward
the 11th Street Bridge. The concentrations of lead and PAHs tend to increase with
depth, while copper concentrations are highest in surface sediments and decrease with
depth.
• Copper, lead and PAHs sediment contamination exceeds the screening values, called
Probable Effect Concentrations (PECs), throughout the canal. The PECs are 150
parts per million (ppm) for copper, 130 ppm for lead, and 22.8 ppm for total PAHs.
• The highest levels of each COC in the sediment are: copper, 14,100 ppm; lead, 1,680
ppm; and total PAHs, 1,292 ppm.
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• Surface water samples were taken and compared to Wisconsin Code NR 105 Water
Quality Criteria. The results indicate no human health or environment concerns for
the Site based on exposure to COCs in the surface water.
• Contaminated soil at the west end of the canal serves as the primary source of
contamination to the canal. The COC concentrations exceed the screening levels for
industrial soil in the paved and unpaved areas of the western terminus.
• The highest concentration of copper in the soil is 35,400 ppm (unpaved soil). The
highest concentration of lead in the soil is 32,300 ppm (paved soil). The highest
concentration of PAHs is 269 ppm and is located in the unpaved soil.
III. SCOPE AND ROLE OF THIS ACTION
The remedy presented in this Proposed Plan addresses the soil at the west end of the canal in the
paved and unpaved areas, and the sediment in the Burnham Canal up to the 11th Street Bridge.
EPA expects that remediation of the west end soil and the canal sediment will minimize
exposure of contaminated sediments to benthic organisms, minimize contaminated soil exposure
via ingestion and dermal contact to trespassers and on-site workers, and prevent contaminated
soil from contributing more contamination to the sediment.
IV. SUMMARY OF SITE RISKS
As part of the 2010 RI, Miller conducted a screening level risk assessment (SLRA) for both Site
soil and sediment. An SLRA evaluates risk by comparing risk-based screening levels to
contaminant concentrations. The unacceptable risks identified at the Burnham Canal Site are
based on contaminant concentrations in sediment and soil above risk-based screening levels.
Regional Screening Levels (RSLs) for industrial soil were compared to the concentrations of
metals and PAHs found in the soil at the west end and soil under the paved portion of the Site.
Soil at the west end is not paved, but it is fenced to prevent direct contact human exposures.
Screening levels for copper, lead and PAHs were exceeded in the west end soil. The
contaminated soil, therefore, was identified as: (1) a future direct contact threat to industrial
workers and trespassers in the area; (2) an unacceptable source to sediment contamination via
erosion; and (3) a potential source of contamination to sediments via ground water.
Contaminated soil at other areas of the Site is covered with asphalt or concrete to prevent current
human exposures and further potential transport of contamination to the ground water.
Site-related ground water contamination may have adversely impacted the sediment. Ground
water investigations were not conducted during the RI, however, because of the Site's industrial
setting and the inability to distinguish Site-related ground water contamination from other
ground water contamination sources in the immediate area. As such, it is not known, to what
extent the ground water may be contaminated from Site releases. Therefore, potential ground
water contamination is being addressed with a conservative approach. An existing source of
potential ground water contamination from Site activities (exposed contaminated soil) is being
removed in order to prevent potential additional Site-related contaminant sources migrating to
the ground water, and thus sediments. It is not known whether the existing contaminated soil
below the pavement (added after the copper reclamation ceased) is in contact with ground water.
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The Wisconsin Department of Health Services (WDHS) conducted a Site visit in January 2009
and reviewed the existing data for the Site in the Completion Report. WDHS issued a Health
Consultation for the Burnham Canal Site on September 28, 2009. WDHS determined that the
primary exposure pathway via soil is to site workers, and the secondary pathways are to
recreational adolescent trespassers and the sport fish angler. Eating fish from the Milwaukee,
Menomonee, and Kinnickinnic Rivers (including the canal) could harm human health due to the
levels of PCBs in the fish; however PCB contamination is not Site-related. The levels of metals
and PAHs found in the sediment and water are not likely to harm public health because direct
contact is not occurring and the canal is not a source of drinking water. The levels of metals and
PAHs from unpaved soil do not currently harm public health because the unpaved soil is fenced
and human exposures are currently not occurring. Contaminated soil on the rest of the Site is not
a direct contact threat because it is covered with concrete or asphalt.
State of Wisconsin PECs were used to evaluate the risk from contaminated sediments at the Site.
Sediment concentrations for copper, lead, and PAHs exceed PECs throughout the canal. The
PRP conducted Acid Volatile Sulfides - Simultaneously Extracted Metals (AVS-SEM) analyses
for the metals to determine if the contaminants in the sediment were bio-available. Although the
results indicate that the benthic organisms may not uptake significant levels of contamination,
the AVS-SEM analysis is not conclusive because site-specific toxicity tests needed to verify the
results of the analysis were not conducted. The screening level eco-risk assessment numbers
were exceeded; therefore remedial action is determined to be needed given the absence of a site-
specific risk assessment.
V. REMEDIAL ACTION OBJECTIVES
To protect the public and the environment from current and future health risks, the following
Remedial Action Objectives (RAOs) have been developed to address the contaminated soil and
sediment at the Site:
• Minimize exposure of benthic organisms to COCs in sediments in the biologically
active zone.
• Minimize potential for dermal contact and incidental ingestion of surface soil.
• Mitigate potential for erosion and contaminant transport from the upland soil and
into the canal via ground water.
VI. SUMMARY OF REMEDIAL ALTERNATIVES
The remedial alternatives for the Site are presented below. The alternatives are numbered to
correspond with the alternatives in the FS.
Common Elements
All of the soil alternatives rely on the existing paved asphalt and concrete cover to prevent
exposures with contaminated soil that is underneath. All of the alternatives require Institutional
Controls and five-year reviews. Five-year reviews are required at all Superfund sites where
contamination that does not allow for unlimited use and unrestricted exposure is left in place.
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Soil Alternatives
Alternative 1
Alternative 2
Alternative 3 a
Alternative 3b
Alternative 4
Paved
Area
No Action
Institutional
Controls,
Pavement
Institutional
Controls,
Pavement
Institutional
Controls,
Pavement
Institutional
Controls,
Pavement
Unpaved
No Action
Engineered
Cover
Soil Cover
Soil Cover and
Excavation
Excavation
and Backfill
Sediment Alternatives
Alternative 1
No Action
Alternative 2a
Institutional
Controls,
West End
Dredge, 6-
inch Sand
Cover
Alternative 2b
Institutional
Controls, West
End Dredge,
12-inch Sand
Cover
Alternative 3
Full Dredge, 6-
inch Sand
Cover
Soil Alternatives
The soil has been divided into two areas: the paved area and the unpaved areas. Each alternative
addresses both areas separately.
Alternative 1 - No Action
Estimated Cost: $0
Estimated Annual O&M Costs: $0
Estimated Present Worth: $0
Estimated Time to Completion: Not Applicable
This alternative is developed and retained as a baseline scenario that the other alternatives are
compared. Under this alternative EPA would take no action at the Site to prevent exposure to
soil contamination.
Alternative 2 - Engineered Cover
Estimated Capital Cost: $216,950
Estimated O&M Costs (30 years): $65,300
Estimated Present Worth: $282,000
Estimated Time to Completion: 1 month
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 meets the
requirements for an engineered cover and would not require additional thickness, although it
would require inspections and need to be maintained in the future. In addition, ICs will be
implemented to ensure that the land is restricted to industrial or commercial use and the existing
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cover remains in place. An Institutional Control Implementation Plan (ICIP) for the sediment
and soil will be developed during the design. This component is a part of all the soil remedies.
Unpaved Soil
This alternative consists of placing a geosynthetic clay liner (GCL) cover in the unpaved area to
serve as an engineered barrier and as an alternative to a soil cover. This alternative would
include removing the top six inches of material along with the excavation of an anchor trench to
install the GCL. A six inch layer of imported clean material would be placed over the GCL,
compacted and graded to protect the integrity of the GCL. To complete the installation, the
unpaved area will be covered with a six inch layer of top soil and seeded, along with rip-rap at
the soil/water interface to prevent future erosion.
Alternative 3a - Soil Cover
Estimated Capital Cost: $214,050
Estimated O&MCosts (30 years): $65,300
Estimated Present Worth: $279,000
Estimated Time to Completion: 1 month
Unpaved Soil
This alternative includes the placement of a two 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 will 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 will be covered with a six inch layer of top
soil and seeded along with rip rap at the soil/water interface to prevent future erosion.
Alternative 3b - Soil Excavation to 2 feet and Soil cover
Estimated Capital Cost: $233,350
Estimated O&M Costs (30 years): $65,300
Estimated Present Worth: $299,000
Estimated Time to Completion: 1 month
Unpaved Soil
Same as Alternative 3a, except the excavation depth is two feet instead of six inches; and the
resulting surface grades and finished slope will be similar to the existing conditions.
Alternative 4 - Excavate Contaminated Soil to the Water Table (about 7 feet deep) and
Backfill
Estimated Capital Cost: $2 79,300
Estimated O&M Costs (30 years): $65,300
Estimated Present Worth: $345,000
Estimated Time to Completion: 1.5 months
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Unpaved Soil
This alternative includes the excavation of soil down to the water table in the unpaved area to
accomplish greater contaminant mass removal in close proximity to the canal and mitigate future
transport of soil contamination to canal sediments via ground water. The excavation will consist
of a seven foot cut (sloped as required for stability) on the west side of the unpaved area east to
the soil/water interface. The area around soil boring (SB) 1 will only be excavated to one foot
because COCs do not exceed screening levels beyond that depth. Excavated soil will be
disposed of off-site, and the area will be reconstructed with clean backfill. Backfill will be
placed, compacted and graded to maintain a natural slope to the canal. To complete the cover,
the unpaved area will be covered with a six-inch layer of top soil and seeded, along with rip rap
at the soil/water interface to prevent future erosion.
Sediment Alternatives
Alternative 1 - No Action
Estimated Capital Cost: $0
Estimated O&MCosts (30 years): $0
Estimated Present Worth: $0
Estimated Time to Completion: Not Applicable
This alternative is developed and retained as a baseline scenario to which the other alternatives
may be compared. Under this alternative EPA would take no action at the Site to prevent
exposure to sediment contamination.
Alternative 2a - West End Dredge and 6-Inch Sand Cover
Estimated Capital Cost: $1,202,550
Estimated O&M Costs (30 years): $129,500
Estimated Present Worth: $1,332,000
Estimated Time to Completion: 3 months
This alternative includes dredging about 200 cubic yards of sediment from the west end of the
canal that 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 alternative also includes placing a six inch sand cover over the canal up to the 11th Street
Bridge and placing geotextile fabric and armor stone over the sand layer around the combined
sewer outfalls. The sand cover will be evenly distributed over the entire sediment area of
concern. Prior to sand cover placement an easement or equivalent approval mechanism will be
obtained from the landowners along the south boundary of the canal. This cover will separate
the underlying contaminated sediments; reduce the potential exposure to the benthic community;
and minimize the ability for organisms to burrow into contaminated sediments beneath the cover.
In addition, ICs will be implemented to ensure that the sand cover remains in place and is not
disturbed. An ICIP for the sediment and soil will be developed during the design.
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Alternative 2b - West End Dredge and 12-Inch Sand Cover
Estimated Capital Cost: $1,844,350
Estimated O&MCosts (30years): $129,500
Estimated Present Worth: $1,974,000
Estimated Time to Completion: 4 months
This alternative is the same as Alternative 2 a, except the thickness of the sand cover for
Alternative 2b will be 12 inches instead of six inches.
Alternative 3 - Full Dredge and 6-Inch Sand Cover
Estimated Capital Cost: $22,265,100
Estimated O&M Costs (30 years): $129,500
Estimated Present Worth: $22,395,000
Estimated Time to Completion: 12 months
This alternative assumes the dredging target would be about a 22-foot dredge depth at the west
end and a 15 foot dredge depth as the east end near the 11th St. Bridge. The amount of material
to be dredged for this alternative is about 60,000 cubic yards of sediment. This alternative will
require significant structural support of surrounding seawalls. For purposes of estimating the
cost, it is assumed that permanent sheet piling with tie backs will be required along 50% 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 will be necessary at the west
end of the canal to create a stable slope, as well as rip-rap at the face for shoreline erosion
protection.
After the dredging is complete a six inch sand cover will be placed over the sediment to create a
clean biologically active zone. This is necessary because the dredging would remove the benthic
environment and natural sedimentation processes would not be able to restore it in a reasonable
time frame. This sand cover will be similar to the six inch sand cover presented in Alternative 2a.
VII. EVALUATION OF ALTERNATIVES
Nine criteria are used to evaluate the different remediation alternatives individually and against
each other in order to identify a preferred remedy. The nine criteria are discussed below. More
description of the alternatives relative to the nine criteria and a more robust comparative analysis
of the alternatives can be found in the Detailed Analysis of Alternatives section of the FS.
EVALUATION CRITERIA FOR SUPERFUND REMEDIAL ALTERNATIVES
1. Overall Protection of Human Health and the Environment determines whether an
alternative eliminates, reduces, or controls threats to human health and the
environment through institutional controls, engineering controls, or treatment.
2. Compliance with ARARs evaluates whether the alternative meets federal and state
environmental statutes, regulations, and other requirements that pertain to the site; or
whether a waiver is justified.
3. Long-term Effectiveness and Permanence considers the ability of an alternative to
maintain protection of human health and the environment over time.
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4. Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment
evaluates an alternative's use of treatment to reduce the harmful effects of principal
contaminants, their ability to move in the environment, and the amount of
contamination present.
5. Short-term Effectiveness considers the length of time needed to implement an
alternative and the risks the alternative poses to workers, residents, and the
environment during implementation.
6. Implementability considers the technical and administrative feasibility of
implementing the alternative, including factors such as the relative availability of
goods and services.
7. Cost includes estimated capital and annual operations and maintenance costs, as well
as present worth cost. Present worth cost is the total of an alternative over time in
today's dollar value. Cost estimates are expected to be accurate within a range of
+50% to-30%.
8. State Acceptance considers whether the State agrees with EPA's analyses and
recommendations, as described in the RI/FS and the Proposed Plan.
9. Community Acceptance considers whether the local community agrees with EPA's
analyses and preferred remedy. Comments received on the Proposed Plan are an
important indicator of community acceptance.
DETAILED ANALYSIS OF THE PROPOSED REMEDIAL ALTERNATIVES
1. Overall Protection of Human Health and the Environment
The Alternative 1 for soil and sediment is not protective of human health and the environment
compared to other alternatives; therefore, it will not be evaluated further.
Soil Alternatives: Alternatives 2, 3a, 3b, and 4 are all protective of human health and the
environment for both current and reasonably foreseeable future use in both paved and unpaved
areas.
Sediment Alternatives: All of the alternatives, except for Alternative 1, are protective of human
health and the environment.
2. Compliance with ARARs
All the alternatives, both soil and sediment, comply with ARARs. There are many ARARs for
the proposed alternatives. The proposed plan only highlights the key laws that must be complied
with during the remedial action. A more detailed listing of the ARARs will be provided in the
ROD. The key ARARs that are associated with this remedy include: the Clean Water Act, the
Resource Conservation and Recovery Act, the Clean Air Act, Wisconsin Administrative Code
(WAC), and the Wisconsin statutes.
The key To Be Considered (TBC) associated with this remedy is the WAC chapters NR 105 to
106 - Consensus Based Sediment Quality Guidelines, Interim Guidance published in December
2003. U.S. EPA has selected the sediment risk based screening level (PEC).
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3. Long-Term Effectiveness and Permanence
Soil Alternatives: Alternative 4 is the most long-term effective and permanent soil alternative,
as it removes all contaminated soil down to the water table in the unpaved area. Alternatives 3b
and 3a remove some contaminated soil in the unpaved area, and are less long-term effective and
permanent than Alternative 4, but more so than Alternative 2 which provides for no excavation
of soil in the unpaved area. All alternatives are comparable regarding long-term effectiveness
and permanence for the paved area, as maintenance of the existing asphalt or concrete cover is a
part of all of the soil alternatives.
Sediment: Alternative 3 (full dredge) is the most effective and permanent. The capping
Alternatives (2a and 2b) provide long-term effectiveness through use of ICs combined with the
use of a sand cover. Alternative 2b offers greater permanence when compared to Alternative 2a
because it is twice as thick. There is some concern that the six-inch cover in Alternative 2a
would not be effective over the long-term.
4. Reduction of Toxicity, Mobility, or Volume through Treatment
None of the alternatives use treatment to reduce toxicity, mobility or volume. An in-situ
treatment option (solidification) was evaluated as a process option for the contaminated soil. It
was screened out because of the limited space available to implement the remedy. There are no
viable treatment options for this type of sediment contamination.
5. Short-Term Effectiveness
Soil: All of the soil alternatives have manageable short-term effectiveness impacts. Alternative 4
will be most disruptive because it requires a deeper excavation and a longer implementation
time. Alternatives 3a and 3b have less short-term impacts than Alternative 4; but more short-
term impacts than Alternative 2, which has no off-site soil disposal.
Sediment: All the sediment alternatives adversely impact the benthic community in the short-
term because of cover placement and/or removal of sediment. Alternative 3 has significantly
greater short-term impacts to the surrounding local community and the benthic community
because of the longer duration and high volume of sediment removal. Alternatives 2a and 2b
have the less adverse short-term impacts than Alternative 3, due to the smaller volume of
sediment targeted for dredging.
6. Implementability
Soil: All of the soil alternatives are reasonably easy to implement, with moderate disruption to
business operations. Alternative 4 is the most difficult to implement of the soil alternatives
because of the excavation would occur in a small area. The excavation would require the
creation of safe slopes, and there is limited access to the canal bank.
Sediment: Alternatives 2a and 2b are comparable in terms of ease of implementation; and are
readily implementable. Alternative 3 is the most difficult to implement and may not be feasible
in areas where building structures are in close proximity to the canal and the shoreline cannot be
stabilized. Shoring will be required to stabilize the seawalls during dredging and an engineering
evaluation would be required to assess seawall stability.
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7. Cost
The table below shows the costs for each alternative.
Soil: The present worth costs for the soil alternative do not vary significantly from one another.
Alternative 3a costs the least ($279,000) and Alternative 4 costs the most ($345,000).
Sediment: The present worth costs for the sediment alternatives vary appreciably. Alternative 3
is the most expensive Alternative at $22,395,000, more than ten times the cost of the other
alternatives. Alternative 2a and 2b both include a sand cover with west end dredging, but
Alternative 2b is $642,000 more expensive (approximately 30% more) because the sand cover is
twice as thick as the sand cover proposed in Alternative 2a.
Remedial Alternatives Cost Comparison Table
Alternative
Soil 1 - No Action
Soil 2 - ICs, Pavement, GCL
Soil 3a - ICs, Pavement, Soil Cover
Soil 3b - ICs, Pavement, Excavation and Soil Cover
Soil 4 - ICs, Pavement, Excavation and Backfill
Cost
$0
$282,000
$279,000
$299,000
$345,000
Alternative
Sediment 1 - No Action
Sediment 2a - ICs 6-in sand cover, west end dredge
Sediment 2b - ICs 12-in sand cover, west end dredge
Sediment 3 - Full Dredge, 6-in sand cover
$0
$1,332,000
$1,974,000
$22,395,000
8. State Acceptance
The State of Wisconsin has expressed support for EPA's preferred alternative. State acceptance
of the preferred remedy will be fully evaluated after the public comment period ends.
9. Community Acceptance
Community acceptance of the preferred remedy will be evaluated after the public comment
period ends. EPA's response to public comments received will be available in the
Responsiveness Summary of the ROD.
VIII. EPA'S PREFERRED ALTERNATIVE
EPA's preferred remedy is Alternative 4 for the soil and Alternative 2b for the sediment, as
further described below. The preferred remedy consists of: (1) excavation of unpaved,
unsaturated contaminated soil at the west end of the Site; (2) backfill and vegetative cover of
excavated area; (3) maintenance of the paved areas of the Site; (4) dredging and off-site disposal
of approximately 200 cubic yards of the most contaminated soil on the west end of the canal; (5)
installation of a 12-inch sand cover over the canal up to the 11th Street Bridge; (6) placement of
armor stone at the storm water outfalls; and (7) implementation of Institutional Controls to
preserve the integrity of the remedy.
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Soil Alternatives: All soil alternatives, except the "No Action" Alternative are protective and
meet ARARs; and none of the soil alternatives employ treatment to reduce toxicity, mobility or
volume of hazardous substances. All alternatives are readily implementable and have
manageable short-term impacts; and there is not a significant cost difference among the
protective alternatives. Therefore, Alternative 4 is the preferred soil alternative because it
provides the greatest long-term effectiveness and it significantly mitigates the potential
contaminant transport from the upland soil into the canal sediment via erosion and contaminant
transport to canal sediment via ground water from the contaminated soils.
Sediment Alternatives: All sediment alternatives, except the "No Action" Alternative, are
protective of human health and the environment and meet ARARs; and none of the sediment
alternatives employ treatment to reduce toxicity, mobility or volume of hazardous substances.
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 six inch
cover of Alternative 2a because it is more permanent and better able to withstand sediment
disturbance. A 12 inch cover is recommended by EPA sediment guidance (See ERDC TN-
DOER-C21, August 2001, Guidance for In-Situ Subaqueous Capping of Contaminated
Sediments, Chapter 3). The full dredge option, Alternative 3, is very disruptive in the short-term.
It costs over ten times more than Alternatives 2a and 2b, without providing significantly greater
effectiveness. Therefore Alternative 2b is the EPA's preferred sediment remedial alternative.
EPA's preferred alternatives are protective and comply with ARARs. They use treatment to the
maximum extent practicable, and are cost-effective.
IX. COMMUNITY PARTICIPATION
EPA relies on public input so that the remedy selected for each Superfund site meets the needs
and concerns of the local community.
The public comment period ensures that the community's concerns are being addressed, a public
comments period will open on June 15, 2011 and close July 15, 2011. During this time the
public is encouraged to submit comments on the Proposed Plan to EPA.
A public meeting will be held to discuss the Proposed Plan on June 28, 2011 from 6:00 p.m. To
7:30 p.m. The public meeting will be held at the United Community Center, 1028 South 9th
Street, Milwaukee, WI 53204.
It is important to note that although EPA has proposed a preferred remedy, the remedy has not
yet been selected for the Site. All relevant comments received will be considered and addressed
by EPA before the remedy is selected. The cleanup plan could differ from information in this
proposed plan, depending on information or comments EPA receives during the public comment
period.
Detailed information on the material discussed in this document may be found in the
Administrative Record for the Site. These materials include the Completion Report, the RI, the
FS and other information used by EPA in the decision making process. EPA encourages the
public to review the Administrative Record in order to gain a more comprehensive understanding
of the Site and the Superfund activities that have taken place there. Copies of the Administrative
Record are available at the following locations:
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Forest Home Library United Community Center EPA Region 5
1432 West Forest Home Ave 1028 S 9th St. Record Center, room 711
Milwaukee, WI 53204 -3228 Milwaukee, WI 53204 77 West Jackson Boulevard
Phone: (414) 286-3083 Phone: (414) 384-3100 Chicago, IL 60604
Monday - Friday 8 am - 4 pm
Written comments, questions about the Proposed Plan or public meeting, and requests for
information can be sent to either representative below:
Nefertiti Simmons (SR -6J)
Remedial Project Manager
Region 5 EPA
77 West Jackson Blvd
Chicago, IL 60406
simmons.nefertiti@epa.gov
or
Heriberto Leon (SI-7J)
Community Involvement Coordinator
Region 5 EPA
77 West Jackson Blvd
Chicago, IL 60406
leon.heriberto@epa.gov
Following the conclusion of the public comment period on the Proposed Plan, a Responsiveness
Summary will be prepared. The Responsiveness Summary will summarize and respond to
comments on EPA's Preferred Alternative. EPA will then prepare a formal decision document,
the Record of Decision (ROD), that summarizes the decision process and the alternative selected
for the Burnham Canal Site. The ROD will include the Responsiveness Summary. Copies of the
ROD will be available for public review in the information repositories, as describes above.
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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
Soil Alternatives
1
n
n
n
°
•
•
•
2
•
•
D
D
•
•
3a
•
•
D
D
•
•
3b
•
•
D
~ D
•
•
4
•
•
•
— n
•
•
These evaluation criteria 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 Alternatives
1
n
n
D
D
•
•
•
2a
•
•
D
D
D
•
•
2b
•
•
•
°
D
•
•
o
•
•
•
D
D
n
n
These evaluation criteria will be evaluated after the public
comment period.
• Fully meets criteria Q Partially meets criteria D Does not meet criteria
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