U.S. EPA Superfund Program ^to sr/) •^ • Proposed Plan for the Soil and Sediment • | 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 ------- 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 ------- 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. ------- 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 • WPn 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 ------- 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. ------- • 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. ------- 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. ------- 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 ------- 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 ------- 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. 10 ------- 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. 11 ------- 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). 12 ------- 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. 13 ------- 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. 14 ------- 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: 15 ------- 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. 16 ------- 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 17 ------- |