-wEPA

United States
Environmental Protection
Agency

For more information

If you are interested in the Cedar
Creek Mercury Marine Plant 2
site cleanup, please attend a public
meeting at 7 p.m., Wednesday,
Oct. 10, 2007, at the Cedarburg City
Hall, Council Chambers, W63 N645
Washington Ave.

Comments on the proposed plan
should be submitted from Oct. 8 to
Nov. 9:

•	Orally or in writing at the public
meeting

•	Electronically via the Internet at
epa.gov/region5/publiccomment/
cedarcreek-pubcomment .htm

•	Fax to Susan Pastor at
312-353-1155

Contact EPA

Susan Pastor

EPA Community Involvement
Coordinator
312-353-1325
pastor.susan@epa.gov

Scott Hansen

EPA Remedial Project Manager

312-886-1999

hansen. scott@epa.gov

EPA Region 5 toll-free:

800-621-8431,

weekdays 9 a.m. - 4:30 p.m.

Contact WDNR

Margaret Brunette
State Project Manager
414-263-8557

margaret .brunette@wisconsin .gov

EPA Proposes Cleanup Plan for
Former Cedar Creek Plant 2 Site

Cedar Creek

Cedarburg, Wisconsin	October 2007

Cautionary sign at Cedar Creek Plant 2 site entrance

To clean up PCB contamination at the Cedar Creek Mercury Marine Plant 2
site, U.S. Environmental Protection Agency Region 5 is proposing to remove
soil from targeted areas containing PCB concentrations above established
safety levels, remove the plant's concrete slab to the extent necessary for
excavations or redevelopment, and replace excavated areas with clean soil
The cleanup goal is to prevent human exposure to harmful levels of PCBs,
which is short for polychlorinated biphenyls and VOCs, or volatile organic
compounds. PCBs were commonly used in manufacturing as a coolant and
lubricant but often spilled or leaked from machines and soaked into the soil of
industrial sites. The safety level for PCBs in soil is set at 50 parts per million.
A part per million is a tiny amount, similar to one second in 12 days. Soil that
will not be covered will be removed to a level of 1 ppm. Soil that will remain
covered with a concrete-like material will be removed to 50 ppm.

The safety level for the main VOC of concern (tetrachloroethene, or PCE),
is .5 parts per billion. This is equal to one second in 32 years.

The purpose of this proposed plan is to provide background information
about the Cedar Creek site, describe the various cleanup options considered,
and identify EPAs recommended cleanup alternative.1 The public is

1 Section 117(a) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA blown as the Super/and law) requires publication of a notice
and a proposed plan for the site remediation. The proposed plan must also be made
available to the public for comment. This proposed plan fact sheet is a summary of more
detailed information contained in the remedial investigation, feasibility study, and other
documents in the administrative record for the Cedar Creek Plant. 2 site. Please consult
those documents for more detailed infonnation.


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Former Cedar Creek Mercury Marine Plant 2 site map

encouraged to comment on this proposed plan. EPA will
be accepting comments from Oct. 8 to Nov. 9. See the
box on Page 1 for ways to provide comments to EPA. You
also can attend and participate in a public meeting at the
Cedarburg City Hall on Wednesday, Oct. 10.

EPA along with its state partner Wisconsin Department
of Natural Resources will select a final cleanup plan for
the Cedar Creek Plant 2 site. This will occur after review
and consideration of information provided by the public
during the comment period and public hearing. The final
cleanup proposal, which will be announced with a local
newspaper notice and presented in an EPA document
called a record of decision, could differ from this proposed
plan depending on information or comments EPA receives
during the public comment period.

The public also is encouraged to review the supporting
documents for the Cedar Creek site at the Cedarburg

City Hall and Public Library. The information
includes documents called the remedial investigation
and feasibility study and the site-wide human health
assessment report, found in the remedial investigation.
The remedial investigation studies the nature and extent
of contamination at the site, while the feasibility study
evaluates different cleanup options. The risk assessment
evaluates potential health risks to people and the
environment from contamination at the site.

About the Cedar Creek site

The Cedar Creek site is in a suburban residential area in
southeastern Wisconsin north of Milwaukee in the city
and township of Cedarburg (Ozaukee County) (see map
above). The entire site consists of Mercury Marine's Plant
2, the fonner Amcast facility, and the segment of Cedar
Creek from below the Ruck Pond Dam to the point where
it meets the Milwaukee River. This segment includes open

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Demolition activity at the Cedar Creek Plant 2 site

stretches of creek as well as areas known as Columbia
Pond, Wire and Nail Pond, and the former Hamilton Pond
totaling 5.1 creek miles.

PCBs from two local companies contaminated Cedar
Creek, the Plant 2 property, the former Amcast property
and some private properties near Amcast. One source was
the boat engine manufacturer Mercury Marine. It operated
a plant on St. John Avenue from 1951 to 1982. Fluids
containing PCBs leaked from equipment and were washed
into floor drains. These drains emptied into storm sewers
that ran to Ruck Pond on the creek.

The second source of contamination in the area was
Amcast, a local automotive production facility and
industry supplier on Hamilton Road in Cedarburg. The
company, which closed in 2005, also had a plant that
emptied PCBs into the creek via storm sewers. One of
them emptied into Hamilton Pond, upstream of Green
Bay Road. Due to heavy rains and creek flooding in 1996,
the Hamilton Dam collapsed and was removed. The pond
was drained leaving behind several acres of mud flats
containing PCBs that Mercury Marine removed in 2000.

Until May 2005, much of the Plant 2 site was occupied
by a 66,000-square-foot building. The plant, which began
operations in 1953, was composed of a series of additions
that were constructed over the years. The original building
at the site dated back to the early 1900s and served as a
rail car barn and repair shop, and later in the 1940s as a
canning factory. Mercury Marine acquired the building in
the early 1950s for use as an aluminum die casting and
machining facility.

Summary of site risks

A study of potential risks to public health was done for
the Cedar Creek Plant 2 site. Coming into contact with

PCBs, arsenic-contaminated soil or underlying ground
water (underground supplies of fresh water) and lead-
contaminated soil during routine activities was found to
be the greatest health risk to people. It is also possible for
construction workers digging in the soil to be exposed
to contaminants due to shallow ground water. The study,
called a risk assessment, found the cleanup goals of
50 ppm for PCBs and .5 ppb for PCE will protect people's
health and the environment. EPA is most concerned about
the PCBs.

Cleanup options

EPA considered four options for cleaning up the Cedar
Creek Plant 2 site, each of which was evaluated against
nine criteria required by the Superfund law (see criteria
explanation in the box on Page 4). Options 3 and 4
would require a cover made of heavy plastic to control
water seepage, and both involve shallow soil removal
and ground-water monitoring. The four options are
summarized below.

Option 1 - No further action

EPA includes a "no-action" option as a basis for
comparison with other cleanup options. Since no action
would be taken, this option would increase the potential
for human and animal contact with the contamination.

Cost—$0

Option 2 - Capping with ground-water
monitoring

This option requires that the site fence, concrete slab,
and cap currently covering the site would continue to be
monitored and maintained as a direct contact barrier and
to prevent surface water infiltration. Periodic monitoring
of site ground water would be done to document changes
in concentrations over time.

Cost—$370,000

Option 3 - Remove shallow soil and
monitor ground water

This option assumes the site will be redeveloped and
a majority of Plant 2"s concrete slab will remain in
place. Shallow soil around the slab would be removed
to reduce risk associated with potential direct contact.
Removal areas would be backfilled with clean soil. Soil
would be removed using readily available earthmoving
equipment, such as backhoes, and properly disposed
of at an off-site disposal facility. To reduce the risk to
construction workers and others, the concrete slab would
be removed only to the extent needed to accommodate the

3


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redevelopment of the site, and soil would be excavated
only to the depth necessary for construction. Clean soil
would be backfilled into the excavation areas to reduce
the risk to future construction workers. The rest of the slab
would remain across the site to eliminate direct contact
and minimize surface water infiltration. Deed restrictions
would be implemented to control future uses and to
provide for appropriate cap maintenance.

Cost—$840,000

Option 4 - Remove shallow and subsurface
soil and monitor ground water (EPA's
recommended option)

This option assumes the site will be redeveloped and
removal of the concrete slab might be required to
excavate highly contaminated areas. This option is the
same as Option 3, except excavation would be done
to accommodate redevelopment of the site and in
areas where investigations showed high PCB levels.
The excavation of subsurface soil with elevated PCBs
reduces potential future risk. The concrete slab would be
removed to the extent necessary for targeted excavations
or as needed to accommodate the redevelopment. In the

areas where higher PCB concentrations exist, targeted
excavations would be done. The rest of the slab would
remain across the site to eliminate direct contact and
minimize surface water infiltration. New slab or building
footings would be placed over the excavated areas. Deed
restrictions would be implemented to control future uses
of the site and to provide for appropriate cap maintenance
and ground-water monitoring.

Cost—$2.6 million

How do the options compare?

EPA evaluated the various cleanup options against seven
of the nine criteria required by the Superfund law (see the
comparison chart below) and selected its recommended
option. State and community acceptance will be evaluated
after EPA receives public comments. More information
about the evaluation is in the feasibility study report.

Cleanup goals for the Plant 2 site are to protect people's
health by reducing or eliminating exposure to soil with
high levels of PCBs; preventing exposure to contaminated
ground water; and ensuring that contaminant levels in
ground water are reduced in a reasonable period.

Evaluating the options

EPA uses nine criteria to evaluate and compare cleanup options. See the table on Page 5 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 complies with
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 under construction.

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 in a financial calculation called present worth.

Cost includes capital expenditures such as buildings,
machines, and wells plus operation and maintenance
costs. Present worth cost is the total cost of an option
over time in terms of today's dollar value. 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 WDNR, agrees with EPA's
recommended option. EPA evaluates state acceptance
after it receives public comments on its preferred
option.

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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Next steps

EPA in consultation with WDNR will evaluate public
reaction to the recommended cleanup option during the
comment period before deciding on a final cleanup plan.
Based on new information or public comments, EPA may
modify its recommended option or select another. EPA
encourages you to review and comment on the cleanup
alternatives.

EPA will respond in writing to the comments in a
"responsiveness summary," which will be attached to the
document detailing the final cleanup plan called the record
of decision. EPA will announce the selected cleanup
plan in a local newspaper advertisement and will place
a copy of the record of decision in the local information
repositories and post it on its Web site.

Regarding Cedar Creek, EPA is doing a separate study to
find ways to clean it up. A proposed plan for the creek
that will detail cleanup options should be completed by
fall 2008.

Evaluation Criteria for the Cedar Creek Site

Evaluation Criteria

Option 1

Option 2

Option 3

Option 4*

Overall protection of human health and
the environment

~

¦

¦

¦

Compliance with ARARs

~

¦

¦

¦

Long-term effectiveness and permanence

~

~

~

¦

Reduction of toxicity, mobility, or vol-
ume through treatment

~

~

~

~

Short-term effectiveness

~

¦

~

~

Implementability

¦

¦

¦

¦

Cost

$0

$370,000

$840,000

$2.6 million

State acceptance

Will be evaluated after public comment period

Community acceptance

Will be evaluated after public comment period

¦ Fully meets criteria

G Partially meets criteria

~ Does not meet criteria

*EPA's recommended option

What are PCBs?

PCBs were once widely used by industry as coolants,
insulators and lubricants. The manufacture of PCBs
in the United States was stopped in 1977, but the
compound stays a long time in the environment.

They are linked to cancer, as well as reproductive
and developmental problems in people and animals.
PCB-contaminated river sediment (mud) affects fish,
wildlife and people as it rises through the food chain.
In the 1970s, Wisconsin advised residents not to eat
fish from various rivers throughout the state because
of the contamination. The advisories are still in effect.

What is tetrachloroethene?

Tetrachloroethene is a synthetic chemical that is
widely used for dry cleaning of fabrics and for metal-
degreasing operations. It is also used as a starting
material for making other chemicals and is used in
some consumer products. It has a sharp, sweet odor,
is nonflammable at room temperature and evaporates
easily into the air. Other names for it include
perchloroethylene, PCE, PERC, tetrachloroethylene,
perclene, and perchlor.

5


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Upcoming Public Meeting about
Cedar Creek Plant 2 Cleanup

Wednesday, Oct. 10, 2007
7 p.m.

Cedarburg City Hall, Council Chambers

At the meeting, EPA will explain the proposed plan
and provide opportunities to ask questions and
make oral comments. You may also submit written
comments. If you need special accommodations for the
public meeting, contact Susan Pastor by Oct. 3. Her
contact information is on Page 1.

Site information is also posted on the Internet at:
www.epa.gov/region5/sites/cedarcreek.

Read the documents

Site-related documents and files may be viewed at the
following locations:

Cedarburg City Hall

W63 N645 Washington Ave.

Cedarburg Public Library

W63 N583 Hanover Ave.

An administrative record, which contains detailed
information that will be used in the selection of the
cleanup plan, is also located at the library and at EPA's
Chicago office.


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Comment Sheet

U.S. Environmental Protection Agency is interested in your comments on the proposed cleanup plan for the Cedar Creek
Plant 2 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 Nov. 9. Comments may also be faxed to
Susan Pastor at 312-353-1155. If you have general questions, contact Susan at 312-353-1325, or through EPA's toll-free
number 800-621-8431, 9 a.m. - 4:30 p.m., weekdays. Comments may also be submitted to EPA via the Internet at:
epa.gov/region5/publiccomment/cedarcreek-pubcomment.htm.

Name _
Address

City
Zip.

State


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Fold on Dashed Lines, Tape, Stamp, and Mail

Name	

Address	

City	 State	

Zip	

Susan Pastor

Community Involvement Coordinator
EPA Region 5 (P-19J)

77 W. Jackson Blvd.

Chicago, IL 60604-3590

Place
Stamp
Here


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