U.S. EPA RAP Liaison
U.S. EPA Region 5
77 W. Jackson Blvd. (C-14J)
Chicago, IL 60604
State RAP Contact - Michigan
Michigan Department of Environmental Quality – Water Bureau
State RAP Contact - Wisconsin
Chief, Office of the Great Lakes
WDNR – Bureau of Watershed Management
- AOC Area of Concern
- BUI Beneficial Use Impairment
- CMP/EIS Chemical Management Plan or Environmental Impact Statement
- GLNPO Great Lakes National Program Office
- RAP Remedial Action Plan
- Beneficial Use Impairments
- Delisting Targets
- RAP Development and Status
- Significant RAP Milestones
- RAP Implementation
- RAP-Related Publications
- Community Involvement
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The Menominee River forms the boundary between the northeast corner of Wisconsin and the southern tip of the Upper Peninsula of Michigan. The river's headwaters originate in both states. The main stem of the river flows between the cities of Menominee, Michigan, and Marinette, Wisconsin before emptying into Green Bay.
The Menominee River Area of Concern (AOC) includes the lower three miles (4.8 km) of the river from the Upper Scott Paper Company (Wisconsin) Dam to the river's mouth and approximately 3.1 miles (5 km) north and south of the mouth along the adjacent shoreline of Green Bay. The AOC also includes the cities of Marinette and Menominee, as well as the adjacent nearshore area of Green Bay, Wisconsin, extending three miles north to John Henes Park and south of the river mouth to the point of land known as Seagull Bar. The AOC also includes Green Island.
Land use in the AOC is primarily industrial and residential. A chemical company, two paper mills, two municipal wastewater treatment plants, a ship building company, and a foundry are located along the river. The AOC watershed is shared between Michigan and Wisconsin. The U.S. Environmental Protection Agency is the lead agency working on the Ansul Fire Protection Company site. The Wisconsin DNR is providing support.
Beneficial Use Impairments
- Restrictions on fish and wildlife consumption
- Degradation of fish and wildlife populations
- Beach closings
- Degradation of benthos
- Restriction on dredging activities
- Loss of fish and wildlife habitat
Six of 14 beneficial use impairments have been identified through the Remedial Action Plan (RAP) process. A primary cause of the identified use impairments is arsenic contamination in the turning basin and in sediments along the right bank (downstream direction) of the river below the Ansul Fire Protection Company, an herbicide production facility, in Marinette, Wisconsin. This problem was caused from improper arsenic storage and disposal practices by Ansul from 1957 to 1977. Under recent RCRA corrective action enforcement efforts, sediment and groundwater remediation efforts were implemented in the Eighth Street Slip area.
Other pollutants of concern identified in the AOC included paint sludge and coal tar. Remediation of the paint sludge site was completed in 1995, on the Michigan side. The site was remediated under Act 307 authority. The WPSC Marinette MPG (Manufactured Gas Plant) "Coal Tar Site" is another significant source of contamination. It is currently under remedial investigation by the U.S. EPA Superfund Division. Other pollutants -- such as mercury, polychlorinated biphenyls (PCBs), and oil and grease – have also contributed to use impairments. A fish advisory exists for mercury and PCBs.
The following delisting targets are discussed in the most recent Menominee River AOC RAP document, the 1996 Lower Menominee River Remedial Action Plan Update (PDF 7.83MB, 177pages). The purpose of the plan was to guide restoration, where possible, of the identified impaired uses in the 1990 Stage 1 RAP.
The long-term goals were identified as:
- Protect the aquatic ecosystem of the Menominee River and harbor from the effects of toxic and conventional pollutants.
- Maintain a balanced aquatic and terrestrial community to ensure long term health of the ecosystem
- Maintain and enhance recreational and commercial uses of the Menominee River and Harbor, consistent with the long term maintenance of the natural resource base and a healthy economy.
Objectives for meeting the long-term goals were identified as:
- Evaluate the exposure risks to fish, aquatic life, wildlife, and human health from in-place pollutants (contaminated sediments) to determine the need for remediation.
- Eliminate all toxic effects to fish and aquatic life from industrial and municipal discharges.
- Identify and eliminate all toxic effects to fish and aquatic life from polluted runoff.
- Maintain water quality in the river and bay as drinkable after standard treatment.
- Maintain a balanced and productive fishery that produces fish that everyone can safely eat.
- Improve water and sediment databases to assist in evaluating environmental quality in the AOC.
- Restore, protect, and enhance environmental corridors in the AOC.
- Limit excess nutrients entering the Menominee River and harbor area.
- Promote public attitudes and perceptions of the waterfront as a valuable and aesthetic resource.
- Develop, improve, and maintain shoreline access and recreational facilities for public use and enjoyment.
- Protect wildlife and fish habitat in nearshore and wetland areas.
- Reduce conflicts among different types of users.
- Encourage commercial and industrial developments that build upon and enhance the value of the waterfront.
- Improve the scenic beauty of the river and bay shorelines.
- Remediate sediment contamination to protect human health, fish, aquatic life, and wildlife.
- Eliminate all raw sewage discharges and overflows and other known bacterial problems to meet water quality standards for total and partial body contact (including recreational uses) throughout the AOC.
- Pursue all opportunities to reduce or eliminate all discharges of toxic substances into the AOC, including direct discharges to surface waters, runoff from land surfaces, and air emissions.
RAP Development and Status
The Wisconsin Department of Natural Resources (WDNR) has worked with the Michigan Department of Environmental Quality (MDEQ) to develop and implement the RAP for the Menominee River. The multi-stakeholder Citizens' Advisory Committee (CAC) and a Technical Advisory Committee (TAC) have been instrumental in the development of the RAP by mobilizing public support, increasing awareness, and conducting data and problem analysis. A vision statement for the desired future state of the Lower Menominee River was developed by the CAC and used as guidance in the preparation of RAP goals and objectives that were developed jointly by the CAC and TAC.
Currently, The U.S. Environmental Protection Agency and Wisconsin Department of Natural Resources are working with Ansul Fire Protection Company under the RCRA Corrective Action Program to address arsenic contamination in the AOC.
Significant RAP Milestones
- 1996: The Lower Menominee River RAP Update (PDF 7.83MB, 177pp) was completed.
- 1995: Working Together to Improve and Protect the Great Lakes: A Summary of the Lower Menominee River RAP (PDF 2.70MB, 15pp) was released.
- 1995: Paint sludge removal operations were completed along Green Bay which resulted in the excavation of more than 10 million pounds of hazardous waste from the bay. An additional 20 million pounds of contaminated sediments were removed during this effort, which was part of an enforcement order issued to the Lloyd Flanders Furniture Company in Menominee.
- 1993: A RAP Progress Report (PDF 1.40MB, 11pp) was released.
- 1991: The Stage 1 RAP Report – Lower Menominee River RAP: A Water Quality Restoration and Restoration Plan (PDF 8.94MB, 228pp) was completed.
- 1988: The Menominee River CAC and TAC were established.
Recent progress and achievements
A significant amount of progress has occurred since the RAP process began in 1988. Agreements and programs among government agencies, municipal authorities, and industry have been created to address the use impairments. Presented below is a summary of actions and accomplishments:
- Ansul, Inc. is addressing arsenic contaminated sediments and soil from the river and shore areas in Marinette under a RCRA order.
- CSO (Menominee) and wet weather bypassing (Marinette) have been corrected under the National Pollutant Discharge Elimination System permit process.
- The paint sludge site remediation was completed in 1995 under Michigan's Act 307 authority.
- A navigational dredging project was conducted by the city of Menominee to allow for oceangoing vessels to access the lower part of the Menominee River. Completed in summer 1998, the dredging project partially restored navigation, one of the impaired beneficial uses listed for the AOC. The dredged material was disposed of upland.
- The City of Menominee is conducting sewer renovations and had applied for a loan to fund construction of the final combined sewer overflow elimination project. Construction work is now completed.
- Remediation work on the contaminated paint sludge site located on Lake Michigan just north of the river has been completed. MDNR issued a unilateral order under Act 307 to Flanders Industries (1992) for remedial work at the site that included cleanup of the shoreline, construction of a dike (1993), and excavation of 15 tons of paint sludge from Lake Michigan (1995). Analysis of sampling conducted in 1997 was to be used to determine if ecological problems still existed at the site. If the area was free of problems, the dike was to be dismantled and the site restored in 1997/1998.
- The Menominee River was sampled in 1993-1995 as part of the tributary monitoring portion of the Lake Michigan Mass Balance Modeling project. Results are available for the organic pollutants and metals that were part of the mass balance sampling effort.
- A follow-up survey of sediment toxicity was conducted in the Eight Street slip by WDNR in 1993 and revealed similar results to the 1989 testing (complete mortality of the aquatic test organisms Daphnia magna and significant reductions in growth and weight of the Chironomus tentans). Extremely high concentrations of arsenic were detected in samples of both assessments. Sediment and groundwater remediation efforts were initiated in the late 1990s.
- The City of Marinette purchased land in 1992 along the riverfront near the mouth and along Green Bay as a first step in a cooperative effort with WDNR to install a 1,000 meter recreational walkway along the waterfront from the Menekaunee Bridge to Red Arrow Park. In 1993, the city received a grant from WDNR and a Coastal Management grant to proceed with the development of the scenic walkway. The walkway was completed and provides an environmentally friendly recreational facility for public enjoyment.
- The bulkhead line designation along the river on the Wisconsin side from Sixth Street to the Menekaunee Bridge was removed, allowing this section of the river to remain natural and preventing any more land along the river's edge from being bulkheaded.
- The City of Menominee is in compliance with its National Pollutant Discharge Elimination System permit combined sewer overflow (CSO) separation schedule, and with the 1990 Consent Agreement with the U.S. EPA for corrective action on its CSO/wet weather discharges at outfall #8 was eliminated in 1992. After securing a significant portion of construction funding for the largest CSO (Outfall #2) from the State of Michigan Revolving Loan Fund, construction was initiated. The separation project was completed in 1993 and as been closely monitored to determine the effectiveness of the separation.
- The purge well system installed at the Menominee City Landfill in 1991 has been connected to the sewer system. The contaminated groundwater is being treated at the Menominee Wastewater Treatment Plant. A silty sand cap was installed and seeded with grass at the landfill in 1992. Preliminary reports indicate that contaminants have been contained on site.
- Marinette's wastewater collection and treatment system was expanded to handle a wet weather flow of 68 million liters (18 million gallons) of wastewater effluent per day.
- The City of Marinette developed and implemented an industrial pretreatment program to reduce disruptions of wastewater treatment plant operations caused by industrial discharges.
- High concentration of PAHs, typically found in coal tar waste, had been detected in river sediments adjacent to the Marinette wastewater treatment plant as well as in on-site soils and groundwater. The site, a gas manufacturing plant until 1962, is under investigation with a potentially responsible party to determine the extent of contamination and to assess remediation alternatives.
- The U.S. Army Corps of Engineers completed a maintenance dredging operation at the mouth of the Menominee River during the summer of 1991. The project removed 17,500 m3 of material from the main channel below the turning basin and restored channel depths to 6.4-7.0 m. Laboratory analyses indicated that some of these sediments contained elevated levels of arsenic.
Current projects and outlook
- Ansul Arsenic Ground Water Contamination Remediation Project
- A project to develop a barrier to cut off arsenic contaminated ground water contributions to the Menominee River is in the modeling and design phase. Hope to begin construction by the end of 2006.
- Need to determine cleanup level and negotiate dredging of contaminated sediments.
- Developing new remediation technique to treat the high arsenic concentrations found in the ground water.
- WPSC Marinette MPG (Manufactured Gas Plant) "Coal Tar Site"
- April 29, 2005 U.S. EPA-Superfund Discovery Phase complete.
- Site will be developed as a Superfund Alternative Site,
though not on the National Priorities List. The site
development will follow the Superfund Process, essentially:
- Historical review
- Complete site review
- Full investigation
- Lake Michigan Monitoring Inventory – Menominee River (PDF 658K, 6pp)
A primary goal of the Lower Menominee River RAP is and has been to include and encourage public participation in RAP development and implementation. Public participation has focused on:
- Community Recognition
- Public Meetings
- RAP Advisory Committees
- Education and Outreach
- Community Cleanup Days
- School Presentations
- Stakeholder Survey
As part of the RAP process, WDNR and MDEQ formed a RAP Citizen's Advisory Committee (CAC). The CAC included area residents, local government officials, educators, recreation specialists, environmentalists, and business and industry representatives from the Marinette, Wisconsin and Menominee, Michigan area. Also included were CAC community education and outreach activities were also begun and will continue throughout the RAP process.