February 12, 2002

The Commission’s review and comments on the Stage 2 Waukegan Harbor RAP reflect an assessment of the document submitted in relation to the five Stage 2 requirements outlined in the introduction , consideration of the implementation of an ecosystem approach to the restoration and protection of beneficial uses, and an assessment of adequacy of public consultation.

Have in-place remedial measures been evaluated?

As described in Chapters 5, 6, and 7, the Stage 2 RAP provides an excellent summary of past remedial activities and preventive measures. In particular, the removal of polychlorinated biphenyls (PCBs) from slip 3 and the Outboard Marine Corporation property remains one of more outstanding remediation efforts that have been undertaken in the Great Lakes Basin. Approximately 1 million pounds of PCBs were removed from the environment and monitoring of PCB levels in fish tissue is ongoing.

Have alternative additional measures to restore beneficial uses been evaluated?

Chapter 8 outlines RAP objectives and Chapter 10 describes remedial actions. Evaluation of additional measures would be aided by use of a matrix such as that utilized in the Rochester Embayment Stage 2 RAP where the linkage between each proposed action and related beneficial use(s) is clearly displayed.

Have additional remedial measures to restore beneficial uses been selected?

An extensive listing of remedial actions is provided in Chapter 10. A table that demonstrates how each remedial action contributes to each RAP objective(s) would be useful. The Grand Calumet River and Indiana Harbor Ship Canal Stage 2 RAP has an usable table format that could be utilized.

Has a schedule for implementation been adopted and have persons and agencies responsible for implementation of remedial measures been identified?

Many remedial measures have been completed and remaining commitments and responsibilities are identified.

Has an ecosystem approach been taken to the restoration and protection of beneficial uses?

The RAP Team and the Citizens Advisory Group (CAG) have adopted a comprehensive view of their efforts to restore and protect beneficial uses. For example, after finding that the AOC boundaries limited their ability to adopt an ecosystem approach to the restoration and protection of beneficial uses, they began utilizing an extended study area which has provided them with a broader view in regard to environmental issues.

Was the public consulted adequately?

The CAG has proven to be an important element in the ongoing effort by Illinois Environmental Protection Agency to involve the general public in the RAP process. Through its nearly monthly meetings and other outreach events, the CAG has been able to inform the public as well as elected officials of the need to restore water quality in the Waukegan Harbor AOC.

Conclusion

The Waukegan Harbor Stage 2 RAP contains necessary documentation related to the major environmental issues in the AOC. As remediation is accomplished on remaining upland sites, it would be useful to update progress toward full restoration of the beneficial uses. The continued effectiveness of the CAG is notable. In particular, the CAG’s recent information exchange effort with the Lake Baikal Environmental Network is a notable undertaking.