Listing Guideline

When the incidence rates of fish tumors or other deformities exceed rates at unimpacted control sites or when survey data confirm the presence of neoplastic or preneoplastic liver tumors in bullheads or suckers.

Delisting Guideline

When the incidence rates of fish tumors or other deformities do not exceed rates at unimpacted control sites and when survey data confirm the absence of neoplastic or preneoplastic liver tumors in bullheads or suckers.

Delisting Targets

Removal may occur if:

  • All known major sources of PAHs and chlorinated organic compounds within the AOC and tributary watershed have been controlled or eliminated
  • A fish health survey of resident benthic fish species, such as white suckers, finds incidences of tumors or other deformities at a statistically similar incidence rate of minimally impacted reference sites.

OR, in cases where tumors have been reported:

  • A comparison study of resident benthic fish such as white suckers of comparable age and maturity, or of fish species found with tumors in previous fish health surveys in the AOC, with fish at minimally impacted reference sites indicate that there is no statistically significant difference (with 95% confidence) in the incidence of liver tumors or deformities.

Sources of Pollution or Problem

  • Contaminated sediments; spills of chemicals within the watershed; atmospheric deposition
  • Sediment, nutrients, and bacteria as a result of nonpoint, or diffuse, sources of pollution; urban stormwater runoff; sewer overflows; noncontact cooling water

Remediation Actions

The 1994 RAP included this BUI as suspected because the concentrations of certain PAHs and metals in AOC sediments were similar to concentrations in areas with verified fish tumors. As of 2008, no fish health surveys had been conducted within the AOC to determine the extent (or existence) of the impairment. This has since changed (see information in next two sections).

Moving Forward

Results from the sampling of the Milwaukee Estuary and Root River reference indicate more needs to be done to control or eliminate the sources of contaminants contributing to the fish tumor problem. Sites that contain elevated amounts of PAHs, metals, and other substances that cause fish tumors and deformities must be addressed before removal of this impairment can occur.

The following actions need to be completed in order to determine contamination related management actions.

  • Assess areas on the Milwaukee River from Estabrook Park dam downstream to the estuary.
  • Assess the potential impacts to sediments from other manufactured gas plants within the AOC.
  • Review and act upon sediment assessment data from other areas of the AOC. This includes, but is not limited to, Kinnickinnic River/Turning Basin, Menomonee River from confluence with Little Menomonee to the harbor and existing Milwaukee River data. The following management actions are necessary to move towards removing this impairment. This list is not complete. The actions that have been implemented are italicized.

1) Sources of contamination within the AOC need to be remediated.

  • Complete the assessment and cleanup of PCBs at the Cedar Creek Superfund Alternative Site.
  • Complete the management of sediments containing PAHs and metals from the Burnham Canal Superfund Alternative Site.
  • Complete the assessment of contaminated sediment and evaluate and implement clean up related to the Solvay Coke Superfund Alternatives Site.
  • Blatz Pavilion, Lincoln Park Phase 1 and Phase 2 Contaminated Sediment Remediation
  • Kinnickinnic River Legacy Act Cleanup


The main barrier to progress is ensuring enough funding through programs or responsible parties to complete all the contaminated sediment projects (both assessment and remediation) in a timely manner.

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Photo credit Brian Gratwicke