Subject: Project Approach/Scope of Work for Assessing the Feasibility of a Sustainable Regulatory Compliance Strategy for the Waukegan WRF

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1 125 South Wacker Drive, Suite 600 Chicago, Illinois tel: fax: February 26, 2015 Mr. Brian Dorn, P.E. General Manager North Shore Sanitary District P.O. Box 750 William Koepsel Drive Gurnee, Illinois Subject: Project Approach/Scope of Work for Assessing the Feasibility of a Sustainable Regulatory Compliance Strategy for the Waukegan WRF Dear Mr. Dorn: CDM Smith is pleased to submit our Project Approach/Scope of Work to assist the District in assessing the feasibility of a sustainable regulatory compliance strategy for the Waukegan WRF and the potential relocation of the F3 outfall from the Des Plaines River to the Lake Michigan watershed. Our approach builds on our December 2014 meeting when we discussed the drivers and challenges, as well as the benefits and opportunities, of a potential outfall relocation. This information is being provided in preparation for our March 3 meeting with the District. Project Approach Our approach is structured in two phases to enable us to work through several initial tasks that will allow the District to verify the feasibility of an outfall relocation before moving on to a second phase that will formulate and evaluate potential outfall relocation solutions and make a recommendation for moving forward. Phase 1 will identify the regulations, challenges and opportunities associated with a Lake Michigan watershed outfall and will determine the preliminary feasibility of relocation. Phase 1 delivers: Current operations and costs for discharging to the Des Plaines River Stakeholder Involvement Strategy - Who the critical stakeholders are, what they think about the project and how we believe they can be utilized in achieving the

2 February 26, 2015 Page 2 project objectives moving forward (or what their key concerns are that will need to be addressed for future implementation) Current and anticipated regulations and requirements for a Lake Michigan watershed discharge location Assessment of potential outfall locations Potential improvements that will be required to meet anti-degradation requirements and future effluent limits for both watershed outfalls Life cycle costs for long-term operation, maintenance and replacement of the F3 Line General feasibility of discharging through a Lake Michigan watershed outfall Preliminary opportunities that could be realized and benefits that could be associated with a Lake Michigan watershed outfall Phase 2, which will move forward only after the District has concluded that the relocation is potentially feasible, will formulate and evaluate two potential outfall alternatives and provide a recommendation and action plan to move forward. Phase 2 will deliver: Two potential Lake Michigan watershed outfall alternatives that define: o basic improvements/project components o potential roadblocks to implementation o planning level costs o potential opportunities Summary report and alternative evaluation matrix Documentation of the feasibility of a potential Lake Michigan watershed outfall that can be used in subsequent stakeholder consensus-building initiatives Fact sheet that can be used to validate the benefits and feasibility of a proposed Lake Michigan watershed outfall location Action plan that identifies the next critical steps that need to be addressed in order for the project to move forward Presentation to the Board to brief them on the results of the project and to obtain their concurrence on moving the project forward Please review the attached approach/scope of work in anticipation of our Tuesday meeting. We plan on having an interactive discussion with you and your staff to walk

February 26, 2015 Page 3 through our scope of services and to answer any questions that you have. We will also discuss the anticipated level of effort and cost for this work.

3 February 26, 2015 Page 3 through our scope of services and to answer any questions that you have. We will also discuss the anticipated level of effort and cost for this work. If you have any questions, please do not hesitate to give me a call at or me at laudh@cdmsmith.com. Our approach development has helped us better define the steps required to move this concept forward. We re excited about the opportunity to further discuss the project with you next week. Sincerely, Daniel H. Lau, P.E. BCEE, D.WRE Vice President CDM Smith Inc.

4 North Shore Water Reclamation District Sustainable Regulatory Compliance Strategy for the Waukegan Water Reclamation Facility Outline Scope of Service February 26, 2015 Draft Introduction When CDM Smith met with the District last December, we discussed the drivers, challenges, benefits and opportunities (see Figure 1) that might be associated with a Sustainable Regulatory Compliance Strategy for the Waukegan Water Reclamation Facility that would include relocation of the outfall from the Des Plaines River watershed to the Lake Michigan watershed. The preliminary drivers that we identified were: Annual maintenance costs of the pipeline (estimated at $25,000/year) Pumping (energy) cost (estimated at $300,000/year) Pipe replacement/lining (estimated at as much as $55 million) Risk and liability associated with a failure of the pipeline Potential tighter effluent limits on nutrient removal Commitment to a more sustainable approach that considers environmental, economic and social factors Although relocating this outfall to the Lake presents a number of technical, environmental, regulatory and political challenges, the benefits and opportunities the District and its customers could realize could be significant. Relocating the outfall to the Lake would significantly reduce the District s risk and result in significant savings in energy pumping costs and future maintenance/pipe replacement costs. In addition, there are a number of other potential opportunities that could be created or enhanced by a new outfall location including recreational improvements, habitat enhancement, public education, and continued renewal of the lakefront. Project Overview The project is intended to explore the feasibility of relocating the outfall from the Des Plaines River watershed to the Lake Michigan watershed, to recommend a relocation concept, and to identify an action plan that defines the next steps forward. This project will evaluate the feasibility of returning the Waukegan WRF outfall to the Lake Michigan watershed as a more sustainable long-term solution to effluent disposal, and will identify an action plan for moving the project forward. 1

5 Sustainable Regulatory Compliance Strategy Regulators/Stakeholders CMAP IEPA EPA IDNR Lake County SMC Alliance for the Great Lakes Others Compliance Strategy Objectives Drivers Public Demand for Sustainable Practices Increasing Energy Costs F3 Failure Risk F3 Repair/ Replacement Costs More Restrictive Effluent Limits Stormwater Regulations Outfall Relocation Challenges Political Reluctance Public (Environmental) Objections Regulatory Requirements Anti-Degradation Analysis Mercury Levels Demonstrated Value/ Justification Data Collection/ Assessment Stakeholder Contacts Desktop Analysis Life-cycle Costs Challenge Resolution Strategies Benefits and Opportunities Maintenance Cost Savings Elimination of F3 Failure Consequences Harbor Recreational Impacts Glen Flora Wetland Enhancement Triple Bottom Line Proof Energy Savings Reuse Opportunities Harbor Habitat Enhancement Public Education Opportunities Sustainable Regulatory Compliance Strategy Next Steps Figure 1 2

6 We have organized this effort around five major tasks and two phases. Phase 1 will identify the regulations, challenges and opportunities associated with a Lake Michigan watershed outfall and will determine the preliminary feasibility of relocation. Phase 2, which will move forward only after the District has concluded that the relocation is feasible, will formulate and evaluate two potential outfall alternatives and provide a recommendation and action plan to move forward. The phases and major tasks are: Phase 1 Preliminary Feasibility Task A - Data Collection and Review Task B - Stakeholder Involvement Strategy Task C - Assessment of Current and Future Conditions Phase 2 Recommendation and Action Plan Task D - Alternative Formulation and Evaluation Task E - Recommendations/Action Plan A workflow diagram outlining these and other important activities for the project is included in Figure 2. Scope of Services Task A Data Collection and Review 1. Meet with the District in a kickoff meeting to define the goals and objectives for the project and to agree on project communication protocols. Define the goals, objectives, potential benefits and opportunities associated with the project. 2. Meet with District staff to understand current plant, effluent pump and pipeline operations and performance, and other information that are important relative to an objective evaluation of this concept. 3. Collect and review data including: a. Current and projected influent and effluent flows and loads (BOD, TSS, nutrients, metals, bacteria) b. F3 treated effluent line and pump station history, operation, maintenance and performance data i. Simpson Gumpter reports on effluent force main ii. Cost and damage associated with pipe breaks in the 1990 s iii. Facility O&M costs associated with pump station and force main iv. Existing pump station, and recent maintenance on pumps c. Facility hydraulic profile and available site survey (for both Lake and Des Plaines discharge locations) d. Mapping of service area 4. Develop a plan for and meet with three selected external stakeholders to obtain information on regulations, concerns and opportunities associated with the project. Anticipated meetings with selected stakeholders include (see Task B Stakeholder Involvement Strategy for related tasks): a. IEPA to discuss a preliminary outfall relocation scenario and the specific concerns and requirements of the state relative to this course of action 3

Sustainable Regulatory Compliance Strategy (Outfall Relocation Study) Workflow Diagram NSWRD Meetings Kickoff Meeting/ Stakeholder Strategy Alternative Formulation Workshop Recommendations/ Action

7 Sustainable Regulatory Compliance Strategy (Outfall Relocation Study) Workflow Diagram NSWRD Meetings Kickoff Meeting/ Stakeholder Strategy Alternative Formulation Workshop Recommendations/ Action Plan Workshop Identify/Assess Regulations/ Expectations Data Collection/ Review Data Requests/ Initial Contacts/ Meetings Evaluate Operations/ Performance Identify Gaps/ Required Improvements Formulate Relocation Alternatives Evaluate Alternatives Recommendations/ Report Action Plan Next Steps Identify/Assess Outfall Options Identify/Assess Benefits & Opportunities Fact Sheet/ Graphic Stakeholder Identification & Characterization Stakeholder Message/ Initial Strategy Preliminary Feasibility Technical Memo Stakeholder Strategy Update Phase 1 Preliminary Feasibility Phase 2 Recommendations & Action Plan Figure 2 4

8 b. CMAP to determine its role and concerns/requirements to consider relocating the Waukegan WRF outfall to the Lake c. City of Waukegan to assess its plans for redevelopment of the Lakefront and to identify synergies with potential outfall locations d. Environmental stakeholder groups for the Lake, Harbor and Des Plaines River 5. Task A outcomes: Summary of current operations and costs to discharge to the Des Plaines River Initial requirements, regulations, and expectations of critical stakeholders Task B Stakeholder Involvement Strategy Relocating the Waukegan WRF outfall to the Lake Michigan watershed (Lake outfall or harbor outfall) is a sensitive issue that must be addressed appropriately because of the long history of removing pollutants from the Lake and entrenched positions that assume any outfalls to the Lake are detrimental and should not be allowed. This requires a managed stakeholder involvement strategy that allows the District to prepare and deliver the correct message at the right time and to the right stakeholders. The objectives of this task are to: define the stakeholders expected to be part of a review, comment and approval process; understand their mission, purpose and position regarding the outfall relocation; and, identify a strategy to communicate with them and address their concerns. One of the key outcomes of this task is to identify potential stakeholders who may be able to support the relocation or ideally, serve as a champion for its implementation. Some stakeholder interaction is expected during the project, but others will occur in subsequent steps as a part of the action plan. Stakeholder interaction/meetings will be carried out by CDM Smith, District staff, Commission members or a combination. 1. Meet with the District in a kickoff meeting to identify potential stakeholders and to prepare an initial assessment of their interest and role in the project. A portion of the kickoff meeting will be dedicated to the stakeholder involvement strategy and may have different participants than the data collection aspects of the meeting. Summarize the stakeholder s information in a stakeholder involvement matrix. Potential stakeholders include: IEPA, regulators CMAP Des Plaines Watershed Group Waukegan Citizens Advisory Group City of Waukegan (redevelopment plans) Local Businesses/Industry Drinking water regulatory groups Elected officials Non-profits and environmental groups Lake County SMC IDNR (permits, water, coastal/shoreline, IL Beach State Park) Other 2. Define a stakeholder involvement/communication strategy in collaboration with the District that clarifies our approach for early interaction with selected stakeholders. This would include a 5

9 careful review of which stakeholders should be contacted in light of the importance and sensitivity of this issue to Lake Michigan stakeholders. Develop the message to be conveyed to these stakeholders during initial contacts. Define potential advocates or champions who would potentially support this project. 3. Conduct initial stakeholder meetings to obtain data and information relative to the feasibility of relocating the outfall and to obtain feedback/concerns on the potential relocation. Document stakeholder meetings in a stakeholder contact summary memorandum. Initial meetings are anticipated with the City, EPA, IEPA, CMAP, IDNR, Lake County SMC, NRG (formerly Midwest Generation), the Citizens Advisory Committee, and the Port Authority. 4. Following an assessment of the feasibility of relocating the outfall and the formulation of a recommendation, revisit the stakeholder involvement strategy and modify relative to defining a path forward. This would include an action plan for each stakeholder in our stakeholder matrix that would identify the reason for contacting and the general timing of the contact (immediate or long term). This task could be expanded to include additional follow up meetings if necessary. Incorporate this information into an update of the stakeholder involvement strategy matrix. 5. Task B outcomes: Identification of key stakeholders, their expectations and their potential role in the project Stakeholder involvement/communication strategy and message Meetings/Discussions with critical stakeholders Stakeholder matrix summarizing the strategy for each stakeholder Task C Assessment of Current and Future Conditions A credible assessment of the feasibility of relocating the outfall requires identifying current and future regulations, perceptions and expectations regarding a Lake Michigan watershed outfall, and an understanding of current outfall operations, performance, cost and risk. This information must then be considered relative to potential outfall options, a gap analysis to meet requirements and expectations, and an identification of potential benefits that would be realized by an outfall relocation to the Lake. Task C subtasks include: 1. Identify IEPA s current strategy for future nutrient loading limits for the Des Plaines River and Lake Michigan and the implications they may have on the District s wastewater treatment processes at the Waukegan plant. 2. Assess existing effluent limits for outfalls to the harbor compared to the Lake. 3. Summarize the status of the TMDL being developed for the Des Plaines River. Assess the potential impacts to the NSWRD and future effluent limits and associated plant improvements. 4. Assess state and federal anti-degradation requirements and the implications to a potential relocation of the Waukegan WRF outfall. 5. Review the Great Lakes Compact relative to potential opportunities or restrictions on future Lake Michigan withdrawals in Illinois. 6. Estimate life cycle costs associated with long-term operation and maintenance of the current discharge system to the Des Plaines River. 6

10 7. Qualitatively assess several potential Lake outfall locations in terms of existing effluent limits/water quality requirements. These locations will be compared based on their ability to comply with current and anticipated water quality standards/permit requirements. Identify additional steps/improvements that may be necessary to meet requirements and expectations. Potential outfall locations include: Direct discharge to the Lake via the existing Lake outfall Discharge to constructed wetlands at the plant and then to the Lake Direct discharge to harbor Discharge to the nearby Glen Flora wetland complex for near-shore coastal wetland rehabilitation and ultimate discharge to the Lake Reuse options for the treated effluent 8. Identify gaps and potential improvements to operations or plant performance that may be required for a permitted Lake Michigan outfall. That is, pinpoint what modifications may be required to meet effluent limits or water quality guidelines for a Lake discharge. 9. Identify potential benefits and opportunities that could be associated with different outfall options to the Lake. This could include: Reduction in risk for abandonment of the F3 Treated Effluent Line Energy and cost savings Reuse opportunities Public recreation and education opportunities Harbor recreational benefits Harbor habitat enhancement Lakeshore habitat enhancement for the black crowned night heron Wetland creation Glen Flora wetland enhancement Synergies with Waukegan s vision for the Downtown and Lakefront 10. Summarize requirements, challenges and opportunities in a technical memorandum that will provide initial documentation of the feasibility of an outfall relocation to the Lake Michigan watershed. 11. Task C outcomes: Existing and potential future effluent limits/discharge/anti-degradation requirements Life-cycle costs of the current discharge system Assessment of potential outfall locations Identification of any required treatment improvements Identification of potential benefits/opportunities Preliminary feasibility technical memorandum Task D Alternatives Formulation and Evaluation The previous task will provide guidance on which potential outfall locations would appear to be most acceptable to the stakeholders, the improvements necessary to be acceptable, and the benefits that 7

11 could be achieved if that outfall option was utilized. This task will formulate and evaluate three potential alternatives for consideration by the District including a No Action alternative. 1. Develop and evaluate the No Action alternative. The No Action alternative would leave the current system as is subject to its routine operation and maintenance costs, as well as a future replacement cost of the F3 Treated Effluent Line. The No Action alternative will provide a baseline cost scenario against which other alternatives can be evaluated. 2. Conceptualize two additional alternatives from the potential outfall locations and their ability to meet effluent limits, water quality standards and stakeholder expectations. These alternatives will be developed and screened with District staff in an Alternative Formulation Workshop to determine their potential acceptance and perceived feasibility. The alternatives will be developed at the conceptual level and will identify the required components and general required flow capacities. Alternatives could have one outfall, or could be more complex with more than one outfall location. 3. Develop, characterize and evaluate the selected two alternatives in terms of their basic components and operational performance. This will include estimated construction and O&M costs, environmental impacts, potential benefits/opportunities, technical feasibility, performance, risk, regulatory approval, cost, and public/stakeholder acceptance. 4. Document the alternative formulation and evaluation in an alternative evaluation matrix and brief report and submit to the District for review. 5. Task D outcomes: Formulation of two potential alternative outfall solutions Characterization and evaluation of the two outfall alternatives Alternative evaluation matrix Summary report Task E Recommendation and Action Plan One of the critical deliverables of the project is the supporting documentation for an alternative discharge location. CDM Smith will provide a comprehensive narrative of the alternative formulation and evaluation in a draft report that will be provided to District staff for review. We would suggest the report remain in draft form until the District is comfortable finalizing the study and making it public. We would recommend that either a brief Executive Summary or a one-page fact sheet be prepared for the District to use when discussing the potential project with outside stakeholders or partners. 1. Meet with the District to obtain comments on the draft report and to obtain concurrence our recommendation. 2. Develop an action plan that identifies the next steps and long-term implementation plan for outfall relocation. 3. Prepare a fact sheet and graphic that depicts the recommended relocation concept. The fact sheet can be used by the District to present a concise, consistent and factual message to the public and stakeholders. 4. Identify immediate stakeholder meetings that should occur to keep the project moving forward. 8

12 5. Meet with individual trustees or make a presentation to the full Board on the results of the project and the recommendations to move forward. The process of informing the Board on the progress of the project will be determined through discussions with District staff based on the final Stakeholder Involvement Strategy. 6. Task E outcomes: District concurrence on the recommended plan Action items for long term implementation Fact sheet for the recommended relocation concept Board presentation of the results and recommended path forward 9

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