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Exhibit MSD 89F - Solids Handling Master Plan Executive SummaryBLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 1 EXECUTIVE SUMMARY – PHASE 1 AND PHASE 2 To: Metropolitan St. Louis Sewer District From: Bently C. Green _____________________________________________________________________________ This Technical Memorandum (TM) provides an executive summary of both the Phase 1 and Phase 2 portions of this biosolids master plan for the District. Table of Contents Table of Contents ................................................................................................................................ 1 1.Overall Summary ........................................................................................................................ 2 a.Triple Bottom Line (TBL) Summary ......................................................................................... 7 b.Limitations of Prospect Hill Disposal ...................................................................................... 10 c.Regulatory Issues ..................................................................................................................... 11 2. Summary of Phase 1 Technical Memoranda.......................................................................... 19 a.TM 1 -MSD O&M Management ............................................................................................. 19 b.TM 2 -Facilities Summaries and Solids Projections ................................................................ 19 c.TM 3 -Solids Disposal I Reuse Alternatives............................................................................ 19 d.TM 4 -Summary of Regulatory Issues ..................................................................................... 22 e.TM 5 -Condition Assessment Report ...................................................................................... 23 f.TM 6 -Triple Bottom Line Evaluation ..................................................................................... 24 g.TM 7 -Summary of Solids Processing Technologies .............................................................. 25 h.TM 8 -Summary of Prospect Hill Reclamation Facility .......................................................... 25 i.TM 9 -Report on Prospect Hill Remaining Life with Recommendations ............................... 26 j.TM 10 -Report on Potential Prospect Hill Replacement Sites ................................................ 26 3. Summary of Phase 2 Technical Memoranda.......................................................................... 27 a.TM 1 –Bissell Point WWTP Solids Processing Alternatives Evaluation ................................ 27 b.TM 2 - Lemay WWTP Solids Processing Alternatives Evaluation ......................................... 28 c.TM 3 –Coldwater WWTP Solids Processing Alternatives Evaluation ................................... 29 Exhibit MSD 89F BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 2 d. TM 4 –Missouri River WWTP Solids Processing Alternatives Evaluation ............................ 30 e. TM 5 –Lower Meramec WWTP Solids Processing Alternatives Evaluation.......................... 30 f. TM 6 –Regional Solids Processing Alternatives Evaluation ................................................... 31 g. TM 7 – Review of Air Emission Requirements....................................................................... 32 h. TM 8 – Greenhouse Gas Emissions ......................................................................................... 33 i. TM 9 – Opinions of Costs for Alternatives ............................................................................. 33 j. TM 10 – Alternatives Selection Processes and Results ........................................................... 34 k. TM 11 – Phasing and Implementation of Selected Alternatives ............................................. 35 1. Overall Summary The solids master plan update was undertaken by the District with the overall goal and purpose of assessing the capacity of the existing facilities to remain functional and achieve regulatory compliance for the next 20 to 30 year period. A secondary goal of this effort was to assess the benefits of alternative technologies, processes, and partnerships in conjunction with the District’s historical solids handling and disposal means and methods. As the study proceeded however, a number of regulatory drivers were evolving; often conflicting and counter-intuitive, such that the District’s optimum path forward was somewhat uncertain, and in part dependent upon the resolution of legal challenges to the regulatory framework that is currently in place. As such, until there is long-term regulatory clarity, a flexible plan is needed. As this plan evolved, numerous options were considered for each of the District’s seven wastewater treatment facilities; both within the context of what could be done within each of the plants as stand- alone facilities, as well as from a more holistic and region-wide perspective. Ultimately, the District honed in on a regionalized solution for future solids handling processes, with fluidized bed incineration (FBI) facilities located at the Bissell Point plant that would serve as the regional solids handling facility for all of the Districts treatment facilities. However, as that decision-making process was being developed, the United States Environmental Protection Agency (USEPA) on October 14, 2010 published proposed new emission standards for existing sewage sludge BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 3 incinerators (SSIs). These proposed emission standards were based on maximum achievable control technology (MACT) for SSIs, but in several instances, emission limits were proposed that were significantly below the MACT “ceiling” (i.e., the average stack emission concentration for each pollutant achieved by the best performing 12% of SSIs across the country and for which information had been collected). This in essence threw much of the evaluation process into a state of uncertainty as it was unclear what the overall implications of these rules were going to be, if USEPA would re- consider and modify them, and if potential legal challenges would result in their modification. USEPA’s below the MACT ceiling emission limits effectively challenged the results and conclusions that had been developed up to that point in time (i.e., a “regionalized” solution utilizing FBIs), given that this solution was projected to cost in excess of $270M and it could no longer be stated with absolute certainty that such a solution would fully satisfy all future regulatory constraints. Given the level of uncertainty from a regulatory perspective, the District elected to re-consider its approach and evaluate a more fiscally conservative path forward, until the ramifications of the rules are fully known and understood. On March 21, 2011, the USEPA published its final performance standards for both new and existing SSIs. In it, the USEPA actually modified its originally proposed limits so that none were below the MACT ceiling. These modifications added some level of clarity to the emission standards, particularly in that it could be stated with reasonable certainty that existing technologies could achieve these limits with advance emission controls (AEC). However, there still exist a number of elements to the rules that are counter-intuitive and subject to legal challenges. For instance, existing multiple hearth incinerators (MHIs) that undergo a modification that exceeds 50% of the original cost of the unit (in today’s dollars) would be re-classified as “new” MHIs and subject to more stringent emissions limits that would be very difficult to achieve. USEPA has noted that AEC technologies and maintenance are not considered a modification. They have however, indicated that the incinerator structure itself, feed systems, conveyance systems, and waste heat recovery systems for the incinerator are considered a modification. In essence, the final rule BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 4 interpretation by USEPA actually discourages and penalizes facilities that would consider implementation of new technologies and/or green solutions such as energy recovery. The regulatory framework for SSIs is subject to revision going forward, with the outcome influencing the District’s path forward. This implementation plan outlines a number of options that the District will consider depending on the ultimate resolution of legal challenges and interpretation of the SSI MACT standards. Primary options for the District’s consideration are outlined below based on various regulatory scenarios; with capital costs presented in 2011dollars and rounded for discussion purposes (Note: For more refined costs, reference costs tables in TM 9 and as further defined in this TM 11 for more exact estimates): • Full SSI MACT Compliance Achieved with MHI’s Immediately: Delay action indefinitely until regulatory clarification is achieved, or some future modification of the SSI MACT standards dictates additional action. Until further stack tests have been completed, it is unknown as to whether regulatory compliance will be achievable. Assuming that the stack tests indicate the MHIs can comply with the final SSI MACT standards on a consistent basis, the District could elect to delay proceeding with any improvement plans until further developments make it necessary. o Immediate Cost Impact: $0 for regulatory compliance. o Future Cost Impact: To be determined based on regulatory changes. If emission standards do not substantially change, the District could operate the MHIs indefinitely depending on their long-term structural and process integrity. Some modifications and improvements could be considered, so long as they do not exceed a threshold that triggers stricter and unachievable emission limits. • Partial SSI MACT Compliance Achieved with MHI’s Immediately: Invest in necessary AEC technologies for the MHIs at both Bissell Point and Lemay to achieve full compliance. Because the existing facilities do not appear to have sufficient room for these facilities, a building expansion would be necessary to implement this strategy. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 5 o Immediate Cost Impact: Ranges from $30M to in excess of $50M, depending on strategy. o Future Cost Impact: Could be in excess of $120M to the MHIs so long as the MHIs can maintain regulatory compliance. These costs would be for the long-term structural and process improvements to the existing MHIs – under the assumption that such improvements can be made without exceeding a threshold that triggers stricter regulations. Or, improvement costs could be as much as an additional $270M if MHIs are abandoned altogether and replaced with FBIs. • SSI MACT Standards for MHIs Become Stricter in 5 Years: Assumes that the District is able to operate the existing MHIs for a five year period without having to make a substantial investment to achieve regulatory compliance, but that USEPA revises the standards in five years based on additional MHI compliance data and assesses stricter emission standards on existing facilities. o Cost Impact in 5 Years:  In excess of $50M if standards are achievable with limited AEC technology improvements to the MHIs.  In excess of $170M if MHIs can be improved such that they can meet stricter emission standards indefinitely and the District elects to invest in the MHIs long-term. These costs would be for AEC systems, as well as long-term structural and process improvements to the existing MHIs – under the assumption that such improvements can be made without exceeding a threshold that triggers stricter regulations.  Or, the District could elect to implement a regional solution with FBIs at a project capital cost of approximately $270M. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 6 In general, the District’s path forward will be dependent on the ultimate outcome of legal challenges to the SSI MACT standards (and whether those standards become subsequently stricter), the Districts stack test results (and the MHIs capacity for achieving compliance with the SSI MACT standards), as well as other drivers that emerge that dictate re-consideration of the District’s overall solids handling master plan, such as opportunities to partner with other entities for energy recovery or generation. Overall costs, irrespective of a phased implementation plan, for Alternatives S-1, S-2, and S-3 are provided in the table below. Table 9-1 Summary of Cost Opinions for the Regional Evaluation ($1000) Alternative Decentralized (No Regional) S-1 Regional Total System S-2 Regional Total System S-3 Capital Costs $366,785,000 $274,488,000 $316,143,000 Salvage Value ($10,626,000) ($9,034,000) ($15,875,000) Annual O&M Costs $20,362,000 $20,109,000 $17,182,000 Annual Revenue ($2,032,000) $0 $0 Present Worth Costs Capital $366,785,000 $274,488,000 $316,143,000 Salvage Value ($4,005,000) ($3,405,000) ($5,983,000) O&M $253,756,000 $250,603,000 $214,126,000 Revenue ($25,323,000) $0 $0 Total Present Worth Costs $591,213,000 $521,686,000 $524,286,000 BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 7 a. Triple Bottom Line (TBL) Summary The overall triple-bottom-line (TBL) assessment of all alternatives considered is provided in TM 10 (of this Phase 2 Master Plan Report). Each plant was assessed on an individual basis, and then from a more holistic system-wide approach. On a system-wide basis, a regional solids handling facility (with multiple options) was compared against a de-centralized option in which each plant maintained its existing operations. For the Bissell Point and Lemay plants, continued use of the MHIs was compared against replacing them with FBIs. The TBL analysis ultimately concluded that long-term operation of the MHIs was not the preferred option for a variety of reasons; primarily due to concerns regarding their age and condition, and the general need for future upgrades in conjunction with regulatory uncertainty. Additionally, the cost of the FBI system (including AEC) drove the evaluation process towards the consideration of a regional facility – to be located at the Bissell Point plant site. Ultimately, three overall total system alternatives were developed for a long-term strategy: 1) Construct a regional facility at Bissell Point, with all other plants (including Lemay) hauling solids to the facility (except Coldwater which would continue to pump solids to the Bissell Point collection system); 2) Construct a regional facility at Bissell Point, with Lemay and Coldwater pumping solids to the Bissell Point system and the remaining treatment plants hauling their solids to the regional facility; and 3) De-centralized options in which all existing plants are upgraded in accordance with their long-term needs. Under this alternative, the Bissell Point and Lemay plants would both ultimately replace their existing MHIs with new FBIs at each facility. The final TBL analysis results are shown in Figure 11-1. Following the publication of USEPA’s SSI MACT rules however, and given the lack of clarity in the rule’s implementation and potential legal challenges; other options for continuing to operate the MHI’s have emerged that should be considered until further stack testing has been completed which will define upgrades necessary (if any) that are required to meet the currently published emissions limits, and give the District more time to contemplate overall upgrades required to achieve regulatory compliance for a sustained 20 to 30 year period without having to rush into any upgrades based on emission limits that are subject to legal challenges. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 8 Figure 11-1 Triple Bottom Line Results As shown, both of the options for a regional facility are virtually tied and are substantially ahead of a non-regional option. Ultimately, the District’s decision of whether to haul or pump solids from Lemay to the Bissell Point plant will depend on the overall feasibility of constructing a 12-mile force main through a heavily developed part of downtown St. Louis versus the potential social impacts (particularly odor) of having a load-out and hauling operation from Lemay to Bissell Point. Although a force main option has a number of technical and logistical challenges associated with it, it has favorable social and environmental impacts with it as compared against a major cake hauling operation from Lemay to Bissell Point. Unlike the Bissell Point plant, which is located in a predominantly industrial area, the Lemay plant sits in a very heavy residential and commercial area. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 9 i. Implementation Concerns MSD has considered economic, environmental and social impacts throughout the decision-making process of developing a solids master plan. The overall recommended plan has been developed via a large and inclusive project team operating within a workshop format to develop a consensus for meeting the District’s goals and objectives over the next 20 year period. However, these modifications will require a significant capital investment that will impact the District’s overall rate structure for its customers. Simultaneously, the District will also (over the next 20 years) be implementing a Long-term Control Plan (LTCP) for its combined sewer overflow (CSO) system, its sanitary sewer overflow (SSO) system, as well as a number of other regulatory issues that will need to be addressed. The CSO LTCP program alone is ultimately expected to cost nearly five billion dollars. Consequently, the cost of implementing an additional program for the solids handling facilities should be compared against a bare minimum cost alternative, irrespective of whether it was the selected alternative as part of the workshops. In general, there are at least three other alternatives to consider in lieu of the recommended plan, summarized as follows: • Use MHI’s Temporarily Assuming No AEC Equipment Required to Meet Emission Limits This concept will require stack testing to confirm that the existing MHIs can achieve compliance with the SSI MACT standards with no additional AEC required. This option would allow the District to continue operating the MHIs until further regulatory developments, clarifications, and legal challenges help to clarify the long-term regulatory picture, after which the District will be able to make an informed decision on its long-term solids handling strategies. • Use MHI’s Temporarily With AEC Equipment Required to Meet Emission Limits This concept is based on an approach proposed by the District in a workshop on January 19, 2011, and assumes that the MHIs can be used for an extended period of time with additional AEC controls to meet emission limits. Under this concept, the existing MHIs would continue BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 10 to operate indefinitely with advance air emission equipment constructed as necessary to meet SSI MACT pollutant limits under the assumption that these limits were reasonably achievable and not below the MACT floor. • Modify MHI’s for Long-Term Use In this case, financial considerations dictate the continued use of the MHIs for as long as possible, even if this requires significant investments to maintain the structural and functional integrity of the MHIs for a sustained 20 to 30 year design period, and would include advance emission control (AEC) systems as required to meet long-term regulatory objectives. This option also assumes that USEPAs “modification” rule will be clarified to conclude that such modifications could be made without triggering a revision in the emission limit standards such that the MHIs would be classified as “new.” This is unlikely given that the current definition for modification, as summarized in Table 11-2 – Modification Criteria for SSI Units, defines much of the structure as counting towards the threshold that would constitute such a re-classification. The standards for new MHIs are considered too stringent for existing MHIs to consistently meet. As such, this alternative has very little realistic probability, although it should certainly be considered. b. Limitations of Prospect Hill Disposal One of the secondary drivers for this study was the remaining life limitations of the Prospect Hill landfill, which has been the primary disposal site for incinerator ash from the Bissell Point and Lemay treatment plants. These issues were assessed and summarized as part of the Phase 1 report (reference TM 8 and TM 9). As noted, the landfill has historically averaged 72,500 cubic yards of material on an annual basis. Future ash production however is anticipated to increase to 96,500 cubic yards per year (and under certain “regional” scenarios not contemplated in Phase 1, this rate could be even higher since raw solids from the county plants would be incinerated rather than hauled to a landfill). At the current permitted landfill boundary limits (assuming a rate of 96,500 cubic yards per year) the landfill would have as little as 8 years of capacity remaining (thus requiring modified BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 11 operations or landfill expansion by approximately 2017-2018). A vertical expansion is currently being considered by the District to add up to 814,000 cubic yards of volume to the landfill and extend the remaining life by approximately 8.4 years (at future ash production rates). Thus, with a vertical expansion, the Prospect Hill Landfill site has roughly 15-20 years of life remaining. There are some alternatives being considered that could extend the life of the landfill further. Most notable is a potential partnership opportunity with a local cement manufacturer who has expressed an interest in using the ash material as an amendment to their operations. Spokesmen for the company have conducted some preliminary assessments of the material and have indicated that they may be interested in taking all of the material that is produced from both the Lemay and Bissell Point plants. In reality, unless modifications could be made to address concerns for mercury, the feasibility of such a partnership is possibly limited to the remaining life of the MHI units as currently operated (i.e., without mercury limits). Other wastewater treatment facilities that have sewage sludge incinerators (SSI) units and formerly had partnerships with cement manufacturers, indicated that once stringent mercury emission limits were imposed (and the mercury was removed within the ash instead of being emitted to the atmosphere), cement manufacturers faced their own regulatory issues with the mercury that effectively eliminated the use of the ash material as a suitable amendment, and thus partnership agreements were terminated. For the District however, even a temporary partnership with a cement manufacturer could potentially extend the life of the Prospect Hill landfill by another 3-5 years. Additionally, programs to remove mercury discharge to sewer collection systems might also reduce its concentration such that mercury in the ash is not detrimental to cement manufacturer operations. In such a case, the life of Prospect Hill landfill as an alternate disposal live would be extended indefinitely. Preliminary discussions and testing conducted by cement manufacturers have been very positive. c. Regulatory Issues Regulatory issues with respect to incineration facilities are anticipated to be the primary driver for the District’s future major capital expenditures related to the solids process and handling facilities. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 12 Since 1993, the Part 503 Regulations and Clean Air Act emission requirements for incinerators have primarily governed treatment and disposal options associated with biosolids. Curently, the United States Environmental Protection Agency (USEPA) has developed regulatory rule changes under which air emission requirements for SSIs would be regulated under solid waste incinerator rules and criteria. Emissions from municipal wastewater SSIs are currently regulated under Section 112 of the Clean Air Act (CAA). If biosolids processed by SSIs are regulated as “solid waste,” incineration of biosolids would no longer fall under the “domestic sewage exclusion” provision and would be regulated under Section 129 of the Clean Air Act. USEPA has proceeded under this interpretation and has developed air emission requirements based on Maximum Achievable Control Technology (MACT) standards (which are based on the best performing 12% of SSIs currently operating in the U.S.). On October 14, 2010, USEPA released the draft MACT standards for SSIs. There were a number of emission limit standards developed that actually fell below the MACT ceiling (i.e., the limits as defined by the best performing 12% of SSIs). It was also noted that the MACT standards were developed from very limited data set and that emission limits were established based on each individual pollutant (or what is referred to as the best performing source for that pollutant). These standards were subject to a public hearing on October 29, 2010, and a comment period that ended on November 29, 2010. MSD and many other utilities provided comments on the proposed rule. MSD’s comments are attached to this memorandum (see Attachment 1). USEPA considered these comments and made some modifications. On March 21, 2011, EPA published is final SSI MACT standards and raised the limits on a number of pollutants (i.e., they became less restrictive), particularly for existing MHI SSI’s (see Attachment 2 for USEPA Final Rule Implementation) such that none of the emission limits were less than the MACT ceiling. Note that EPA maintained its interpretation that SSI’s should be regulated as a “solid waste.” As such, there are a number of public agencies (including NACWA) that are considering legal challenges to the rule as currently implemented. The rule became effective 60 days from the publication date (i.e., May 20, 2011). Although USEPA announced that it will “reconsider” certain aspects of other BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 13 separate but related air emissions regulations (e.g., boiler and commercial/industrial solid waste incinerator, or CISWI, rules), the SSI rule is not part of the reconsideration. A summary of modifications made to the MACT standards from the initially proposed rule (October 14, 2010) to the final rule (March 21, 2011) is provided as follows: • Beyond the MACT Floor limit for Hg has been eliminated for existing MHI source category with the Hg limits for existing MHIs increased by a factor of 10. • The EPA has included a “new MHI” category. The new MHI category provides an option for existing MHIs that may undergo “modification” and be subject to ”new MHI” limits rather than existing source limits. • For new FBIs, the emission limit for Hg has not changed; Dioxin and Furan (CDD/CDF) limits have been relaxed; and all the others remain the same compared to the proposed rule. • For CDD/CDF, EPA is now giving the flexibility of choosing either the total mass basis (TMB) limits or the toxic equivalency (TEQ) based limits. • Inclusion of an emission threshold test (< 75% of the limit), if met, will result in a three- year testing frequency rather than annual performance testing for PM, Cd, Pb, Hg, SO2, HCl, NOx and CO. • Maintaining sludge feed rate and moisture criteria established during the performance test has been relaxed to more typical monitoring. • Compliance performance testing can be done at 85 percent of maximum permitted capacity of the SSI. • Contrary to the assumption in the proposed rule that alternative disposal methods (i.e., land filling) would be required for a majority of the facilities, EPA now estimates that all facilities will choose to continue incineration. Should a facility choose an alternative method of disposal, EPA acknowledges that the decision is based on local variables. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 14 A summary of EPA’s proposed limits for MHIs and FBIs (for both new and existing) is provided in Table 11-1. Table 11-2 - Final Emission Limits for SSI Units Final Emission Limits for SSI Units Pollutant Units Emission Limits for Existing MH SSI's Emission Limits for Existing FB SSI's Emission Limits for New MHI's Emission Limits for New FBI's Cd mg/dscm @7% O2 0.095 0.0016 0.0024 0.0011 CDD/CDF, TMB ng/dscm @ 7% O2 CDD/CDF, TEQ ng/dscm @ 7% O2 CO ppmvd @ 7% O2 3800 64 52 27 HCl ppmvd @ 7% O2 1.2 0.51 1.2 0.24 Hg mg/dscm @7% O2 0.28 0.037 0.15 0.001 NOX ppmvd @ 7% O2 220 150 210 30 Opacity % Pb mg/dscm @7% O2 0.3 0.0035 0.00062 PM mg/dscm @7% O2 80 18 60 9.6 SO2 ppmvd @ 7% O2 26 15 26 5.3 A number of project team discussions and workshops were conducted immediately following the USEPA’s announcement of potential SSI MACT standards, with consideration given to the long- term impact of the District’s operations and current overall master plan strategy. A summary of these discussions is provided as follows: • There are a number of inconsistencies in EPA’s proposed rules that will ultimately require clarification and interpretation to fully assess their impact on future investment decisions. • Currently, language appears to significantly limit the level of upgrades possible to MHIs before a threshold of 50% investment (defined as greater than 50% of the cost of the original unit updated to 2010 dollars) in a modification results in the re-classification of the MHI as a “New Unit” – which would trigger essentially non-achievable emission limits (for MHIs). Simultaneously, mercury limits for existing MHIs will necessitate the addition of Advanced BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 15 Emission Control (AEC) equipment in order to comply with the proposed standards. Thus, utilities interested in keeping MHIs in operation would be required to invest in upgrades to equipment that may ultimately be rendered obsolete if those and/or other upgrades surpass the 50% threshold, and nearly non-achievable “New Unit” limits are imposed. Modification means a change to an SSI unit later than 6 months after March 21, 2011, and that meets one of two criteria: (1) The cumulative cost of the changes over the life of the SSI unit1 exceeds 50 percent of the original cost of building and installing the SSI unit (not including the cost of land) updated to current costs (current dollars). Land costs and costs for updated emission controls to meet the SSI MACT requirements are not included in the cumulative costs. (2) Any physical change in the SSI unit or change in the method of operating it that increases the amount of any air pollutant emitted for which Section 129 or Section 111 of the Clean Air Act has established standards. 1 The EPA uses a comprehensive definition of what constitutes a SSI unit – A SSI unit includes, but is not limited to, the incinerator vessel, the sewage sludge feed system, auxiliary fuel feed system, flue gas system, waste heat recovery equipment, if any, and ash system. The SSI unit includes all ash handling systems. The combustion unit ash system ends at the truck loading station or similar equipment that transfers the ash to final disposal. The SSI unit does not include air pollution control equipment or the stack. A summary of what constitutes a “modification” is provided below. Table 11-3 Modification Criteria for SSI Units Included in “modification” Not included in “modification” Feed system and grate system Air pollution control equipment Incinerator Maintenance Bottom ash and conveyance system Waste heat recovery equipment As noted, there currently exists a “penalty” for energy recovery that actually discourages its usage, as well as for the implementation new technology (FBIs). Furthermore, there is a lack of clarity as to how utilities are supposed to address these regulations given that the limits are reconsidered on a five year basis and are anticipated to get progressively stricter. Requirements for initial compliance with the regulations are summarized as follows: BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 16 • Existing SSIs must demonstrate compliance with the standards as expeditiously as practicable after approval of a State plan, but no later than 3 years from the date of approval of a State plan or by March 20, 2016, whichever is earlier. • Operators of SSIs must conduct initial and annual emissions performance tests or, as an alternative, install continuous emissions monitoring; bag leak detection systems for fabric filter (when used); and continuous monitoring of critical operating parameters and annual inspections for all air control equipment. • For new SSI units, operators must prepare and submit a pre-construction Site Analysis report that evaluates site-specific air pollution control alternatives that minimize potential risks to public health or the environment. The alternatives should be evaluated considering costs, energy impacts, non-air environmental impacts and other factors relating to alternative practicality. The report must be submitted to the EPA (and in some cases the state agency, instead of the EPA) prior to the start of facility construction. • All publicly operated treatment works and utilities operating existing and proposing new SSIs must obtain a new Title V air operating permit. • The new standards will require at least one operator or supervisor per facility to complete the operator training course, an annual review, or refresher course. POTWs and utilities that operate SSIs must maintain training information at each plant and update it annually. In general, there are a number of control mechanisms for addressing regulatory compliance, depending on the constituent. A summary of the various mechanisms for addressing selected MACT standard constituents is provided on the following page. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 17 Table 11-4 Control Mechanisms for SSI Units Constituent Units Existing MHI New FBI Control Mechanism(s) Cd mg/dscm 0.095 0.0011 Particulate removal CDD/CDF, TEQ* ng/dscm 0.32 0.0044 Combustion, carbon CDD/CDF, TMB** ng/dscm 5 0.013 Combustion, carbon CO ppmvd 3,800 27 Combustion HCl ppmvd 1.2 0.24 Absorption or chemical conversion Hg mg/dscm 0.28 0.001 Adsorption NOx ppmvd 220 30 Combustion, chemical conversion Pb mg/dscm 0.3 0.00062 Particulate removal PM mg/dscm 80 9.6 Particulate removal SO2 ppmvd 26 5.3 Absorption or chemical conversion Existing SSIs must be assessed on a unit by unit basis to determine compliance under existing SSI limits. Baseline emissions from performance testing for SSIs should be used to determine compliance with the new rule. A review and analysis of the selected baseline emissions for SSIs reported by EPA suggests the following potential emission issues: Table 11-5 Potential Emissions Issues for SSI Units Cd CO HCl Hg NOx Pb CDD/CDF PM SO2 Existing MHI    New MHI      Existing FBI      New FBI       = potential emission limit issue based on EPA baseline emission data of selected SSIs and available control equipment BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 18 An initial assessment of the “Existing Multiple Hearth” emission limits, based on the performance of a number of these units nationwide, indicates that most MHIs will likely comply with the limits initially. Compliance with CO should not be a problem. Older units, depending upon site-specific data, may need emission control upgrades or add-on emissions controls. Existing MHIs are anticipated to meet “existing” MHI standards. In some cases, Cd, Hg, NOx and SO2 emissions may be problematic, requiring additional controls. The District is currently conducting stack tests on its MHI units to assess its capacity to achieve “existing MHI” limits. A preliminary review of the District’s incinerator stack test data completed within the last 20 year period indicates that the MHIs may very well meet many of the currently proposed limits, with the potential to have occasional issues with NOx and SO2. Should the limits become tighter as they are periodically updated on a five year basis against the best performing 12% of SSIs, the feasibility of the MHIs maintaining regulatory compliance would need to be re-evaluated in conjunction with any emission limit modifications enacted. The District will need to closely track capital expenditures to determine if “modification” is triggered, which would reclassify an existing MHI to a new MHI. If functional upgrades are extensive, existing MHIs may have to shutdown rather than accept the “new” incinerator designation and limits. New MHI status is very restrictive, potentially requiring controls for CO, Hg, and CDD/CDF. New FBI, the most restrictive of all the categories, will require extensive emissions controls as part of the design package. This will dictate that AEC systems be employed on FBIs from the outset, rather than delaying until the more restrictive limits are imposed in the future. This scenario had already been contemplated during workshops completed in September 2010, and the consensus decision made then was to move AEC systems from an “alternative” to be implemented in the future into the overall FBI base case to be implemented with initial FBI construction. Although the limits for new facilities were more stringent for some pollutants that what had been anticipated, FBI BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 19 204 200 21 21 9 9 8 96 47 9 11 6 9 30 50 100 150 200 250 Bissell Point LeMay Missouri River Coldwater Lower Meramec Grand Glaize FentonDesign solids (dtpd)Solids Production Design Current systems with AEC equipment can achieve the proposed limits, although with less room for error than had previously been anticipated. 2. Summary of Phase 1 Technical Memoranda a. TM 1 -MSD O&M Management Technical Memorandum (TM) No.1 summarizes overall MSD Operations and Maintenance Management costs as provided by the District. These costs were incorporated into the overall cost estimates developed as part of Phase 2. b. TM 2 -Facilities Summaries and Solids Projections Technical Memorandum (TM) No.2 summarizes the existing solids processing facilities and current solids production for each of the Metropolitan St. Louis Sewer District's (MSD) seven wastewater treatment facilities. It also provides us with the initial operation date of each treatment facility and its major treatment components along with its average design capacity, peak hydraulic design capacity, design sludge production and current solids production based on plant data from 2006 ¬2008. Solids production levels for each of these seven facilities are shown in the figure below: c. TM 3 -Solids Disposal I Reuse Alternatives Technical Memorandum (TM) No.3 covers the disposal/reuse alternatives and technologies for municipal wastewater solids and incinerator ash produced by the Metropolitan Sewer District (MSD) BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 20 of the City of St. Louis. Disposal/reuse alternatives reviewed in this section included landfill disposal, land application, distribution and marketing of a fertilizer product, incinerator ash use as construction material, and energy production. Regulatory requirements and preliminary cost estimates for each final use/disposal alternative were also discussed. Landfilling has been used as disposal method for dewatered solids found to be cost effective in places where tipping fees are low and the hauling distance is relatively short. Different landfilling options such as monofill and co- disposal were reviewed. MSD currently hauls sludge from the Lower Meramec, Grand Glaize, and Fenton Wastewater Treatment Plants to the IESI-BFC Ltd. (formerly Fred Weber) landfill. From the Missouri River WWTP, biosolids that exceed the capacity of the St. Peter's composting facility are also hauled to the IESI-BFC Ltd. (formerly Fred Weber) landfill. Landfilling unit costs were reviewed for both tipping and hauling. Many of the landfills anticipate long term availability for dewatered cake, on the order of 50 years or longer. Bulk application was also analyzed and found to be the most common option for beneficial use of biosolids and is often most cost effective. Biosolids can be applied to agricultural land, forested areas, rangelands, or to disturbed land in need of reclamation. Composting can be used for horticultural and agricultural purposes. There are numerous facilities in the St. Louis area that compost various organic materials (including some portion of MSD's biosolids), and it is anticipated that the market for end product is well-supplied. Markets for compost are generally seasonal in nature with greatest use occurring during the spring and fall. One of the benefits of compost is that it can be stored uncovered outside for many months. Incineration produces steam, flue gas, and ash. The most common disposal method of incinerator ash is landfill disposal. Ash is regulated as a solid waste in Missouri. Biosolids ash typically meets Toxicity Characteristics Leachate Procedure (TCLP) requirements and can be disposed in properly permitted landfills. The incineration process itself must comply with air emission requirements. Incinerator ash is typically hauled to landfills or monofills for disposal. The MSD-owned ash monofill is currently being evaluated to determine ultimate capacity and expected life. A number of landfills are available for ash disposal. Landfill unit disposal costs for ash in privately-owned BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 21 landfills are similar to those for biosolids with tipping fees; however incineration significantly reduces the quantity of material requiring disposal. Heat drying removes water from dewatered biosolids to accomplish both v e and weight reduction. Drying can also be used to meet vector attraction reduction standards through desiccation. Since dried biosolids are relatively odor free, easy to handle, and meet Class A pathogen requirements, they have a number of outlets. While bulk land application is the most common, marketing programs can be developed to target high-end outlets. Local fertilizer use and distribution will generally be seasonal, but the relatively high value of the end product may support transportation to other markets that can utilize the biosolids year around. Product that is committed to use as a fuel component for cement manufacturing or power production will generally have a year around outlet; however such plants may schedule periodic outages in which no biosolids will be utilized. Product that cannot be beneficially used can be landfilled. The market value of heat dried biosolids depends on local market conditions, nutrient content, physical characteristics of the product, and other factors. Gasification has been used for over fifty years to convert coal and petroleum based materials into a combustible gas, commonly referenced as synthetic gas (syngas), and a carbon rich residue called char. The ash that comes out of the gasification system can be reused/disposed in the same way as incinerator ash. Gasification is still an emerging process for biosolids treatment, with a single demonstration unit in operation at Stamford, CT. Biosolids that are not treated through gasification or SlurryCarb process can be disposed in landfills (if dewatered). If the biosolids are stabilized, such as thorough digestion, they may be suitable for bulk land application. Ash generated through the gasification process will have disposal costs similar to incineration ash. Costs and/or revenues for char as a fuel product are unknown at this time. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 22 d. TM 4 -Summary of Regulatory Issues Technical Memorandum (TM) NO.4 presents a review of biosolids-related regulations that would potentially apply to the Metropolitan St. Louis District (MSD) biosolids program. It addresses Federal and State regulations: Biosolids are regulated by the U.S. Environmental Protection Agency (USEPA) 40 Code of Federal Regulations (CFR) Part 503 Rule and by state and local ordinances. Odor, pathogens (e.g. disease- causing bacteria and viruses), biological vectors (e.g. rodents and flies) and heavy metals impact biosolids management, disposal, and final use practices. Results of discussions with the Missouri Department of Natural Resources (MDNR) to identify existing trends in biosolids management or permitting practices or potential changes in state regulations were also included. Federal: The Part 503 rules primarily regulate land application practices, surface disposal (monofills), sewage sludge incineration, pathogen and vector attraction reduction. Federal Regulations for biosolids also include air emission and metal limits. Air emissions are controlled under a number of federal regulations, including both Clean Air Act and 40 CFR Part 503. State Regulations: The Missouri Department of Natural Resources (MDNR) has no sludge incinerator specific regulations other than those that are already listed under the federal regulations. The MDNR has its biosolids rules codified under the Code of State Regulations (CSR), Title 10. The State of Missouri does not have delegation over biosolids permitting; however, the state has the authority to promulgate regulations and guidelines in addition to those presented in Part 503. The MDNR has incorporated the Part 503 rules in the state requirements under the Missouri Clean Water Law and regulations. The state rules include additional requirements that are not covered under USEPA. Complying with the state rules automatically meets the USEPA requirements as well. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 23 e. TM 5 -Condition Assessment Report Technical Memorandum (TM) No.5 summarizes the O&M and management strategies determined from condition assessment evaluations performed as a part of the Comprehensive Solids Handling Master Plan. It also summarizes the Results of the condition assessments conducted on the solids processing systems at the Metropolitan St. Louis District's seven wastewater treatment plans (WWTPs). An assessment of the facilities and equipment for the WWTP's was conducted to support the overall goals of the project. Specifically, the assessment and ranking of risk levels of the facilities was based on the product of the ranking of the Probability of Failure (POF) and Consequence of Failure (COF). Assessment of Probability of Failure (POF) -Probability of Failure criteria were evaluated using the following guidelines: Condition, Reliability, Capacity, Functionality, Financial Efficiency. Assessment of Consequences of Failure (COF) -The Consequences of Failure criteria at the WWTP's were evaluated using the following guidelines: Health & Safety, Social Impact, Difficulty of Repair, and Redundancy. The Team met with MSD O&M staff and briefly reviewed the organization and current use-of- equipment data, maintenance Work Order (WO) history, and obtained downloads of the target equipment data for each of the seven waste water treatment plants (WWTP). Based on discussions with staff, equipment associated with the following systems was used as a basis for the assessment activities to support the Comprehensive Solids Master Plan development. An analysis was performed on the equipment/asset hierarchy. It was apparent that significant effort was put in by MSD in developing its location and equipment-based hierarchy. A review was performed of the WO's captured and downloaded from MSD's IBM¬Maximo application for a subset of plant process area. Extensive WO History has been maintained and identified dating back to 1995. Failure data associated with WO's was also recorded and reviewed. It was determined that Failure data can have a positive direct impact on the maintenance strategies of equipment and ultimately result in improved performance and reliability of equipment at MSD's facilities. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 24 As MSD plans/implements the next generation of its IBM-Maximo CMMS, there are several opportunities for improving the speed, accuracy and consistency of analyzing key equipment failure- related data to make it more consistent with Best Asset Management practices. A Condition Assessment was performed by Condition Assessment teams where staff reviewed each District's plants with District personnel. The goal of the condition assessment was to review each facilities solids processing equipment, as well as its screening and grit removal equipment. The assessments consisted of a visual inspection and focused on key process equipment. An Equipment Inspection Summary by Plant was developed indicating the number of equipment items assessed per plant and the number of POF and COF ratings of 4 or 5. Findings from each WWTP condition assessments were also summarized. f. TM 6 -Triple Bottom Line Evaluation Technical Memorandum (TM) No.6 represents information on the Triple Bottom Line (TBL) evaluation methodology, criteria, and weighting factors. Incorporating TBL evaluation in the Comprehensive Solids Handling Master Plan analysis ensures that factors affecting sustainability, including environmental and social merits and life The TBL consists of: 1. An economic component that reflects the cash flow accounting stance of the utility (i.e., internal costs and revenues) 2. A "social" component that reflects the social impacts of the utility action (e.g., minimizing nuisance impact to local community such as truck traffic and noise from plant operators.) 3. An environmental component that addresses environmental impacts of the utility actions and decision, such as reducing Green House Gas (GHG) emissions by reducing methane flaring and electricity purchases. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 25 g. TM 7 -Summary of Solids Processing Technologies Technical Memorandum (TM) No.7 summarizes solids processing technologies that may be considered to support the final use alternatives identified during Workshop 1, Final Use Alternative Screening. Each of these technologies was discussed and evaluated during Workshop 2, Technology Screening Workshop. The results of screening are also included in this TM. The treatment technologies discussed in this TM are thickening, dewatering, stabilization, incineration, and energy recovery. The technologies presented include only those that can support the final use options selected for further evaluation at the Metropolitan Sewer District (MSD) facilities. Benefits and drawbacks of each of the listed technologies are also presented. Each technology is also presented in terms of suitability for a large-sized facility or a medium-sized facility. Large-sized facilities include the Bissell Point and the Lemay Wastewater Treatment Plants (WWTPs). Solids quantities from the Lemay plant were used to represent "large-sized plant" requirements for the Phase I screening. Medium-sized facilities include the Coldwater, Missouri River, and Lower Meramec plants. The Coldwater WWTP solids quantities have been used to represent "medium-sized plant" requirements. The Grand Glaize and Fenton plants were not included in the Phase I screening evaluation. These two plants are scheduled to be decommissioned within the 20 year project time period. h. TM 8 -Summary of Prospect Hill Reclamation Facility Technical Memorandum (TM) No.8 is the evaluation of the Metropolitan Sewer District (MSD) Prospect Hill Reclamation Project disposal site existing conditions, permitted capacity and remaining disposal life estimate. The Prospect Hill Reclamation Facility is permitted as a special waste disposal area by the Missouri Department of Natural Resources under Solid Waste Disposal Area Operating Permit No. 0718905. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 26 The existing site conditions were indentified through research of MSD and MDNR's historic site files. The site's remaining capacity was evaluated by comparing the permitted final grading plan found in MDNR's files to a current topographic survey performed by a registered land surveyor. The remaining disposal life under the current Solid Waste Disposal Area Permit was estimated by determining a historical average annual disposal rate of 96,500 cubic yards and was calculated to be about 8 years. The remaining life can be further extended by using disposal options discussed in TM3. i. TM 9 -Report on Prospect Hill Remaining Life with Recommendations Technical Memorandum (TM) No.9 summarizes the evaluation of the Metropolitan Sewer District (MSD) Prospect Hill Reclamation Project disposal site remaining life and recommendations regarding findings on waste streams, quantities and characteristics, remaining life under the current landfill permit, landfill end uses, options for extending the landfill life through vertical expansion and impediments to landfill vertical expansion.TM9 utilizes the background information and conclusions developed in TM8 and builds on the information to evaluate realistic options for increasing the operational life of the Prospect Hill Reclamation Project Disposal site. Gredell Engineering evaluated two potential options for vertically expanding the existing landfill area: -The Moderate vertical expansion will yield additional estimated life of 8.4 years -The Aggressive vertical expansion will yield additional estimated life of 6.1 years The geologic and hydrologic characteristics of the Prospect Hill Reclamation Project site are acceptable for landfill development. Vertical expansion of an existing landfill for the purpose of gaining additional capacity and operating life is an accepted and common practice in Missouri's non- hazardous waste disposal business. j. TM 10 -Report on Potential Prospect Hill Replacement Sites Technical Memorandum (TM) No. 10 summarizes the evaluation of potentially finding and developing a future incinerator ash landfill as a replacement for the current Metropolitan St. Louis BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 27 Sewer District (MSD) Prospect Hill Reclamation Facility disposal site. The criteria used for the sites evaluation included: • Geological criteria for Missouri identified from readily available published information and input from the Missouri Department of Natural Resources Division of Geology and Land Survey (MDNR DGLS) on the St. Louis metropolitan area geology. • Geological criteria for Illinois identified from readily available published information from the Illinois Geologic Survey website. • A geographic search area limited to a 30-mile radius from the two MSD sludge incinerators locations (Bissell Point and Lemay Wastewater Treatment Plants) • A potentially available property size of 80 acres to 100 acres. 3. Summary of Phase 2 Technical Memoranda a. TM 1 –Bissell Point WWTP Solids Processing Alternatives Evaluation Technical Memorandum (TM) No.1 consists of information on the solids processing and management alternatives evaluated for the Bissell Point Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. TM No. 1 describes the existing biosolids management system, the solids quantities used as the basis for the evaluation, and the treatment options evaluated for Bissell Point. Numerous options were considered for solids handling and stabilization processes. Dewatering alternatives consisted of either re-using the existing belt filter presses, or replacing them with centrifuges. Incineration options consisted of continued use of the MHIs or replacement with FBIs, with options for advanced emission controls (AEC) should regulatory considerations dictate their inclusion. Extensive consideration was given to power generation and waste heat recovery. Overall, BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 28 two primary alternatives were developed, with a myriad of options and processes that could be considered within the context of each of these. These are summarized as follows: • Alternative B-1 – Re-use of MHIs and BFPs • Alternative B-2 – New FBI and Centrifuges Overall present worth costs for Alternative B-1 were lower, as might be expected. However, regulatory drivers later emerged that essentially rendered Alternative B-1 unfeasible since it could not be implemented without surpassing an investment threshold for the MHIs that would trigger near-unattainable emission limits. b. TM 2 - Lemay WWTP Solids Processing Alternatives Evaluation This Technical Memorandum presents information on the solids processing and management alternatives evaluated for the Lemay Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. TM No. 2 describes the existing biosolids management system, the solids quantities used as the basis of the evaluation, and the treatment options evaluated for Lemay. As with the Bissell Point plant, numerous options were considered for solids handling and stabilization processes for Lemay. Dewatering alternatives consisted of either re-using the existing belt filter presses, or replacing them with centrifuges. Incineration options consisted of continued use of the MHIs or replacement with FBIs, with options for advanced emission controls (AEC) should regulatory considerations dictate their inclusion. Extensive consideration was given to power generation and waste heat recovery. Overall, two primary alternatives were developed, with a myriad of options and processes that could be considered within the context of each of these. These are summarized as follows: • Alternative L-1 – Re-use of MHIs and BFPs BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 29 • Alternative L-2 – New FBI and Re-use of BFPs • Alternative L-3 – New FBI and New Centrifuges Overall present worth costs for Alternative L-1 were lower, as was expected. However, as noted before, regulatory drivers emerged that essentially rendered Alternative L-1 unfeasible since it could not be implemented without surpassing an investment threshold for the MHIs that would trigger near-unattainable emission limits. In the case of both Bissell Point and Lemay, the magnitude of costs being considered for replacing the MHIs with FBIs dictated the consideration of a regional facility. Also, in both cases, power generation and steam recovery options are dependent upon external markets to be immediately economically effective, and AEC options are entirely regulatory driven. c. TM 3 –Coldwater WWTP Solids Processing Alternatives Evaluation This Technical Memorandum presents information on the solids processing and management alternatives evaluated for the Coldwater Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. The Coldwater WWTP currently discharges solids to the collection system in the Bissell Point WWTP sewer shed. This concept has proven successful over the years although there has been some concern about the need for redundancy with the biosolids conveyance force main. Alternatives considered included the following: • Alternative C-1 – Continuation of the Existing Solids Management scheme • Alternative C-2 – Landfilling of Raw Dewatered Solids • Alternative C-3 – Anaerobic Digestion Continuation of current operations appears to be the most economically advantageous option for the Coldwater facility. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 30 d. TM 4 –Missouri River WWTP Solids Processing Alternatives Evaluation Technical Memorandum (TM) No.4 consists of information on the solids processing and management alternatives evaluated for the Missouri River Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. TM No. 4 describes the existing biosolids management system, the solids quantities used as the basis for the evaluation, and the treatment options evaluated for Missouri River. The Missouri River WWTP is uses anaerobic digestion for solids stabilization with energy recovery facilities. The plant is currently undergoing an upgrade to its biosolids facilities and as such, no major modifications are anticipated for the foreseeable future. With respect to alternatives evaluated for this plant, they consisted of: • Alternative M-1 – Continuation of Existing Solids Management Scheme • Alternative M-2 – FOG Co-Digestion Essentially, Alternative M-2 is a slight modification of the existing process in the event that the District was to locate FOG disposal facilities at this site. . e. TM 5 –Lower Meramec WWTP Solids Processing Alternatives Evaluation Technical Memorandum (TM) No.5 consists of information on the solids processing and management alternatives evaluated for the Lower Meramec Wastewater Treatment Plant (WWTP) as part of developing a strategic plan for long-term management of biosolids. Information on the existing facilities for the planning effort was obtained from existing plant records, interviews with MSD staff, and plant permits. TM No. 5 describes the existing biosolids management system, the solids quantities used as the basis for the evaluation, and the treatment options evaluated for Lower Meramec. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 31 The Lower Meramec WWTP is the most recently constructed wastewater treatment facility that the District operates (having gone on-line in 2007) and provides gravity thickening and dewatering with landfill discharge of its solids. No major improvements are anticipated for the foreseeable future for the plant within the constraints of its current watershed boundary. However, ultimate plans for the District consist of eliminating the Grand Glaize and Fenton WWTPs and conveying flow from those facilities to the Lower Meramec plant via the Baumgartner Tunnel extension. At that point, the District may consider adding anaerobic digestion to the facility, and possibly mechanical thickening as well. With respect to alternatives evaluated for this plant, they consisted of: • Alternative LM-1 – Anaerobic Digestion with Existing Gravity Thickening • Alternative LM-2 – Anaerobic Digestion with Mechanical Thickening of WAS Total present worth costs for Alternative LM-1 was approximately 10% less than Alternative LM-2, essentially making them near-equal alternatives within the framework and cost accuracy of a long- range study. . f. TM 6 –Regional Solids Processing Alternatives Evaluation Technical Memorandum (TM) No.6 consists of information on the solids processing and management alternatives evaluated for a Regional Biosolids Processing Facility considered as part of developing a strategic plan for long-term management of biosolids. Consideration was given to constructing a regional facility at either of the two largest plants (Bissell Point and Lemay) or locating a facility independent of these two plants. From a practical standpoint, locating a regional solids processing facility at the Bissell Point WWTP emerged as the overwhelming and logical choice. As with the Bissell Point and Lemay plants, numerous options were considered for solids handling and stabilization processes. However, given the quantity of solids to be processed at a regional facility, all new equipment, processes and facilities were assumed for long-range planning purposes. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 32 Incinerations with FBIs, along with options for energy and waste heat recovery, as well as advanced emission controls, were built into the overall assessment. Perhaps the biggest hurdle for a regional plant is determining the most optimum method for conveying solids from the remote facilities to the regional facility, and particularly so for the Lemay WWTP due to the volume of solids produced at that facility in comparison to the remaining treatment plants. Ultimately, two options emerged through considerable workshop evaluations with the entire team: 1) hauling solids from Lemay to the Regional Facility, and 2) Constructing a force main and pumping solids from Lemay to the Regional Facility. Both of these options were then compared across the District’s entire watershed system against making improvements to each treatment plant individually in lieu of a regional facility. Consequently, systematic options considered are summarized as follows: • Alternative S-1 – No Regional Facility • Alternative S-2 – Regional Facility with Lemay Hauling Solids to the Regional Facility • Alternative S-3 – Regional Facility with Lemay Pumping Solids to the Regional Facility Overall present worth costs for Alternative S-2 had the lowest present worth costs associated with it. However, within the realm of accuracy for a planning-level study, Alternative S-3 is essentially near equal in comparison. g. TM 7 – Review of Air Emission Requirements Technical Memorandum (TM) No.7 summarizes overall air emission requirements being considered as this overall master plan was being developed. It should be noted that at the time TM No. 7 was completed, final emission standards had not been published, and this memorandum was essentially an assessment of the impact of various outcomes that ultimately could prevail, and the considerations that would need to be made. In the months following the completion of TM No. 7, EPA ultimately published draft emission standards, then considered their impact through the public comment process, and subsequently enacted a final version of the standards (with revisions) on BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 33 March 21, 2011. This process resulted in a delay to the overall study schedule, so that the District could respond (along with other entities) to the proposed standards, and full consideration could be given to their impact on long-term plans for biosolids facilities. Final air emission standards are summarized and quantified in TMs 9, 10, and 11. h. TM 8 – Greenhouse Gas Emissions Technical Memorandum No. 8 provides a discussion and summary of greenhouse gas (GHG) emissions projected for each solids processing alternative considered for the current biosolids evaluation. Greenhouse gases have become widely recognized as significant contributors to global climate change. Major initiatives have already been undertaken as part of an overall global effort to curb the production of greenhouse gases and mitigate to as great an extent possible the impacts that global climate change could have in the 21st century. Global climate change is measured by significant changes in temperature or weather patterns that last for an extended period of time (measured in terms of decades). In general, greenhouse gases become entrapped when the sun’s radiation is partially absorbed by the earth and then reflected back to the atmosphere. Greenhouse gas molecules partially absorb the reflected radiation and re-direct it back to the earth; thus entrapping the energy within the atmosphere. i. TM 9 – Opinions of Costs for Alternatives Technical Memorandum (TM) No.9 presents the Engineer’s Opinions of Costs for construction, operations and maintenance, benefits with use of biosolids, and Present Worth costs. These costs are determined for the plant alternatives as defined in Technical Memorandums No. 1 through No. 6. Those alternatives were developed as part of Phase 1 of this study and refined as part of Phase 2 workshop conducted on June 2, 2010 and September 22, 2010. Additional comments and direction from the District regarding specific elements of these alternatives were reconciled in subsequent group discussions. BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 34 The costs presented in TM No. 9 are used for comparisons, evaluations and selections of alternatives as defined in Technical Memorandum No. 10 - Alternatives Selection Process and Results. Costs and cost factors were developed for use in assessing overall capital and operations/maintenance costs. Costs for equipment and materials used are based on the following components and assumptions: Support equipment and utilities including water supplies, electrical, and instrumentation and controls. • Building modifications, structural changes, new grating floors and access platforms for equipment. • Demolition of replaced equipment. • Instrumentation and controls to support new or modified equipment. • Manufacturer vendor quotes for significant equipment. • Engineer’s experience with similar projects, including power generation boilers and emissions controls. • Quantity take-offs and unit costs. • In cases where existing belt filter presses are being retained, costs include maintenance repairs and overhauls for the existing presses through the life of the project. • In cases where existing incinerators are being retained, costs include new wet scrubbers to replace existing scrubbers. Construction and design factors are applied to capital costs to generate total expected project costs. Capital costs include equipment, buildings, sitework, electrical, instrumentation, contingency, construction management/general conditions, bonding and insurance, and engineering costs j. TM 10 – Alternatives Selection Processes and Results Technical Memorandum (TM) No.1 presents information on the Triple Bottom Line (TBL) evaluation methodology, criteria, and weighting factors for the Phase II evaluation. A TBL BLACK & VEATCH St. Louis MSD Phase II B&V Project 165186 Executive Summary – Phase 1 and Phase 2 December 10, 2011 MSD Contract No. 2009145 B&V File 44.000 35 evaluation was previously performed for the Phase I screening process. The TBL methodology is similar to that used in the Phase I screening; however, suggested criteria and criteria weights have been adjusted to better reflect the decision-making factors associated with the Phase II process. The TBL approach and representative results for the alternatives evaluation are presented. Alternatives and options are described in the respective TM’s for each plant. Refer to TM’s No. 2 through No. 6. Air emission requirements, greenhouse gases, and overall project costs are addressed in TM’s 7 through 9. i. Triple Bottom Line Criteria and Weights As with the TBL process employed during the Phase I evaluation, the Phase II TBL process is based on the following three general categories: • An “economic” component that reflects the cash flow accounting stance of the utility (i.e., internal costs and revenues) • A “social” component that reflects the social impacts of the utility action (e.g., minimizing nuisance impact to the local community such as truck traffic, odor, and noise from plant operations.) • An “environmental” component that addresses environmental impacts of the utility actions and decision, such as reducing Green House Gas (GHG) emissions by reducing fossil fuel use and electricity purchases. k. TM 11 – Phasing and Implementation of Selected Alternatives Technical Memorandum (TM) No.11 summarizes a final phasing and implementation plan based on a triple bottom line assessment of various alternatives, with consideration given to regulatory drivers as well. The Overall Summary at the beginning of this Executive Summary quantifies final results and conclusions of this technical memorandum.