Introduction
Dredging at Waukegan Harbor on Lake Michigan is a complicated matter. PCB contamination of inner harbor sediments and relatively clean sediments moving along the lakeshore have together raised some interesting dredging and disposal issues. For nearly three decades, navigation-related dredging has not happened in the inner harbor thus forcing commercial vessels to operate at uneconomical drafts. The sediment problem and its remediation, as well as disposal of other less contaminated material, have been factors influencing the dredging situation. Even the federal Superfund program relates to the dredging decision-making process at this Illinois port. Its status as an Area of Concern (AOC), with a committed Waukegan Harbor Citizen's Advisory Group and increasing attention from federal and state agencies augurs favorably for a solution to its dredging and sediment problems.

Outer Harbor
The harbor at Waukegan is located midway between Chicago and Milwaukee. The harbor entrance or outer harbor silts in on a continuing basis due to littoral drift of sand from beaches north of the harbor entrance. The clean sand is removed as outer harbor maintenance and is disposed of in open water at "Sand Mountain," located about 2000 feet south of the harbor entrance in 6 to 12 feet of water. The Corps of Engineers indicates that dredging volume ranges from 30,000 to 50,000 cubic yards per year. The cost in 1998 for dredging 39,000 cubic yards was $375,000. A potential beneficial use of this material has been discussed whereby the sand would be redeposited as beach nourishment at Illinois State Beach Park or at a dune area near Waukegan City Park.

Inner Harbor
A unique feature of Waukegan Harbor is that it is a "slack harbor," as compared to many other Great Lakes harbors that are outlets for rivers or streams carrying sediments. In those cases where sediments are confined to a particular area and do not accumulate very quickly, dredging can usually be accomplished without much difficulty. However, in Waukegan's inner harbor case, navigation-related dredging last occurred in 1972. A principal problem was the discovery of serious PCB contamination of sediments resulting from prior industrial activity. The designation of part of the harbor bottom as a federal Superfund site led to a sediment remediation project in which 300,000 pounds of material were dredged, heat treated and placed in nearby sediment containment cells - completed in 1994. The widely-acclaimed result was a 90 percent reduction in the PCB contamination. One positive outcome was the removal of the Waukegan Harbor fish consumption advisory in 1997.

The remaining PCB contamination has complicated the commercial navigation dredging process for Waukegan Harbor but other factors contributed. A parallel issue was the need to confine the remaining material to be dredged from the inner harbor. The Waukegan Port District, with limited financial capacity, and the Corps of Engineers had been unable to agree on a local sponsorship agreement for a disposal option. Since no conventional confined disposal facility (CDF) exists, one would have to be built with a local cost share or some other innovative solution would have to be considered.

Implications for Commercial Navigation
The inner harbor is authorized for a commercial navigation depth of 23 feet but is now at 16-17 feet. Major users of the port include building product manufacturers that rely on waterborne transport and recreational boaters. For those commercial vessels making Waukegan port calls, the restricted draft translates into inefficient operations with an up to 40 percent reduction in potential cargo capacity. This circumstance often requires vessels to off-load cargoes in Milwaukee in order to visit Waukegan. Other factors complicate decisions to off-load cargoes such as Lake Michigan water levels and wind direction. For example, a sustained easterly wind can raise harbor levels by a number of feet. These issues pertain to the economies obtained through shipping by water as well as safe vessel operation.

A Possible Solution
The Corps of Engineers has completed a reconnaissance report for the harbor dredging project which estimates that 300,000 cubic yards of coarse grain sand, sediment, and clay would be placed in either an upland or in-lake CDF. As the harbor is deepened, the Corps estimates that dredging would reach a layer of uncontaminated clay that can be used as a cap for the CDF. One identified site is a thirteen-acre in-lake area south of the Waukegan Port District marina which was recommended in earlier studies. A second site is upland at the vacant Johns Manville (JM) property. This property has an asbestos-contaminated Superfund site containing a sizeable settling pond that could accommodate the harbor material as well as JM building demolition debris. JM sees the dredged material as a source of filling and capping material that would also yield savings for the dredging project. The Waukegan Harbor Citizen's Advisory Group, the Corps, U.S. EPA and the state are presently discussing the JM site as a favored alternative to the in-lake CDF.

Regulatory Issues
For the Waukegan Harbor situation, there has been considerable discussion about the differences between state and federal regulations applying to dredged material. If the material is considered polluted at any level, upland disposal falls under State of Illinois solid waste regulations. In addition, disposal of dredged material with low level contaminants such as the harbor's estimated 1-11 ppm of PCBs at an existing Superfund site complicates the U.S. Environmental Protection Agency's regulatory agreements in managing the site. Also, the local sponsor of the CDF could have a financial liability if the CDF does not perform to either state or federal standards. This liability issue has created a new market in the insurance industry for liability protection for a CDF sponsor. This new insurance "tool" is considered a costly "must" in planning for this type of CDF. The Waukegan Harbor dredging project is a prime opportunity to review the need for regulatory change and improve coordination between states and the federal government.

Conclusion
In summary, this dredging project will help Waukegan gain an efficient port and conceivably investment in new port facilities. Waukegan can achieve de-listing as an AOC and improve its prospects for redevelopment. Beneficial use of dredged material can improve a Superfund site with cost savings at the site and for the dredging project. The City will gain from a well-coordinated and comprehensive plan for improving valuable lakefront property. If regulatory obstacles can be overcome, the dredging of contaminated sediments, from the inner harbor will result in widespread and lasting benefits to the area and its residents.

Note: This case study was prepared during the summer of 1999.

For further information:
Jean B. "Susie" Schreiber
Chair
Waukegan Harbor Citizen's Advisory Group
152 Glenwood Ave.
Winnetka, IL 60093
Phone: 847-835-2517
E-mail: jschreiber@ameritech.net

Mary Walker
Port Manager
Waukegan Port District
P.O. Box 620
55 S. Harbor Place
Waukegan, IL 60079
Phone: 847-244-3133

Steve Thorp
Great Lakes Commission
Eisenhower Corporate Park
2805 S. Industrial Hwy, Suite 100
Ann Arbor, MI 48104-6791
Phone: 734-971-9135
Fax: 734-971-9150
E-mail: sthorp@glc.org