BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

)

)

NATURAL GAS-FIRED, PEAK-LOAD

)

R01-10

ELECTRICAL POWER GENERATING

)

FACILITIES (PEAKER PLANTS)

)

WRITTEN TESTIMONY

TO:

Ms. Dorothy M. Gunn

Amy L. Jackson, Esq.

Clerk of the Board

Hearing Officer

Illinois Pollution Control Board

Illinois Pollution Control Board

James R. Thompson Center

600 South Second Street

100 West Randolph Street

Suite 402

Suite 11-500

Springfield, Illinois 62704

Chicago, Illinois 60601

Enclosed please find written testimony of Mr. Richard Trzupek in the above

referenced matter. An original and nine copies are enclosed.

Respectfully submitted,

___________________________

Richard Trzupek

Air Quality Manager

Huff & Huff, Inc.

Dated: August 15, 2000

Richard Trzupek

Air Quality Manager

Huff & Huff, Inc.

512 W. Burlington Ave.

Suite 100

La Grange, IL 60525

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Introduction

1. The purpose of this testimony is to address two areas of concern in regard to

the peaker plant issue now before the Illinois Pollution Control Board (“the Board”).

These areas are: 1) the overall environmental effect of peaker facilities, in the context of

comprehensive environmental and energy policy, and 2) the health risk represented by air

borne emissions from these facilities.

2. I am Richard Trzupek, currently employed as Air Quality Manager with Huff

& Huff, Inc., an environmental consulting firm primarily serving industrial customers,

including peaker plant developers and operators. I am a chemist with 18 years of

experience in air quality management and am professionally qualified to comment on air

pollution issues. A summary of my qualifications is attached as Exhibit A.

Assumptions

3. In preparing this testimony, I have made the following assumptions:

a) The peaker plants in question are powered by natural gas fired turbines

between 25 MW and 250 MW in size.

b) The natural gas fired turbines used employ either dry low NOx control

or water injection to achieve NOx emissions of 9 ppmvd or less, at 15

% oxygen, in simple cycle. This emission rate is equivalent to Best

Available Control Technology (BACT) for these units.

c) That oil firing, for which some turbines is permitted as an emergency

back up, will be rarely employed, owing to the reliability of natural gas

supplies in the midwest. Emissions resulting from oil firing are not

considered in this analysis.

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d) The emissions of other pollutants from gas turbines quoted, as well as

emissions from other power generation sources (units powered by

coal, oil and jet fuel) have been derived from USEPA AP-42 data.

The reader will note that emission rates for individual units will vary.

For the sake of conducting reasonable comparison, broad assumptions

have been made regarding these emissions rates. While these

assumptions may not hold true in each individual case, it is my belief

that they present a reasonable approximation of the general case,

consistent with observed emissions inventory data. Assumed

emissions rates are quoted in relevant exhibits.

Environmental Effects – Background

4. In considering the effect that peaker plants have on the environment, the Board

should consider airborne emissions from these sources in the context of the midwest

power market. That is to say that, on any given day, there will be a finite amount of

electric power demand. This demand must be satisfied by some combination of regional

energy resources. The extent of the role of peaker plants in meeting this demand will

have a significant effect on air quality in the region, to the extent that these plants are

preferentially built and utilized, or to the extent to which other sources of power are used

to meet that demand.

5. The nation’s electric grid is subdivided into several North American Electric

Reliability Council (NERC) regions. Illinois is part of the Mid-America Interconnected

Network (MAIN), a region which also includes most of Wisconsin as well as smaller

parts of eastern Missouri and the Upper Peninsula of Michigan.

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6. When considering electric demand, it is most useful to consider MAIN as a

starting point. It is an over-simplification to say that power can be distributed freely

throughout MAIN – the complexities of power transmission require a relatively even

distribution of power relative to centers of demand – but the region does represent a

semi-autonomous network within which power demand may be reasonably assessed.

7. It will also be noted that, to some extent, power may be exported from MAIN

to the five regions surrounding it (MAPP, ECAR, SERCW, SPP and TVA). However,

power export is physically limited by the capacity of interconnecting long transmission

lines. (A simplified schematic of MAIN and connectivity to surrounding NERC regions,

published by MAIN, is attached as Exhibit B). More importantly, power export to other

regions will result in transportation costs which economically limit the practice to a small

fraction of total power output. Because power export is a relatively insignificant source of

demand, the practice has not been considered in this analysis. However, if the Board

wishes to confirm this fact, I would suggest an examination of power sales records

available through Federal Energy Regulatory Commission (FERC).

8. Within MAIN, according to its council’s latest report, the forecast peak load

level for the summer of 2002 has been estimated at 50,675 MW. A copy of MAIN’s

2002 forecast summary is attached as Exhibit C.

9. Peak utility summer power generation capacity within MAIN, according to

FERC data, is 50,260 MW. A summary of utility power generation sources in MAIN,

taken from FERC reports, is attached as Exhibit D. This total does not include co-

generation sources, nor does it include independent power producers (IPPs) who are the

owners of many peaking facilities. The utility total of 50,260 MW capacity does,

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however, include a great many utility peaking units, such as jet engines, older stationary

turbines and internal combustion engines, which are rarely utilized.

10. In comparing peak demand to peak generation capacity, it is important to note

that, in order to achieve stability of the grid, most power experts recommend that excess

capacity of 20 to 30% is needed. If generation capacity were to exactly equal demand, it

is very unlikely that power could be evenly and reliably distributed. Rather, as demand

approaches capacity, local brown outs and black outs occur more frequently, as has been

seen in the midwest in recent summers.

11. If a 25% “cushion” were the target, total generation capacity in MAIN should

be about 63,000 MW. Exact requirements should, however, be discussed with an expert

in the field, such as a representative of MAIN. For the purpose of evaluating the effect of

peaker plants on the regional environment, I have assumed a peak demand of 50,675 MW

and have not assumed any reserve generation. While this is an unrealistic picture, it

serves to illustrate the relative effects of peaker plants and will, it is hoped, help to

establish a methodology by which power plant emissions can be fairly evaluated in the

context of electric demand.

Environmental Effects – Regional

12. Currently, utility based electric power in MAIN is generated by nine basic

sources of energy: coal, light oil (#1 or #2 fuel oil), heavy oil (#6 fuel oil), natural gas,

nuclear, hydro, wind and “other” (minor, unidentified sources). A breakdown of current

generation capacity, by fuel type, within MAIN is as follows:

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TABLE 1

MAIN Power Generation Capacity

Summer

Capacity

(MW)

% of Total

Coal

27,936

55.6

Light Oil

1,612

3.2

Heavy Oil

406

0.8

Jet Fuel

369

0.7

Natural Gas

5,667

11.3

Other

32

0.1

Nuclear

13,283

26.4

Hydro

953

1.9

Wind

2

0.0

TOTAL:

50,260

13. The air pollution potential of each of these sources of energy may now be

considered. Using AP-42 factors, maximum emissions of three pollutants have been

calculated: nitrogen oxides (NOx), sulfur dioxide (SO

2

) and particulate matter (PM).

There are, of course, other pollutants that may be examined, but these three are

representative for the purposes of this analysis. Maximum potential emissions of these

three pollutants have been calculated for the five month ozone season (May 1 through

September 30). This period was chosen as that of most immediate environmental

importance, given the EPA’s focus on reducing ozone precursors during those months.

Emissions potentials for MAIN utility sources are as follows:

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TABLE 2

Maximum Emissions Potential

Fuel Type

Emissions

(tons/season)

Emissions

PM Emissions

(tons/season)

Coal

256,448

102,579

20,516

Light Oil

7,693

1,154

462

Heavy Oil

2,423

19,381

194

Jet Fuel

2,035

51

122

Natural Gas

8,739

437

1,020

Other

NA

NA

NA

Nuclear

NA

NA

NA

Hydro

NA

NA

NA

Wind

NA

NA

NA

TOTAL:

277,337

123,602

22,313

14. A comparison may now be made in which 10,000 MW of coal generation

capacity is replaced by gas turbine generation capacity:

TABLE 3

Maximum Emissions Potential

MAIN Utility Sources,

Fuel Type

Emissions

(tons/season)

Emissions

PM Emissions

(tons/season)

Coal

164,648

65,859

13,172

Light Oil

7,693

1,154

462

Heavy Oil

2,423

19,381

194

Jet Fuel

2,035

51

122

Natural Gas

24,162

1,208

2,819

Other

NA

NA

NA

Nuclear

NA

NA

NA

Hydro

NA

NA

NA

Wind

NA

NA

NA

TOTAL:

200,960

87,653

16,768

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15. As would be expected, a comparison of Tables 2 and 3 shows a significant

environmental benefit to the region by substituting natural gas for coal. In this example

NOx emissions are reduced 27%, SO

2

by 29% and PM by 25%. Complete calculations

and graphical presentations of this data are attached as Exhibit E. There would be further

reductions in other air pollutants in this scenario, as well as substantial reductions in

liquid and solid waste generation.

0

50,000

100,000

150,000

200,000

250,000

300,000

NOx

SO2

PM

tons/season

MAIN, Base Case

MAIN, with IPPs

FIGURE 1

MAIN Emissions Comparison

Base Case, With and Without IPPs

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Page 8

16. While one may argue about the exact magnitude of emissions reductions as

gas turbines take up more of the power generation load, it is undeniable that such

reductions take place. There is, on a daily basis, a finite demand for power within MAIN.

This demand must be met, by some means. In allowing the continued construction of gas

turbine fired facilities, unencumbered by the burden of additional environmental rules

that go beyond the strict and effective regulatory structure to which these facilities are

already subject, the Board will allow the environment to continue to realize more and

more of the benefits inherent to the ultra-clean nature of these units.

17. Peaker plants should not be viewed as adding to air pollution. Rather, they are

an integral part of reducing pollution. Demand will always determine how much

electricity is generated. Is it not in everyone’s best interests that the cleanest generating

units are available to meet as much of that demand as possible?

Environmental Effects – Statewide

18. In considering the environmental effects of peaking plants within the state of

Illinois, the type of analysis described above will, of course, continue to hold true.

However, impending NOx reduction regulations under development by the Illinois EPA,

serve to further emphasize how important these facilities are to the state’s economic and

environmental health.

19. Illinois EPA’s proposed Subpart W regulations will reduce statewide NOx

emissions from Electric Generating Units (EGUs) to a little over 30,000 tons per ozone

season. These rules will further accentuate how important peaker plants are in the

context of providing clean power to the state and its citizens.

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20. A rough approximation of current, utility based emissions of NOx, SO

2

and

PM can be made through the use of FERC generation data and by assuming certain

utilization rates. This example assumes an average summer day’s generation rate of

approximately 22,500 MW. Again, FERC data can be researched to further refine that

assumption, if desired. Table 4, below, summarizes this data. (It should be noted that

FERC does not list any hydro, wind or “other” power sources in its Illinois utility

database).

TABLE 4

Illinois Utility Based Emissions, Base Case

Summer

Capacity

Assumed

Utilization

Emissions

(tons/season)

Emissions

(tons/season)

Emissions

(tons/season)

Coal

15,358

70%

98,691

39,476

7,895

Light Oil

363

30%

520

78

31

Heavy Oil

406

70%

1,696

13,567

136

Jet Fuel

369

10%

203

5

12

Natural Gas

3,953

70%

4,268

213

498

Other

0

0

NA

NA

NA

Nuclear

10,646

80%

NA

NA

NA

Hydro

0

0

NA

NA

NA

Wind

0

0

NA

NA

NA

TOTAL:

105,378

53,339

8,572

21. The NOx reductions called for in Subpart W will be realized in the form of a

trading program that will, in effect, place a “hard cap” on EGU NOx emissions. This cap

will apply to EGUs over 25 MW, and will include both utility power generation sources

as well as IPPs. Thus, a second level of control on utility emissions will be layered atop

the “natural cap” implied by the demand factors described earlier. Given the existence of

a hard NOx cap, power generators will not only have to meet demand, they will have to

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do so without exceeding available NOx trading allocations. In this scenario, EGUs with

low NOx emissions rates, such as gas turbines, are vitally important.

22. Under the trading program, the target NOx emission rate for most fossil-fired

EGUs will be 0.15 lbs NOx/mm BTU heat input. In practice, lower heat input rates will

probably be realized, but this target rate allows for a simple comparison. The following

table assumes that coal and oil fired sources meet this target NOx emission rate. Natural

gas fired sources, believed to consist primarily of gas fired turbines, are assumed to emit

NOx at a rate of 0.06 lbs/mm BTU heat input. This rate corresponds to an average of 15

ppmvd NOx at 15% O

2

, a conservative assumption given the current BACT rate for

peakers of approximately 0.04 lbs/mm BTU.

TABLE 5

Illinois Utility Based Emissions, NOx SIP Case

Summer

Capacity

Assumed

Utilization

Emissions

(tons/season)

Emissions

(tons/season)

Emissions

(tons/season)

Coal

15,358

70%

29,607

39,476

7,895

Light Oil

363

30%

390

78

31

Heavy Oil

406

70%

1,017

13,567

136

Jet Fuel

369

10%

203

5

12

Natural Gas

3,953

70%

4,268

213

498

Nuclear

10,646

80%

NA

NA

NA

TOTAL:

35,486

53,339

8,572

23. Table 5 details emissions considering only Illinois utility sources listed in

FERC’s database. This scenario meets the demand requirement of 22,500 MW in the

state that was used to construct Table 4. It can be seen that utility NOx emissions are

reduced over 65%, while emissions of SO

2

and PM remain unchanged.

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24. The next scenario assumes that approximately 14,000 MW of IPP gas turbine

generation capacity has been added to the state’s EGU inventory. Utilization of all units

is reduced by about half in order to match assumed 22,500 MW demand. These

conditions result in the following ozone season emissions scenario:

TABLE 6

Illinois Utility Based Emissions, NOx SIP Case

Summer

Capacity

Assumed

Utilization

Emissions

(tons/season)

Emissions

(tons/season)

Emissions

(tons/season)

Coal

15,358

37%

15,544

20,725

4,145

Light Oil

363

16%

205

41

16

Heavy Oil

406

37%

534

7,122

71

Jet Fuel

369

5%

107

3

6

Natural Gas

21,953

37%

12,442

622

1,452

Nuclear

10,646

80%

NA

NA

NA

TOTAL:

28,832

28,513

5,691

25. It will be seen that, under this scenario, NOx emissions drop 19% below the

EGU targets listed in Table 5. Further more, there is also a drop of SO

2

emissions of over

45% and a PM emissions reduction of over 30%. The aforementioned reductions in

liquid and solid waste reductions are also realized. Additional detail involved in these

calculations are attached as Exhibit F.

26. It may be argued that the above scenario is unrealistic – that utilization of

cheap coal fired power will never drop as low as 37%. That may or may not be true,

depending to some extent on the added costs of NOx control imposed on coal fired

sources. However, this example does illustrate a fact that can not be contested: that the

presence and increased utilization of gas-fired turbine generation capacity will only

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improve the state’s environment. The limiting factors of demand and a hard NOx cap in

the state guarantee this will be so.

Conclusions – Environmental

27. The above analysis supports the conclusion that no additional environmental

regulations are justified in regard to peaker plants specifically, or gas turbines in general.

Extensive restrictions and requirements within the present environmental structure

0

20,000

40,000

60,000

80,000

100,000

120,000

NOx

SO2

PM

tons/season

Base Case

NOx SIP, no IPPs

NOx SIP, with IPPs

FIGURE 2

Illinois Emissions Comparison

Base Case, With and Without IPPs

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Page 13

(which the author assumes have been reviewed in detail by other industrial commentators

as well as the Illinois EPA) are doing their job. These rules have resulted in a new

generation of ultra-clean, efficient gas turbines , the proliferation of which is wholly

consistent with the state’s – and the country’s – environmental goals.

28. If environmentally motivated impediments are placed in the way of these

plants, impediments which either prevent their construction (a moratorium) or add

additional costs of operation (by requiring additional and unnecessary controls), the net

effect in the state and in the MAIN region will be to satisfy more of demand through the

use of coal-fired sources. While coal technology has made massive strides toward

becoming a cleaner fuel, it can not be as clean as natural gas. Therefore, restriction of

gas-fired turbine construction will have the unintended consequence of making it more

difficult for the state to meet both energy demand and air quality goals.

29. Finally, it has been emphasized throughout this section that the analyses

presented above is not intended to be a definitive study. In contains data which may be

refined and assumptions which may be modified. In presenting this methodology to the

Board, my intent is illustrate the principles I feel are important, as well as to offer a

means by which energy and environmental policy may be reconciled in the course of

further study. For it is, undoubtedly, both energy and environmental policy that the Board

will be examining in the course of these hearings. Any attempt to detach the two, will, I

feel, result in serious damage to one, the other, or both.

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Inhalation Risk Issues – Background

30. It is assumed that the issue of inhalation risk associated with peaking plants

will have been addressed in detail by other industrial commentators and by the Illinois

EPA. Accordingly, it is not my intention to delve into this matter in great detail.

31. Risk is an issue that has been sometimes raised in conjunction with these

plants, to the alarm of some localities near which they may be located. On its face, to any

disinterested observer with a technical background, raising the issue of inhalation risk in

regard to natural gas fired sources is a ludicrous concept. If the combustion of natural gas

represents an unacceptable level of inhalation risk, there are few industrial sources – and

no combustion sources – that would not present a far greater danger.

32. It should be noted that USEPA is developing Maximum Achievable Control

Technology (MACT) standards for many combustion sources, including gas turbines, as

part of its efforts to fulfill the requirements of Title III of the Clean Air Act Amendments

of 1990. It is my professional opinion that, with the possible exception of increased

control of certain toxic metal emissions from coal combustion sources, the Agency will

find no justification for any further controls of these sources beyond existing good

combustion practices. In addition, it is also my professional opinion that very few, if any,

natural gas turbine sources would emit toxic air pollutants in sufficient quantity (10 tons

per year of a single Hazardous Air Pollutant (HAP) or 25 tons per year of a combination

of HAPs) to trigger MACT requirements.

Inhalation Risk - Principles

33. In terms of toxic risk, it is maximum ground level exposure that is of primary

importance to the surrounding community. This principle is poorly understood by many

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individuals for whom a peaker plant proposal represents their first real experience in the

complex science of risk assessment.

34. It is an indisputable fact that equivalent amounts of an air pollutant will result

in much different exposures, and therefore risk, depending on the height at which that

pollutant is first introduced into the atmosphere, the buoyancy of the exhaust gas stream

(chiefly related to gas stream temperature and velocity) and the distance to potentially

affected individuals. While I would judge neither to be at all dangerous, the average

person faces far more risk from 5 tons of toxic emissions dispersed by trucks and

automobiles on the expressway than he does from the same 5 tons of toxic emissions

dispersed at 1000 degrees Fahrenheit from a gas turbine stack over 100 feet high.

Furthermore, if such a study were undertaken, I strongly suspect that it could be shown

that the average person attending a meeting to protest a gas turbine installation exposes

himself or herself to far more toxic inhalation risk on the drive to and from the meeting

than the gas turbine would ever represent to him or her.

35. In order to determine maximum ground level exposures, USEPA models are

commonly used. ISCST3 is the model most often used for purposes of Prevention of

Significant Deterioration (PSD) permitting. It is a well-established model whose

accuracy in predicting maximum local concentration has been accepted by USEPA and

most, if not all, state agencies.

Inhalation Risk - Examples

36. A few examples will serve to illustrate the irrelevance of the toxic risk issue

with regard to gas turbine sources. Three pollutants have been chosen for comparative

purposes. These are: NOx (a criteria pollutant), benzene (a HAP) and Polyaromatic

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Hydrocarbons (PAH, a class of HAPs). There are many, many other examples which

could be used, but I believe that these three will be sufficient to illustrate the principle.

37. Emissions from a typical turbine installation will first be considered. The

proposed Grande Prairie Energy facility submitted a substantial amount of ISCST3

modeling data to the state and to the local community (Bartlett) in which it is to be

located. This data was developed for Grande Prairie by Goodwin Environmental

Consultants, Inc. of Springfield, Illinois and Diegan and Associates of Libertyville,

Illinois. Grande Prairie is a planned 1500 MW gas turbine facility, consisting of a mix of

simple cycle and combined cycle capacity. It is on the large end in the spectrum of gas

turbine installations, so it will serve as a good “worst case” example.

38. NOx emissions from the built-out Grande Prairie facility result in a modeled

maximum ground level NO

2

concentration of 0.28

μg/M

3

. This concentration may now

be compared to a few convenient points of reference: a) the National Ambient Air

Quality Standard (NAAQS) for NO

2

, which serves as USEPA’s definition of the

maximum amount of this pollutant that can be present in a clean atmosphere; b) average

NO

2

concentrations detected by ambient air monitors in the state of Illinois in 1998; and

c) the PSD significance level, which is the concentration which officially causes alarm

under the PSD regulations. The comparison is as follows:

TABLE 7

NOx Risk Comparison

Source

NO

2

Concentration,

(mmg/cubic meter)

NAAQS Standard

100

Illinois Average, 1998

42

PSD Significance Level

25

1500 MW Plant

0.28

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39. It is clear, from Table 7, that the level of NOx exposure risk associated with

this project is infinitesimal. People are exposed to far more NOx in their everyday lives

than this admittedly large project will ever expose them to.

40. Benzene is considered next. In this case, the basis of comparison must be

different, since different monitoring and regulatory programs apply. The points of

reference used are: a) the average benzene concentration detected at the Northbrook

monitoring station between June and August of 1998, representing typical summertime

urban ambient air concentrations; b) the rural ambient air background average; and c)

USEPA’s Human Health Risk Based Criteria.

TABLE 8

Benzene Risk Comparison

Source

Benzene Concentration,

(mmg/cubic meter)

Northbrook Average, (June – August, 1998)

5.75

Rural Background Average

0.32

US EPA Risk Based Criteria

0.22

1500 MW Plant

0.00172

41. Finally, PAH’s are considered. Urban and rural background averages provide

available points of reference.

TABLE 9

PAH Risk Comparison

Source

PAH Concentration,

(mmg/cubic meter)

Urban Background Average

0.15

Rural Background Average

0.02

1500 MW Plant

0.00219

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42. More comprehensive studies, using other pollutants and modeling different

sizes and configurations of plants can be undertaken, but it is my belief that such efforts

will inevitably lead to the same conclusions that can be drawn from the above data: gas

turbines are among the least significant sources of inhalation risk to which the public is

exposed on a day to day basis.

43. Finally, the issue of risk can also be considered by examining the different

rates at which sources emit pollutants. In this context, as was the case in the

environmental analysis presented in the first part of this testimony, gas turbines rate as

among the best, if not the best, of all combustion sources. A comparison of published

emission rates for gas turbines and diesel engines, for the three pollutants examined

above, illustrates the point:

TABLE 10

Emission Rate Comparison

Source

Diesel Engines

Gas Turbines

NOx Emission Rate, (lbs/mm BTU)

1.9

0.04

Benzene Emission Rate, (lbs/mm BTU)

0.00078

0.000012

PAH Emission Rate, (lbs/mm BTU)

0.00021

0.0000022

44. This comparison is not meant to raise alarm about diesel engines emissions.

The fact that we largely meet our air quality goals demonstrates that these common

sources do not, for the most part, burden the environment. It is rather to illustrate one

final time the insignificance of natural gas fired turbine emissions. A more complete

presentation of risk data, including comparative charts, is attached as Exhibit G.

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Conclusions

45. I hope that the above discussion serves some role in helping the Board to

conclude what I firmly believe: that the influx of natural gas fired turbines in the state of

Illinois, as in other states, represents valuable environmental progress. They produce

virtually no solid waste, innocuous liquid waste streams and virtually the cleanest air

emissions possible from a combustion process. These ultra-clean units have been

developed, in large part, because of environmental concerns.

46. The fact that industry responded with this technology is proof that

environmental regulations are doing their job. To impose additional rules on these units,

or worse, to declare a moratorium on their construction, would be to send exactly the

wrong signal to industry. Why develop clean, efficient technology if the response to such

innovation is to call a halt to progress?

47. It is my belief that the communities that have accepted these facilities are

playing an important part in continuing 30 years of environmental progress. Just as we

made massive reductions in particulate, lead and sulfur dioxide emissions in the past, so

now we are poised to make massive reductions in NOx emissions without sacrificing the

reliability of the electrical grid. Communities who are part of this effort are helping

Illinois to reach a brighter tomorrow, both economically and environmentally.

48. Communities which reject these projects – which they certainly may do

through the use of local zoning ordinances – choose not play such a role. That is

certainly their right, but it would be wrong for the Board or the legislature to provide

them with a spurious environmental excuse for doing so.

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49. Finally, I would like to conclude by paying a well-deserved compliment to the

Illinois Environmental Protection Agency. Although they are too often the target of

derision from both industry and the public alike, and although I frequently negotiate with

them in an adversarial role, I have nothing but respect for the men and women who make

up the Agency. As a consultant who has dealt with many state agencies in nearly twenty

years of practice, I know of none who are able to fulfill their stewardship over the

environment so well while, at the same time, recognizing the legitimany of the state’s

economic needs.

50. The state’s environmental record is something Illinois can be proud of, a

record Don Sutton, Chris Romaine and all of the men and women in the trenches at IEPA

have played a large, unsung part in developing and maintaining. Gas turbine power

represents a giant step in continuing that progress. I, for one, hope that Board does

nothing to stifle it.

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Exhibit A

Richard Trzupek Qualifications

---

Richard Trzupek

Qualifications Statement

Richard Trzupek is the Air Quality Manger of Huff & Huff, Inc. (“Huff & Huff”).

Huff & Huff is an Illinois Corporation with its principal place of business located at 512

West Burlington, Suite 100, LaGrange, Illinois 60525. Huff & Huff is an environmental

consulting firm specializing in air and water quality engineering, testing and regulation.

Richard Trzupek has a Bachelor’s degree in Chemistry from Loyola University of

Chicago, including courses of instruction in chemistry, physics, mathematics and

engineering. He has been employed in the field of air quality management since 1982.

He has been trained in the sampling and analytical techniques involved in USEPA air

emissions test methods, including Methods 1, 2, 3, 4, 5, 5B, 5F, 6, 6C, 7, 7E, 8, 9, 10, 11,

12 and other federal and state air emissions test methods.

Mr. Trzupek has extensive experience in the field of air quality permitting and

regulation as it applies to electric generating units, including gas turbines and peaking

plants. He has provided consulting services in regard to power projects for, among

others, People’s Energy, Dominion Energy, Elwood Energy, Detroit Edison and Entergy.

Mr. Trzupek is a past Director of Air Quality for the Lake Michigan States Section of

the Air and Waste Management Association (AWMA), the leading international

organization for environmental professionals. He is also a contributing author to the

Analytical Methods section of the “Odor and VOC Control Handbook” (McGraw Hill,

1998, Harold J. Rafson Editor) and is currently under contract to produce an air quality

handbook for McGraw Hill.

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He has written numerous articles about air quality issues for environmental

publications and have lectured on air test methods and air quality issues for numerous

organizations including, USEPA, AWMA, Executive Enterprises and the Graphic Arts

Technical Foundation. Mr. Trzupek’s current resume, including a summary of articles

and presentations, is attached.

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RICH TRZUPEK

Air Quality Manager

Huff & Huff, Inc.

Education:

Loyola University, Chicago, Illinois

Bachelors Degree in Chemistry

Experience:

Mr. Trzupek has been involved in the air quality field since 1982. He has worked with a

wide variety of industries, including the petrochemical, utility, steel, graphic arts, metal

finishing, synthetic organic chemical, consumer products, automobile and food

processing industries.

He has served as an expert witness for a variety of testing and permitting issues, as well

as providing other types of litigation support. His consulting experience not only

includes air pollution, but involves analyzing the business, community and environmental

concerns inherent to industrial projects. Mr. Trzupek is frequently called into projects

during the conceptual stage to provide strategic advice and to facilitate communication

between stakeholders.

He has testified before the Illinois Pollution Control Board and the Illinois Environmental

Protection Agency. He has participated in the development of environmental rules,

including: Illinois’ VOM trading program, Illinois’ NOx SIP rules, USEPA’s air toxics

program and the South Coast Air Quality Management District’s VOM emissions

program. He has also testified as an expert witness in environmental litigation and is a

guest lecturer for Loyola Law School’s Environmental Law program for the past four

years.

Mr. Trzupek developed techniques used to measure emissions of Hazardous Air

Pollutants from steel mill coke ovens. He was also the project manager for a research

program used to develop a new measurement technique for the determination of Volatile

Organic Compounds: USEPA’s Method 204F.

He has been a frequent speaker for organizations such as USEPA’s Emission

Measurement Technical Information Center, the Air & Waste Management Association,

the Chicago Bar Association, the Midwest Cogeneration Association and the Graphic

Arts Technical Foundation. He is also the past Director of Air Quality for the Air &

Waste Management Association (AWMA).

Mr. Trzupek was the Managing Principal at Air Solutions, Inc. from 1994 through 2000.

Prior to that, he was a Senior Project Engineer at Mostardi-Platt Associates, (1991 –

1994) Manager of Air Quality Services at The Almega Corporation, (1985 – 1991)

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Technical Representative for Dubois Chemical Company, (1983 – 1985) and a

Compliance Specialist for Albun Inc., (1981 – 1983).

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Publications and Presentations:

“Air Quality Management Guide”, due for release in 2002 by McGraw Hill

“Analysis of Peaker Plant Air Emissions in Illinois”, testimony presented to the Illinois Pollution

Control, August 25, 2000.

“Recent Developments in NOx Regulation”, presented at the Chicago Bar Association Clean Air

Seminar, (April 2000), Chicago, IL

“VOC and Odor Control Handbook”, Harold Rafson, Editor, McGraw Hill, 1998.

“Emissions Estimations Methods”, presented for Executive Enterprises conference on Clean Air

Act Basics, (June 1997), Chicago, IL.

“Developments in Capture Test Methods”, presented at the Graphic Arts Technical Foundation

environmental conference, (April 1997), St. Louis, MO.

“Preparing Smart Operating and Construction Permits Applications: Avoiding the 7 Basic

Mistakes”, published in Air & Waste Management Association’s EM Magazine (September

1996), Pittsburgh, PA.

“New Ozone Regulations on the Horizon”, published in ABA Section of Natural Resources,

Energy, and Environmental Law Newsletter (May/June 1996), Chicago, IL.

“Determination of VOC Capture Efficiency by Carbon Mass Balance”, co-author: Cheryl A.

Smith, presented at the A&WMA Annual Meeting, June, 1995.

“Permitting Issues Under the Clean Air Act Amendments of 1990”, conference co-chair for the

Lake Michigan chapter of the A&WMA, September, 1994.

“Enhanced Monitoring”, A New World of Demonstrating Compliance”, presented at the Midwest

Cogeneration Association conference, August, 1994.

“The Title V Permit Program under the Clean Air Act Amendments of 1990”, seminar co-chaired

with Nancy rich of Katten, Muchin and Zavis, April 1994.

“Emissions Inventories and the Clean Air Amendments of 1990”, presented at Executive

Enterprises Seminar, January 1994.

“Understanding Air Permitting and Environmental Regulation”, presented at Purdue Fuel

Conference Seminar, September 1993.

“Developments in VOC Capture Technology”, co-author: David A. Ozawa, presented to the

Gravure Arts Association, May 1993.

“Measurement of Volatile Organic Compounds in Air”, presented to the Emissions Measurement

Technical Information Center, October 1992.

“Achieving Compliance Under MACT”, co-author: Cheryl A. Smith, presented to the

A&WMA, January 1992.