Appendix E

ILLINOIS POLLUTION CONTROL BOARD
Testimony and Comments Regarding
context of Peaker Plant Hearings
illinois State Water Survey
Illinois State Water Survey
Illinois State Water Survey
SUMMARY OF WATER QUANTITY LAWS FROM

Appendix E

Thomas V. Skinner, Director

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

Brent Manning, Director

Illinois Department of Natural Resources

524

S. Second Street

Springfield, Illinois 62701-1787

Dear Director Skinner and Director Manning:

ILLINOIS POLLUTION CONTROL BOARD

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Sprm~)i ki. IL 6271)4

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October

25,

2000

On behalf of the Pollution Control Board, I am happy to present the

following information for the review of the Water Resources Advisory

Committee. While the Vonnahme-Park letter of October

2000 to the

Committee seeks commentary in three assignment areas, these remarks focus on

“Assignment Number One”: the need for substantive changes in law or

regulation governing the usage of water in the State of Illinois.

In the June 6, 2000 press release announcing the establishment of this

committee, Governor Ryan explained: “I want this new committee to take a close

look at our water resources and specifically examine the impact of industry,

agriculture and population on Illinois’ groundwater and surface water supplies.

It’s important for us to look into the effects of our usage of our limited natural

resources.” More specifically, the Governor set forth the committee’s task as

follows: to focus on our water resources and its usage, including the effects of

peaker plants on groundwater and surface water supplies.

As all of you know, at the same time Governor Ryan created this

committee, he asked the Pollution Control Board to hold a series of Inquiry

Hearings concerning the potential environmental impact of proposed new natural

gas-fired peaker plants. Given the proliferation of these new facilities and the

expressed public concerns, he asked the Board to specifically address the issue of

whether further regulations or legislation is necessary to adequately protect the

environment. Pursuant to that request, the Board held seven days of public hearing (August

23-24, Chicago; September 7, Naperville; September 14, Joliet; September 21, Grayslake; and

October

5-6,

Springfield.) During those hearings, the Board heard testimony from over 80

individuals

representing a broad variety of interests: state and local government officials;

legislators; industry representatives, and concerned citizens. I have enclosed a list of those

persons who testified. The complete transcript of testimony for each hearing is available on

the Board’s Web site at www.ipcb.state.il.us.

While water usage was NOT the focus of these Board hearings, the issue of water usage

was nonetheless an expressed concern of many who testified. Since it is the function of this

committee to address those concerns, the Board has prepared a summary of all testimony

relevant to the issue of water usage. For review by this committee, I have attached that

summary. Especially important, I believe, is the testimony of local government officials who

seek greater regional or state regulation of the State’s precious supply of water.

For review of this committee, I have also asked Board staff to research the regulatory

framework of several other Midwestern states (Iowa, Indiana, Missouri, Minnesota, Ohio,

Wisconsin) as it concerns the use of water in each state. Interestingly, Illinois is alone in the

virtual absence of state controls or plans regarding the use of water.

Based upon the enclosed information, I believe it is time to focus the committee’s

attention on the development of a workable regulatory framework for the conservation and fair

allocation of water resources in this great State: one that meets the needs of all concerned

entities and citizens. I hope the enclosed information aids us in that important task. I look

forward to seeing you both at the next meeting of the Governor’s Water Resources Advisory

Committee.

incerely,

Claire A. Manning

Chairman

cc:

Renee Cipriano

Members of the Water Resources Advisory Committee

PERSONS TESTIFYING AT BOARD PEAKER HEARINGS

Chicago Hearings

August 23, 2000

Charles Fisher, Executive Director, Illinois Commerce Commission

Thomas Skinner, Director, JEPA

Christopher Romaine, Manager, Utility Unit, Permit Section, Division of Air Pollution

Control, Bureau of Air, JEPA

Robert Kaleel, Manager of Air Quality Modeling Unit, Division of Air Pollution

Control, Bureau of Air, TEPA

Greg Zak, Noise Advisor, IEPA

Steve Nightingale, Manager, Industrial Unit, Bureau of Water Permits Section, IEPA

Rick Cobb, Manager, Groundwater Section, Bureau of Water, IEPA

Todd Marvel, Assistant Manager of Field Operations Section and RCRA

Coordinator! USEPA Lialson/IEPA

Brian Anderson, Director, Office of Scientific Research and Analysis, IDNR

10.

Derek Winstanley. Chief, Illinois State Water Survey, IDNR

August 24, 2000

Gerald Erjavec, Business Development, Indeck Energy Services, Inc.

Greg Wassilkowsky, Mauager, Business Developnient, Indeck Energy Services, Inc.

Arlene Juracek, Vice President, Regulatory and Legislative Services, CornEd

Steve Nauman, Vice President, Transmission Services, CornEd

Deirdre Hirner, Executive Director, IERG

Richard Bulley, Executive Director of Mid-America Interconnected Network

Freddi Greenberg, Executive Director and General Counsel, Midwest Independent

Power Suppliers

Michael Kearney, Manager, Economic Development, Ameren Corp.

Richard Trzupek, Manager, Air Quality, Huff & Huff

Suburban Hearings

Naperville

September 7. 2000

Mayor George Pradel, Naperville

State Senator Chris Lauzen

State Representative Mary Lou Cowlishaw

Mayor Vivian Lund, Warrenville

Paul Hass, Zoning Manager, DuPage County Department of Development

Environmental Concerns

Richard Ryan, President and Chairman, Standard Power and Light, Oak Brook

Diana Turnball, Consultant to variety of citzen groups, private foundations and

businesses who have been in opposition to some of the peaker plants

Carol Dorge, Attorney representing Lake County Conservation Alliance

Connie Schmidt, Representative of River Prairie Group

10.

Mark Golf, Resident, Warrenville

11.

Cathy Capezio, Resident, Aurora

12.

Terry Voitik, Resident, DuPage County, and Founder of Citizens Against Power Plants

in Residential Areas (CAPPRA)

13.

Maurice Gravenhorst, Member, CAPPRA

14.

Lucy Debarharo, Member, CAPPRA

15.

Terry Voitik on behalf of Steve Arrigo, CAPPRA

16.

Susan Zingle, Executive Director, Lake County Conservation Alliance

17.

Beverly Dejovine, Representative, Citizens Advocating Responsible Environments

(CARE), Bartlett

18.

Cathy Johnson, Vice Chair, Rural and City Preservation Association (R&CPA)

19.

Chris Gobel, Member, CAPPRA

20.

Elliot “Bud” Nesvig

21.

Sandy Cole, Commissioner, Lake County Board

22.

Chris Gobel, Member, CAPPRA

Joliet

September 14, 2000

Dr. Thomas Overbye, Associate Professor, Department of Electrical and Computer

Engineering, University of Illinois, Champaign-Urbana

Alan Jirik, Director, Environmental Affairs, Corn Products International, Inc.

Carol Stark, Director, Citizens Against Ruining the Environment, Lockport

Susan Zingle, Executive Director, Lake County Conservation Alliance

Keith Harley, Chicago Legal Clinic

Elliot “Bud”

Nesvig

Michael Shay, Senior Plamier Responsible for Long-Range Planning, Will Counly

Gravslake

SeDtember 21, 2000

State Senator Terry Link

State Representative Susan Garrett

Tom Lynch, Trustee, Libertyville Township

Betty Rae Kaiser, Trustee, Village of Wadsworth

Daniel J. Kucera, Chapman & Cutler, appearing on behalf of the Lake County Public

Water District

Jim LaBelle, Chairman, Lake County Board

Sandy Cole, Commissioner, Lake County Board

Bonnie Carter, Commissioner, Lake County Board

Greg Elarn, CEO, American Energy

10.

i.arry Eaton, Attorney, on behalf of the I .iherty Prairie Conservancy, Prairie Holdings

Corporation, and Prairie Crossing Homeowners Association

11.

Toni Larsen, Resident, Zion

12.

Chris Geiselhart, Chairperson, Concerned Citizens of Lake County

13.

Diane Turnball, Representing Liberty Prairie Conservancy, Concerned Citizens of Lake

County, CARE from McHenry County, Bartlett CARE, and Southwest Michigan

Perservation Association

14.

Lisa Snider, Resident, Wadsworth

15.

Verena Owen, Co-Chair, Zion Against Peaker Plants

16.

Elliot “Bud” Nesvig

17.

Carolyn Muse, Resident, Zion

18.

John Matijevich

19.

Dennis Wilson, Resident, Island Lake

20.

Terry Jacobs, Resident, Libertyville

21.

Jim Booth, Resident, Newport Township in Lake County

22.

William McCarthy, Resident, Libertyville

23.

Susan Zingle, Executive Director, Lake County Conservation Alliance

24.

Barbara Amendola, Resident, Zion

25.

Mark Sargis, Attorney, working with citizens who have been concerned about peaker

issues

26.

Cindy Skrukrud, Resident, Olin Mills, McHenry County

27.

Paul Geiselhart, Resident, Libertyville

28.

Dr. William Holaman, President, Illinois Citizen Action

29.

Evan Craig, Volunteer Chair, Woods and Wet Lands Group of the Sierra Club

30.

Phillip Lane Tanton

Springfield Hearings

October

2000

Roger Finnell, Engineer. Division of Aeronautics, Bureau of Airport Engineering,

IDOT

John Smith, Representative of Illinois Section of American Waterworks Association

Brent Gregory, Representative of National Association of Water Companies, illinois

Chapter

James R~Monk, President, Illinois Energy Association

Patricio Silva, Midwest Activities Coordinator, Natural Resources Defense Council

Brian Urbaszewski, Director, Environmental Health Programs, American Lung

Association

Elliot “Bud” Nesvig

Carol Dorge, Attorney representing Lake County Conservation Alliance

October 6. 2000

Susan Zingle, Executive Director, Lake County Conservation Alliance

Scott Phillips, Attorney, IEPA

Kathleen Bassi, Attorney, IEPA

Chris Romaine, Manager, Utility Unit, Permit Section, Division of Air Pollution

Control, Bureau of Air, IEPA

Greg Zak, Noise Advisor, IEPA

Todd Marvel, Assistant Manager of Field Operations Section and RCRA

Coordinator/USEPA Liaison/IEPA

Steve Nightingale, Manager, Industrial Unit, Bureau of Water Permits Section, IEPA

Testimony and Comments Regarding

Use of Water by Peaker Plants

—

given to IPCB in

context of Peaker Plant Hearings

CHICAGO HEARINGS

Commonwealth Edison

—

Prefiled Testimony of Arlene A. Juracek and Steven T.

Naumann

Water

impacts, including with regard to any potential contamination and water

supply, are also carefully assessed during the planning and development of any

peaker plant. Stringent state requirements regulate the discharge of

contaminants while local authorities often directly oversee issues of water

supply. In addition, the impact of peaker plants and other facilities on water

resources and usage will be closely examined by Governor Ryan’s newly

appointed Water Resources Advisory Committee, which will present its

recommendations to the Governor by December 2000.

Midwest

Indenendent Power Sunuliers Coordination Groun

Prefiled Testimony of

Freddi Greenberg

While water usage will vary depending upon the specifics of the plant involved,

the simple cycle technology currently used for peaker facilities typically places a

small demand on water resources. For example, the owner of onepea.ker plant

located in Kane County advises that the plant consumes no more than

2.5

million gallons of water in a year. In comparison, the average golf course in

the Great Lakes region consume~sj almost 31,000,000 gallons of water in a

year. (Weathermetrics, Inc. 1999 website) MWIPS recommends that the

Pollution Control Board defer its consideration of the impact of peaker plants on

water resources so as to consider the report the impact of peaker plants on water

supply which will be issued by Governor Ryan’s Water Resources Advisory

Committee.

Indeck Ener~vServices. Inc.

Gerald M. Eriavec

Prefiled Testimony

To counter this effect, various methods are

employed to cool the inlet air and

increase its density. One such method is the use

of chillers; however, these

require power to operate and are sometimes counter productive. Another

method is called evaporative cooling, in which the air stream is passed over

water and the air is cooled through evaporation, much like perspiration cools the

skin, This cooling effect can be limited on humid days. While water

consumption varies based on temperature and humidity, an evaporative cooleron

a 300 MW plant will average about 40 gallons per minute (gpm) of water

consumption.

Even though these hearings are directed at peaking plants, the subject of

combined cycle plants is sure to come up, so a brief discussion of them is in

order. Simply put, a combined cycle plant adds a steam cycle to the process but

directing the hot exhaust gas from the combustion turbine through a boiler,

which generates steam to turn a steam turbine. Because more energy from the

fuel is recovered and used to produce electricity, combined cycle plants can be

as much as

more energy efficient tha~n “simple cycle” peakers; however,

they are not suited to peaking use because they cannot be brought on line

quickly enough to function as peakers. Combined cycle plants also have

increased water needs compared to peakers. The first use of water, in the steam

system, is minimal, about 25 gallons per minute in a system that has been

coupled to 300 MW of combustion turbines to create a 200 MW steam cycle.

Water can also be used to cool the steam after it passes through the steam

turbine. If water is the sole medium, up to 2,500 gpm can be consumed, which

may be significant in some areas. Fortunately, advances have been made in

cooling technologies so that this use can be greatly reduced or eliminated if the

situation calls for it.

Water consumption impacts were also compared against other enterprises and

found, in most cases, to be at the low end of the impacts.

Testimony at Hearing

Water consumption can vary by humidity and temperature. For example, on a

very humid day, you’ll evaporate very little water. So very little water will be

used. On a hot, dry day would probably be your maximum consumption.

Typical for, say, a 300 megawatt unit would be about an average of 40 gallons

per minute. It can range from about zero to 80, depending upon the

temperature and the humidity.

One of the things that’s a concern about this type of plant here is the water use,

and I would like to bring that up. The water use, there’s two places. Number

one, there’s water in the steam system going around this way. You have to

—

you get some trace contamination going in there. So you have to occasionally

blow it down. The steam cycle on this plant, this is based on putting a heat

recovery unit on the back of a 300 megawatt plant, would probably be about 25

gallons per minute, which is not a lot.

You can use about 2500 GPM, which can trend toward, depending upon where

you are, significant numbers.

Now, the good news is that there are other ways to attack this problem.

They’ve made significant advances in dry-cooling systems, which would not

require this water at all. There are some hybrid systems that cut down on the

amount of water use.

Water use, as ~Inoted before, when operating a typical 300 megawattpeaker

plant with an evaporative cooler uses a maximum of 80 gallons per minute, an

average of about

50.

Technology, the evaporative cooler generally is only used

above 60 degrees.

** *

What is

gallons per minute? Well, basically it’s the

equivalent

of 11 homes

watering their lawns at the same time. If you walk down the street and you saw

11 homes watering their lawns, you probably wouldn’t think anything of it. On

an annual basis, approximately the consumption of about 30 homes, 30 average

homes. Other water impacts that need to be considered are wastewater and

starmwater. Stormwater is captured on site.

Water consumption, a million gallons per year. Compare your 300 megawatt

peaking plant to a 50-home subdivision, a typical high school, or a retirement

home, a 200-bed medical center, or a 400-room hotel, way down at the low

end, I think my laser pointer is dying here, of water consumption.

IDNR

Testimony of Brian

Anderson. Director. Office of Scientific Research and

Analysis

In Illinois, except for withdrawals of water from Lake Michigan, thereis

extremely limited regulatory authorities associated with water withdrawals from

our other surface waters and from groundwater. It’s, therefore, more

appropriate to deal with water quantity issues in front of

—

in the context of

Water Resources Advisory Committee, however, we do acknowledge the

relationship between these issues and I have asked Dr. Derek Winstanley, Chief

of the Illinois Water Survey, to provide a concise summary of some of the water

quantity issues relating to peaker power plants.

Illinois State Water Survey,

IDNR

—

Testimony of

Dr. Derek

Winstanley, Chief of the

illinois State Water

Survey

One focal point that I do wish to make is that the discussion of peaker power

plants and the impacts on groundwater resources should be placed within the

context of all other water demands including those

for

combined cycle plants as

well as Illinois’ growing water needs for domestic, municipal, agricultural and

other industrial uses. We do need to look at total demands from groundwater

resources as a basis for sound water resource management. The water demands

from the peaker power plants vary widely depending upon plant design, their

intended use and the number of days of operation.

I would like to give you some examples of the quantities of water that may be

associated with operations of peaker power plants by putting that in context of

some other water uses. First of all, peaker power plants, and I am going to

focus on just a simple cycle power plant when I refer to the peaker power

plants, these are typically small producing a few tenths to a few hundred,

perhaps a thousand megawatts of electricity. They do not operate everyday of

the year. The typical period of operation is from perhaps 20 to 90 days per

year. The range of water use there is from less than 100,000 gallons per day to

about 2 million gallons per day. Translating that into an annual use that gives

us a range of from about 1.4 to 180 million gallons of water per year.

Turning to baseload power plants, which is combined cycle, these are obviously

much larger, typically generate maybe 500 to several thousand megawatts of

electricity and are intended to operate more or less continuously throughout the

year. They consume water within the range of about

to 20 million gallons per

day. Translating that to an annual water use, that gives us a range from about

1,500 million gallons per year to 6,000 million gallons per year.

So in context, the peaker power plants consume about a fraction of 1 percent to

about 3 percent of the water used by typical baseload combined cycle plants.

Another example of water use, municipal water use, and I give you data from

Champaign, Urbana, for context. Champaign, Urbana, has a population of

about 120,000 people, and they need that water supply regularly 365 days per

year. Champaign, Urbana, currently consumes about 20 million gallons per day

of groundwater, which translates into an annual use of about 7,300 million

gallons per year.

So to put the water use by peaker plant in context of a municipal use, a typical

peaker plant would use the same amount of water as between about 25 and

3,000 people, depending upon the nature of the peaker.

One concept that is important in examining not only peaker power plants but all

groundwater use is the concept of sustainable yields. And in my written

testimony, I refer to that as potential yield. Sustainable yield is a fairly diffuse

concept but generally, it tends to mean the yield of water that can be sustained

over the long term so that it can be used not only by the current population but

also by future

generations

and a yield that will have no significant impacts.

The determining sustainable yield is a complex scientific exercise that involves

consideration of variables such as rainfall, recharge rates, geology and impacts.

Impacts not only on existing wells, but on peaker systems and on stream flows.

The point here is that for most aquifers in Illinois, we do not have a very highly

accurate estimate of sustainable yield. We need much better scientific data and

modeling capabilities to be able to estimate sustainable yields.

Another important point is that aquifers themselves are not very sensitive to the

end uses of water. That is an aquifer doesn’t really differentiate whether a

million gallons of water is going to be used for drinking water or for peaking

power plants or for golf courses but the public often does differentiate among

those end uses and, I think, trying to incorporate the public values and

preferences into the equation on water resource management is an important

consideration as well as the actual amount of water used.

Water quality has been mentioned by people from Environmental Protection

Agency giving previous testimony. There are natural occurrences of various

chemicals in the groundwaters throughout Illinois. These lead to mineral

concentrations that can effect not only the operation of the peaker plants, but

also the discharges from the peaker plants. So the water quality also needs to be

considered.

In conclusion, I would like to make two points, one focusing exclusively on

groundwater, the other combining groundwater with surface water.

Focusing on groundwater, it’s important to recognize that in the use of

groundwater resources, all uses of groundwater, not just peakers, that we need

to consider the scale of the natural resource, that is the aquifer.

Groundwater typically is found in discrete squifers that transcends political

jurisdictions. They cut across municipalities, counties and even states.

Plumbing management by individual communities will not solve problems in the

long term, we need to take an aquifer-wide perspective. Beyond just

groundwater, I think that we need much more consideration of the conjunctive

use of surface and groundwater. There can be many efficiencies gained in water

supplying usage~by considering conjunctive uses of surface and groundwater.

So my bottom line is that I think Illinois would benefit from moving towards

ziiuch more comprehensive regional water resource planning and management.

This will bring together communities and cut across jurisdictions and we’d

—

much more appropriate to the scale of the natural resources, that is the aquifers

in the case of the groundwater supplies and river basins and water sheds for

surface waters.

Let me give you one example I think is an excellent model of what is going on

in one part of Illinois and that is in central Illinois. We have a major aquifer,

the Mahomet aquifer, that extends from the Illinois River across to Indiana,

which embraces 15 counties. Now, in the past couple of years, the local

communities in that 15 county area have bonded together to form what is called

the Mahomet aquifer consortium and they’re collectively concerned about the

future of their own water resources, want to better characterize those resources

and opportunities as a basis for self-management to the water resources. So, I

think, on the one hand we may need new laws, regulations, but I think we also

need to encourage local communities to attempt to solve their own problems.

IEPA

—

Prefiled Testimony of Richard

P. Cobb. Mana2er of

the

Groundwater Section of

Bureau of Water

However, the few Illinois court decisions since the enactment ofthe Water Use

Act have interpreted that “reasonable use” for groundwater does not restrict the

use of groundwater except from malicious or wasteful purposes of the user.

Concurrent with the requirement for these hearings, Governor Ryan, by

Executive Order, established a WaterResources Advisory Committee. The

committee’s task will be to focus on our water resources and its usage,

including the effects of peaker plants on groundwater and surface water

supplies. The committee will also examine the various economic and social

issues related to energy producing facilities and water use in Illinois and present

recommendations for action to the Governor by December 2000. I plan on

attending this committee’s first meeting on August 31, 2000.

IEPA

—

Prefiled Testimony of Christonher Romaine. Manager of the Utility Unit in the

Permit Section of Division of Air

A key factor in the design of a peaker plant is the capability to maximize the

power output of the plant to be able to meet peak electric power demand. This

leads to a number of variations on the basic simple cycle turbine, all due to the

scientific fact that the power output of a gas turbine varies based on the density

of the air being used in the turbine. The denser the air, the more air that can be

pushed through the turbine and the higher the power output. This means that in

the absence of any adjustments, the output of a given gas turbine will be

significantly less on a 90°Fday in July, when peak power is most likely to be

needed, than on a 20°Fday in January. To correct for this phenomenon, the

modem simple cycle turbines used in peaking plants are routinely equipped with

devices to cool the air going into the turbine. While it may appear

counterproductive to cool the air in a turbine before heating it, cooling the air

allows more air to be handled by the air compressor, thereby allowing more fuel

to be burned and increasing the power output of the turbine.

Gas turbines can be equipped with several different types of air cooling systems

that vary in the effectiveness with which they can cool the inlet air to boost a

gas turbine’s power output. In the simplest system, water is injected directly

into the incoming air to cool the air by evaporative cooling. Clean

demineralized water must be used to prevent excess build up of scale or erosion

of the blades in the air compressor of power turbine. In more advanced

systems, water may also be injected at a point in the air compressor itself. The

inlet air may also be cooled by indirect systems in which the air passes through

cooling coils. In this case, water may still be used in an open cooling tower

where evaporation of water is used to dissipate the heat generated by a

mechanical refrigeration unit. Alternatively, a dry cooling system may be used

in which the heat generated by a refrigeration unit is dissipated to the

atmosphere by dry cooling towers or radiators. The more complex the cooling

system, the greater the amount of energy that is consumed in its pumps and

compressors, which accounts for some of the increase in power output.

Another approach to boost power output of a gas turbine is to inject clean water

of steam into the burners or to inject steam after the burners. All these

measures increase the gas flow through the power turbine and thus increase its

power output. Because fuel must be burned to evaporate the water (either in the

turbine itself or in a separate boiler to make steam), these measures to increase

power output are accompanied by a loss of fuel efficiency by a gas turbine.

NAPERVILLE HEARING

Connie Schmidt, Representative of River Prairie Group

DuPage County is so close to Chicago, one would think it is very urban. I

myselfhave a well and septic on my property and I am incorporated. I live

within the city limits of Warrenville. So it is not totally unusual

—

and all my

neighbors do because we don’t have city water in our neighborhood. So the

groundwater use as well as what happens to it after it’s been used, I think, is a

realistic concern in our area.

Mark

Goff.

Resident, Warrenville

So obviously well water is a concern.

Lake

Coun~Conservation Alliance

—

Testimony of Susan Zin2le. Executive Director

A lot of people have talked about water supply. Some of the peakers do use

vast amounts of water. Some of them as much as a combined cycle plant

We’re looking at Zion is going to use over 200 gallons (sic) a day. That’s as

much as the entire city of Zion in itself. McHenry and parts of Wisconsin draw

on that same aquifer. How can Woodstock and Zion even be aware of each

other’s plants let alone determine which of the two plants is built if either.

Water supply is not a local issue

Rural and City Preservation Association (.R&CPA~.Cathy Johnson, Vice Chair

The water issue, which is a major one in Mdllenry County, is barely even

considered in the new standards. A new peaker plant has to only respond to

how the water it uses affects the area one-quarter of a mile around the plant.

This is ridiculous. This standard isn’t there to protect us.

JOLIET HEARING

Corn Products Internal. Inc., Alan Jirik. Director. Environmental Affairs

With regards to cooling water consumption, our plant currently takes water

from the Sanitary and Ship Canal. The water is used for non-contact cooling

purposed for the corn wet milling operating and then returned to the canal

In a

clever and environmentally friendly approach, we plan to use the existing

cooling water flow to supply cooling water io the new cogeneration operation.

accomplish this by routing an additional loop from our existing cooling

water line to serve the cooling needs of the cogen. After servicing the cogen,

the water will return to our existing line and be discharged the same as it is

today. Thus, the project will not increase our current water withdrawal and will

not result in any new water discharges, any new intake or outfall structures, or

cause any other disruptions to water bodies, water tables, groundwater, aquifers

or burden the community drinking water supply.

Citizens A2ainst Ruining the Environment. Lockport.

Carol Stark, Director

and

Exchan2e

with

Board Member Kezelis

We. also have information that states the aquifers located on this

site

are joined

together. This is the first of our concerns. The fact that the aquifers, our water

supply, could be affected by this peaker using thousands of gallons a day is not

a comforting

thought.

Board Member Kezelis: Ms. Stark, do you know what the source of your

public water supply is in Lockport?

Ms. Stark: We do

Board Member Kezelis: Is it the aquifer?

Ms. Stark: Yeah. We do have

and then there are some people that are on

wells, but yes, it’s the aquifer. We have never tied into Lake Michigan water.

Will

County,

Michael Shay. Senior Planner Responsible for Lon2-Ran2e Plannin2 and

Exchange with Chairman Manning. Board Members Flemal. Girard. Kezelis and

McFawri

The largest thing that we found that concerned us was that Will County’s

aquifer reserve water is about 66 million gallons a day. That’s how much we

have

—

it’s currently recharging

that we could use for water supply. We

contacted several facilities and went on several industry websites and they said

five

to 12 million gallons a day per facility for a combined cycle facility and

roughly a million gallons a day for a simple cycle facility.

So we contacted some of them that actually started operation in Will County,

including the one that you visited today. We arrange tours. On our

tour, we

found out they’re actually planning

—

or they were planning for an expansion

and this comes to a key point that I’d like to discuss today. There was

discussion earlier about separating simple and combined cycle plants. We do

not think you can separate those two facilities.

Simple cycle facilities are designed and physically organized to be converted to

combined cycle facilities down the road and that plans that we received as we

reviewed these petitions explicitly and clearly state that; that they are designed

to be converted or added Onto at a later date. So we do not want to see those

two issues separated at all.

So they

we get into more discussions with them and they say 16 million

gallons a day for one of the facilities which we visited, which means that four

such facilities of which there are already that many could eat up the entire

reserve water capacity for Will County. We are not likely to get more lake

water. River water is another issue altogether regarding quality of our water.

So when you add that to the fact that we are the fastest growing

—

numerically

growing county in Illinois and also the fastest in the sunbelt, we see a problem

for a collision between growth and these facilities for that resource.

We are also concerned

when we continue to do our research, we said, that’s a

lot of water to draw from one facility. How do you get that? Well, they drop

wells in the aquifer obviously and they pull it up at such a rate that it creates a

drawdown. It creates a reverse cone or a cone of water supply and

the radius

on that for a facility of the magnitude that we were discussing is six miles

drawdown, 300 feel drawdown at the point of the well and still 35 to 50 feet of

the six-mile radius.

. .

Will County has thousands and thousands of wells; residential, industrial or

group wells. We’re concerned about well failure because we continue to place

these facilities over time and if they’re to be converted to combined use

facilities.

Board Member Kezelis: I have a question. I, too, hope to be brief, Mr. Shay.

That status of the suggestions that you and the planners for Will County propose

to your board, what is the current status?

-Mr. Shay: Well, we have a first set of regulations in place. We re currently

discussing the second set of-- we’re researching and discussing the second set.

If I had to provide a guess, which bureaucrats despise doing, but I will do

nonetheless, I would suspect that they will prohibit the use of aquifer water for

electric generation.

Board Member McFawn: Is the only industry that you’re concerned about the

drawdown well or is that general a concern?

Mr. Shay: It’s the only industry we know of that draws that amount that

quickly. We can’t find another that draws from the aquifer at that rate, but

we’re unaware of one that draws at that rate.

Let me illustrate this real quickly. When you’re talking about 16 million gallons

a day, that means that three of those facilities could put a pipe on the end of the

Fox River in St. Charles and the river would end while it was in operation.

Chairman Maiming: Where did you get those figures in terms of the drawdown

effect and how much water is actually being used by these facilities?

Mr. Shay: We got from the-- well, we got the information on flow and amount

of the aquifers and reserve capacity from the Illinois Water Survey. They

regularly publish those statistics and we acquired them from them and then we

acquired numbers on the use actually directly from the industry itself.

The engineers who built the Elwood plant, we

our land use and zoning

committee and planning and zoning committee visited those facilities. In those

discussions, we asked them about water use and they gave us very frank

answers on that. The number that they gave us came out to 16 million gallons a

day and we confirmed with them that that was

accurate assessment. So we’re

fairly confident of those numbers.

Board Member Kezeiis: Mr. Shay, what’s your

understanding

about the

Elwood facility; single or combined?

Mr. Shay: My understanding is that it is currently a single cycle plant that the

two additional

the Elwood two and Elwood three will also be simple cycle.

All three of those phases, though, are designed to be converted to combined

cycle should they wish to do so.

Board Member Kezelis: So the 16 million gallons per day

Mr. Shay: Would be if they became a combined cycle. They are not currently.

They do have a well, but it’s comparably small.

***

Board Member Girard: Mr. Shay, if Will County passes an ordinance that

prohibits the use of aquifer water or electrical generating facilities, would that

also apply to a facility that tried to site itself inside a municipality in Will

County?

Mr. Shay: No. That’s why we’re concerned about jurisdiction hopping, but it

would also cover a number of the intersections of pipelines and transmission

facilities.

Board Member Flemal: One of the things that this board may see it necessary

to do ultimately in our decision here is to address the issue of how much local

and how much regional or state level oversight there ought to be in the siting of

these facilities.

We’ve heard quite a range of perspectives from it should be entirely in the

hands of the locals with the facility to what I think I heard you say that there

should be a strong top-down oversight on the plants.

First off, have I characterized where you’re coming from correctly?

Mr. Shay: Okay. I would like a strong state or national presence on the issue

of drawing from wells.

Board Member Flemal: Soley on that issue?

Mr. Shay: And issues that affect cross-jurisdictional

an aquifer doesn’t make

a jurisdictional boundary. It could go across several counties and several

municipalities, et cetera. Well, local authorities, because we are competing for

economical development efforts and because of the nature

the politics

between them, are often played against each other by the private industry

Board Member Kezelis: Mr. Shay, the water use, as you know, is not

something

that we

are

to address. The Governor has

appointed the water

commission to address water use for the state. Nonetheless, your reference to

the water use a few moments ago, I needed clarification of.

You indicated that approximately 16 million gallons per day would be used by a

combined peaker facility and that the drawdown for such a facility would impact

roughly a six-mile radius, is that correct?

Mr. Shay: That’s correct, according to the information we have from the

Illinois Water Survey

Board Member Kezelis: So you received that information from the Water

Survey itself?

Mr. Shay: Yes. We got it off their website. They have a very graphical

explanation.

GRAYSLAKE REARING

Testimony of State Senator Terry Link

Since the effect of peaker power plants, air quality, water supply, natural gas

supply, noise, taxes, are felt regionally, not just locally, I believe we must take

a regional approach in regulating the pearkers.

Testimony of State Representative Susan Garrett

Our aquifer is on the verge of being mined. We are concerned for our long-

term water supply. We need to resolve this.

Testimony of Sally Ball on behalf of State Representative Lauren Beth Gash

Our friends and neighbors are understandably worried about the impact of so-

called peaker plants on air quality and water supplies.

Appearin2 on behalf of the

Lake

County Public Water District, Daniel J. Kucera.

Chapman & Cutler and Exchange with Board Member Kezelis

Now, the term peaker plants is a misnomer because it implies an

oversimplification. The types of electric generating facilities being proposed

throughout the state, and which are raising environmental concerns for many

people, are both base-load plants and peak-demand plants. The environmental

impact issues raised by such plants, including water use, differ only in

magnitude.

In addition, these plants can be both simple cycle and combined cycle.

Accordingly, demand for water and resulting environmental impact of that

demand can vary according to the type of plant. Clearly, a combined cycle

plant, which uses steam to generate a portion of its electricity, can be expected

to use more water than a small simple-cycle plant, which uses water only for

cooling.

A witness for the Illinois State Water Survey in these proceedings, Mr.

Winstanley, has testified that simple-cycle peaker plants can use up to 2 million

gallons of water per day. And combined-cycle plants can use

million to 20

million gallons per day.

Presently with very limited exception, there is no permitting process or

regulatory oversight over the uses of water by peaker plants. Witnesses for

IEPA in these proceedings have acknowledged that IEPA currently has no

jurisdictional responsibility over peaker plant water use.

A public water supply providing Lake Michigan water to a peaker plant would

have to have a sufficient allocation from the Department of Natural Resources to

enable it to supply peaker plant demand.

The Illinois Water Use Act of 1983,

525

ILCS

45/

et seq.,

was cited by one of

the IEPA witnesses in this proceeding. Section 5 of the Act does provide that a

land owner who proposes a new well expected to withdraw over 100,000

gallons per day must notify the local soil and water conservation district. The

district is then to notify other units of local government whose water systems

may be impacted. And the district is to review the impact and make findings.

However, the statute provides no enforcement mechanism.

Moreover, this provision does not even apply to the region governed by

diversion and allocation of Lake Michigan water under 615 ILCS 50/1

et seq.

The Water Use Act states that the rule of reasonable use does apply to ground

water withdrawals, but it does not provide supporting, permitting

or regulation.

As to the need for permitting and regulator oversight, I would first address

Lake Michigan water. Lake Michigan is a valuable and limited domestic water

supply resource. It is valuable because in northern Illinois lake water is

perceived to be superior to ground water.

Aquifers in the region commonly contain high levels of iron, manganese and

other constituents which raise esthetic issues and which can require costly

treatment facilities Deep wells often contain high radium or alpha-particle

contents.

Further, in portions of northern Illinois, water levels in the aquifers have

diminished and some deep wells have been mined into salt water.

Obviously, there is a great demand for lake water to provide the domestic

water supply for as many communities as possible. However, Lake Michigan

water is a limited resource because of legal limits on how much water Illinois

may withdraw.

Accordingly, the use of Lake Michigan water by peaker plants

for cooling, steam production or even as backup to ground water for these uses

should be limited or even prohibited.

As to ground water, because peaker plants can be heavy users of ground water,

upwards of several million gallons per day, there should be regulatory

oversight over such uses. In particular, the potential effects upon aquifers and

ground water domestic water supplies should be evaluated as part of the

permitting and regulatory process. Mr. Winstanely has well stated the issues

in his testimony in this proceeding.

It is also important to point out that the ground water is a limited resource in

certain portions of the state. For example, in parts of central Illinois ground

water is extremely limited, even for domestic water supplies and, of course,

aquifers in northern Illinois have been subject to diminishment.

Finally, other surface water, needless to say where a peaker plan may withdraw

water from a stream or inland lake, the impact of such withdrawal also could

be evaluated. For example, it could reduce the resource value of the water

body for domestic water supply, aquatic life or recreation.

There are now some additional water issues that I would like to bring to your

attention, one of them is decommissioning.

For example, if a plant is terminated, who will be responsible for resulting

excess capacity in the local public water supply? Who will be responsible for

capping the plant s wells? Who will be responsible if leakage from the plant

has contaminated the source of supply for the local water utility or for

individual residential wells? Where is the accountability when these plants are

closed down?

It would seem appropriate to enact a decommissioning procedure to protect

water sources and the public when these plants are removed from service. At

the very least, there should be a procedure for a state administered trust

account, which peaker plants would be required to fund, to assure remediation

and restoration funds will be available if plant owners abandon plants without

protecting water resources.

Another possibility is a requirement that a surety bond or letter of credit be

posted to

secure the obligation to

protect

water

sources.

Another issue is competition. Public water supplies can be expected to remain

a highly regulated industry so as to continue to assure safe drinking water for

the public. Unlike other utility functions, public water supply is not likely to

be deregulated or to be subject to the competitive marketplace. The investment

in water infrastructure per customer far exceeds the comparable investment for

other utilities. This investment in water infrastructure will only continue to

increase under the Sale Drinking Water Act amendments as new requirements

are proposed. Redundant water systems do not make sense.

It is important, therefore, that electric generating plants not be permitted to

engage in helping to finance new public water supplies which may compete

with existing public water supplies. Such predatory competition could deny

customer the benefits of economies of scale.

Another issue we believe is siting. Presently siting of electric generating plants

is considered to be a local issue. However, there may be siting concerns of a

broader interest, as related to water use. Recent proposals indicate multiple

peaker plants in close proximity to each other. What is the impact of multiple

draw-downs on an aquifer at a particular location?

Another concern relates to soil conditions at a proposed site. How vulnerable

are site conditions to a contamination spill? Could a shallow aquifer be

adversely impacted? Presently, there is no regulatory oversight of these siting

issues.

Finally, cross-connection. When an electric generation facility is partially

served by a public water supply and partially served by the facility’s own

wells, there must be assurance that no cross-connections will exist. For

example, the public water supply may provide water for domestic use and fire

protection, while the facility uses its own wells for process water. However,

the public water supply might also provide backup in the event the wells are out

of service.

Local governments may not necessarily have the staff with skills to constantly

monitor for cross-connections in generating plants. Indeed, it is not clear that

they ever would have access to the plants. Who then will be responsible for

policing for cross-connections and protecting the public water supply?

The District understands that the Governor’s water advisory committee may be

considering waLer issues related to peaker plants. We are not aware whcther

that committee is soliciting public comment. Therefore, we believe it is

important that the Pollution Control Board in its report to the Governor include

water issues related to peaker plants discussed in the testimony and comments

submitted in

this proceeding.

In conclusion, we suggest that the Illinois legislature should adopt a permitting

of regulatory oversight requirement for process water used by all electric

generating facilities, including both base-load and peaker plants

***

Board Member Kezelis:

just have a question. Can you

for

the record tell

what your rate of capacity is and roughly how many gallons per day your

customers do take?

Mr. Kucera: Our peak day capacity is 6 million gallons per day. I think iii

actuality the customers average between 3 and 4 million gallons a day.

Lake

County Board. Jim LaBelle, Chairman

The process should not only consider air quality but also other environmental

factors such as water consumption impacts on aquifers or Lake Michigan water

allocations.

In addition to the JEPA considering the polluting impact of multiple plants, the

Department of Natural Resources and the ICC need to consider the impact on

ground water resources, natural gas availability and pricing impact if numerous

peakers operate at the same time.

The high volume of ground water usage can lessen the supply for any other

entity tapping the same aquifer.

Lake

County Board. Sandy Cole, Commissioner

Tn addition to air quality, peaker power plants may affect the region’s water

supply as they need to draw significant amounts of water from Lake Michigan

or local aquifers.

Lake County Board. Bonnie Carter, Commissioner

The village of Island Lake was being

asked to

annex the land. The plant

proposed for the small community on the far western edge of Lake County was

not a peaker plant. The plant was proposed to provide base-load power year

round with ground water usage of 4 to 8 million gallons daily.

Local officials, myself included, and concerned citizens began investigating the

issues surrounding the type of power plant involved. Many issues such as air

quality, noise and lighting were raised. Water usage was by far the most

overwhelming environmental concern. While gathering information, I became

well acquainted with the work of the Illinois State Water Survey, a division of

the Department of Natural Resources and an affiliate of the University of Illinois

at Urbana-Champaign. According to data assembled by the ISWS, the volume

of water required to supply the proposed plant for a year would have been far

greater than what was required for the village’s entire population.

I further learned that neither the Illinois Environmental Protection Agency, nor

the ISWS or any other state agency had any authority limiting ground water

withdrawal. The proposal for the Island Lake plant was eventually withdrawn

and most of the subsequent plant proposals in Lake County are forpeakers, not

base-load. This, I feel, is a direct result of the hightened awareness of the water

withdrawal issue and how precious a resource water is. Though the issue of

water usage is not as critical with peakers, it is still significant enough to

warrant scrutiny.

In February 1999 I drove to Springfield with my two constituents who had

originally brought this issue to my attention. We met with IEPA Director Tom

Skinner, officials from Storm Water Management, Illinois Department of

Natural Resources, Fish and Wildlife, the IEPA Bureau of Water, the IEPA

Bureau of Air and two state legislators. We expressed our deep concerns with

the permitting process of a 90-day review on construction applications, the lack

of regulatory authority over ground water withdrawal and the lack of public

hearings. We also discussed air quality impacts along with the noise and

lighting.

We all felt that the JEPA directors and supervisors that sat among us were

frustrated with having to review permit applications without being able to take

the regional impacts of these plants into consideration. They agreed that a

regional element should be included in the review. We were surprised and

shocked to learn that each division did not review the applications together.

One division follows the application approval process after the other division has

completed its work. They may never have been aware of the combined impact

on adjoining property owners or cumulative environmental impacts. In other

words, they didn’t talk to each other.

After we left Springfield that day, some minor changes did take place. The 90-

day review process was reversed back to 180 days. Public hearings started to

take place on applications and the IEPA Director Skinner never forgot us in

Lake County.

As you may see, we are still dealing with this issue today and we are still very

frustrated. I hope and pray we will all be heard today and that, as a result, you

recommend improvements, not only to the process, but to help reduce the

negative impact power plants could have depending on where they are sited.

As with many of the issues surrounding peaker plants, it is important to

recognize that ground water is a regional issue. It is also important to recognize

while one peaker plant may not threaten a region’s water supply, multiple

peakers may. Aquifers do not end at municipal or political boundaries. The

water consumed in one village not only limits the supply of its immediate

neighbors, but impacts the supply of further villages, commercial wells and deep

community wells which draw from the same aquifer.

In the case of the Island Lake proposal, adjacent villages would have realized

significant financial impacts. Nowhere in the permit application process

submitted by the applicant were those impacts acknowledged or addressed. One

neighboring village, the village of Wauconda, would have incurred expenses

close to $1 million to reset the pumping well head in two municipal wells. The

taxpayers of this neighboring village, not the power company, would have borne

this expense, $1 million. This village had no opportunity to voice its concern

during the application review. Surely, this demonstrates why a regional

application approach must be in place, must be put into practice.

Determining the amount of water available for peaker use as well as all other

users is a significant undertaking for any local community. Dr. Derek

Winstanley of the ISWS in his written testimony to this Board wrote of the

expense of collecting ground water data. Conducting a study to determine the

sustainable level of water usage for Lake County is estimated to be a multi-

million dollar project. To expect local communities to shoulder this burden is

unreasonable. Yet without regional data, a single community cannot make an

informed decision on water supply.

At the August 18th, 1999 meeting of the Lake County Public Works and

Transportation Committee, Illinois State Water survey Director Dr. Derek

Winstanley reported that around the year 2030, Lake County will maximize its

water use. Today, we are at the maximum sustainable level of the northeastern

Illinois deep bedrock. We cannot continue to increase withdrawals from the

deep aquifer. Water demand is up 20 percent, and we are at the point where

supply and demand are beginning to conflict.

Another large source of water for the Lake County area is Lake Michigan.

Here again, the County’s usage impacts the supply of other counties and states.

The supreme court fixes allocations. Local governments do not have an

endless supply.

Peaker plants will either draw ground water, which will have an impact on

neighboring wells, or draw on Lake Michigan water that has already been fully

allocated. Clearly this issue needs to be understood and addressed.

The quality of water will also be impacted by extensive withdrawal. Research

has shown that when too much water

is pumped, surface

waters can be

impacted. Water availability to stream beds, wetlands and lakes can decrease,

and the quality of the existing water may be threatened. Eventually, animal and

plant life will be threatened. Since the technology exists to convert peaker

plants to combines plants at any time, peakers should not be considered as a

minor use, but rather as a major use with regional impact. I would suggest that

all applications should be specific as to whether they are peaker or base-load.

Applications for peakers should question the intention toward possible future

conversion to a base-load.

Allowing one industry that provides a very few number ofjobs to have

unlimited use of our water supply impacts the economic growth in communities

where other industries also require water.

Officials in Lake realize that it is not only peaker plants that threaten our water

supply. Development of any kind, whether residential, commercial or industrial

will place an additional burden on limited resources. County officials further

realize that electricity may be one of the resources in short supply. However,

our analysis of the realities of peaker power plants and the marketing of power

do not convince us that peaker plants located in Lake County will alleviate a

power shortage in Lake county. We feel we are being asked to give up one

precious natural resource with no guarantee that the sacrifice will realize a

benefit for the county’s citizens.

The Water Use Act of 1983 and the Water Authorities Act do not give counties

the authority to regulate ground water withdrawal. A plan that regulates major

aquifer draw-downs is needed. The Lake County Board recommended

legislation to do just that. It is believed that there is support from state agencies

to clarify regulatory authority for ground water withdrawal. These initiatives

are included for your review.

The state needs to determine what the reasonable use is. I finally realize that the

IPCB does not have the authority to regulate ground water withdrawal. I have

the pleasure of being a member of the Water Resources Advisory committee that

was recently initiated by Governor Ryan. This issue will be covered in this

committee and our recommendations will be made to the Governor in

December. I feel it is imperative to point out that we need to share our

expertise with all governing state agencies in order to be better equipped to

make decisions involving, the power industry. It is too complex an issue for one

agency to comprehensively see all facets. I believe that the Pollution Control

Board, the ICC, the IEPA, the ISWS also all need to support each other and

work together. We need a regional cooperative group with regulatory authority

when reviewing applications.

The Lake County Board has made a decision last year to be proactive and not

reactive. Our actions support that position. I ask you to support this board and

the people of Lake County by doing the same. Place a moratorium on all

pending and new applications for power or peaker plants until such time as all

agencies have collaboratively worked together reducing and/or eliminating- the

negative impact to our quality of life. Thank you, Chairman Manning and the

IPC

Board.

Toni Larsen. Resident, Zion

In the Zion area, there are at least five pending permits which will be licensed

separately for future plants. I believe all facilities within Lake County need to

be evaluated regionally to assess the cumulative effect. One of the sites is in

Zion and it is zoned industrial, although most of the neighboring properties are

not in Zion.

These neighboring communities have no say what goes in their backyard.

These communities get their water from wells. One of the proposed peaker

plants plans on drilling an industrial well. This plant can use up to 2 million

gallons of water a day. I believe that needs to be more study on ground water

supply issues.

Concerned Citizens of Lake County. Chris Geiselhart, Chairperson

There is a potential drawdown of hundreds of thousands of gallons of water

from Lake Michigan, which already exceeded water usage for the mining of

deep well aquifers as sources of water for these facilities.

Zion A2ainst Peaker Plants, Verena Owen. Co-Chair

Environmental impact studies for peaker plants are required by other states, for

instance, Wisconsin, Indiana and Ohio. The environmental impact studies

should contain at a minimum hydrology and water quality, water usage, waste

water, water run-off and potentially polluted run-off containment, air quality,

biology, loss of habitat, loss of agricultural land, land use and community

character, archaeology, socioeconomic impact, visual

impact, impact on

local

services, traffic, noise and public health and safety.

Jim Booth. Resident.

Newport Township in Lake County

Upon investigation, I learned that the city of Zion, who purchases their water

from the Lake County Public Water District had exceeded its 822.345 million

gallons of Lake Michigan water by 22 million gallons. They purchased 844

million gallons from the Lake County Water District in the period May 1999

through April of 2000.

Zion, of course, is consideringi the peaker power plant, which would use a

maximum peak of 2.124 million gallons of water per day when they are

operating their five turbines. And they divide this by

365

days a year, of

course. And that would run 230,000 gallons per day. Unless Zion files and is

awarded an increased allocation of Lake Michigan water, they cannot serve my

business nor can they serve the proposed peaker plant.

The state of Illinois is in debt to Canada for exceeding their Lake Michigan

water allocation. This debt is to be repaid by 2019. I assume you are familiar

with that. For 20 years, Illinois took more than their allotted amount of water

out of Lake Michigan, and now they have to pay it back. The bottom line is

that there is less water to be divided among the municipalities, 177 or so, that

use Lake Michigan water.

But the peaker power plant has an alternative which I do not have. They can

drill wells and tap into the Ironton Galesville Sandstone Aquifer.

Circular 182 from the Illinois Department of Natural Resources Water Survey

by Adrian A. Zuchowski addressed the water level trends and pumpings into

the deep bedrock aquifers in the Chicago region in the period 1991 through

195.

On page 15 he wrote that Schiect in 1976 estimated that the practical sustained

yield of the deep bedrock aquifers regardless of the scheme of well development

cannot exceed

million gallons a day.

The practical sustained yield of the deep aquifers is defmed as the maximum

amount of water that can be withdrawn without eventually dewatering the most

productive water yielding formation, that is the Ironton Galesville Sandstone

Aquifer.

In a fax dated August 15th of this year, Mr. Scott Meyer of the Illinois State

Water Survey faxed me and said I recently estimated deep bedrock withdrawals

in that area, referring to Zion, at about 71 million gallons a day That is 6

million gallons above the practical sustained yield.

The point is this. One peaker power plant drawing 230,000 gallons per day

from the Ironton Galesville Sandstone may not seem overly significant. But it is

reported that there is some

peaker power plants proposed in the state of

Illinois. How many will be drawing water from the Ironton Galesville

Sandstone aquifer in the eight-county area?

Now, the survey that I referred to, the circular 182 involved water being taken

from the following eight counties: Cook, DuPage, Grundy, Kane, Kendall,

Lake. McHenry and Will. Now, five plants the size of the proposed Zion plant

would draw 1,150,000 gallons of water per day from that aquifer. For 20

months plants would draw 4,600,000 gallons per day average, but at peak

would draw 42 million gallons in one day. Now, this is out of an aquifer that

can only sustain 65 million gallons and is currently being drawn at 71 million

gallons.

The former state senator and minority leader Everitt McKinley Dickson once

said after attending his first budget meeting, a billion dollars here and a

billion

dollars there, and pretty soon it added up to some real money. The same thing

is true of the peaker power plants and their great appetite for water.

I ask you to consider the following questions. Should quality Lake Michigan

water by used for peaker power plants or should that be reserved for human

consumption? Should there be a limit on the quantity of water mined from the

Ironton Galesville Sandstone Aquifer considering eight counties depend upon

this water source, Cook, DuPage, Grundy, Kane, Kendall, Lake, mclienry and

Will Counties? This is not a local issue. This is a regional issue.

And remember, this Ironton Galesville Sandstone Aquifer begins in Minnesota,

runs through Wisconsin, northern Illinois, central Illinois, into Missouri and

finally into the state of Iowa. It can be mined dry.

William McCarthy, Resident. Libertyville

As far as water use is concerned, these plants do use a lot of water.

** *

Peaker Plants are inefficient. They only covert 28 percent of the power that

they burn into electrical energy. Combined-cycle plants convert 56 percent.

Obviously, you are going to get a lot more bang for your buck with a combined-

cycle plant.

The problem is combined-cycle plants use more than 2 million gallons of water

a day. Peaker plants use maybe 120,000 gallons a day. That is a big

difference.

And as has been mentioned before, Illinois is under water use restrictions

because they don’t want Lake Michigan being drained for all different

kinds

uses. And probably some of you read National Geographic and you are aware

of the Arrow Sea disaster in the Soviet Union. The Arrow Sea was completely

drained within a period of 20 years by overirrigation. And it is a water body

one fourth the size of Lake Michigan. So they drained

I think it was 100

billion trilliongallons of water. It is practically gone. If you could just look it

up on the Internet, you will see.

Cindy Skrukrud. Resident,

Olin Mills. Mcllenrv County

First, relating to the State’s commitment to water conservation, ground water

withdrawals, McHenry County is one of the many counties in Illinois totally

dependent on ground water for our drinking water. Combined-cycle plants with

their massive need for water pose a real competitive threat to these water

supplies. This is an issue we need to address.

SPRINGFIELD HEARINGS

Illinois Section of American Water-works Association

—

Testimony of John Smith

and

Exchange with Chairman Mannin2 and Board Members Girard and McFawm

Number three: Should new or expanding peaker plants be subject to siting

requirements beyond applicable local zoning requirements? ISAWWA believes

that peaker plant siting requirements should encourage the siting of these plants

near a sanitary water treatment plant, if practical, so as to utilize the discharge

from the sanitary water treatment plant known as gray water or cooling water.”

We only wish to comment on the use of water resources by these facilities.

Number one, the State of Illinois must manage, protect and enhance the

development of the water resources of the state as a natural and public resource.

Number two, water resources have an essential and pervasive role in the social

and economic well-being of the people of Illinois and is of vital importance to

the general health, safety and economic welfare. Number three, water

resources of the state must be used for beneficial and legitimate purposes. And

number four, waste and degradation of water resources must be prevented.

ISAWWA is not opposed to the use of water resources by peaker plants. We

are only asking for the responsible use of water resources by these facilities and

all major new water consumers. We believe the regulation or permitting of

large water resource withdrawals should be the responsibility of regional

agencies, such as municipalities, counties or water boards, and that a state

agency should have oversight of these regional agencies.

We believe that the basis for the decision on how much water can be safely used

from a designated water resource be based on the existing knowledge and

scientific studies of that resource, and, if knowledge of that resource is lacking,

then additional research into the adequacy of this source should be done before

allowing major withdrawals. The decision to allow the development of existing

or new water resources must be based on sound science, not politics. We

believe that funding must be adequate for the state agency to perform these

studies.

In conclusion, Illinois Section AWWA is not opposed to peaker facilities. We

are calling for the rules and regulations of water resources be based on

scientific studies of our valuable water resources and that an unbiased state

agency be charged with oversight of regional water use. Adequate funding for

the state agency must allow for the scientific study of our state water resources,,.

and the State must have a plan for the efficient management of water resources.

Chairman Manning: Thank you for being here today. I do have just one

question. Are you aware of any projects right now that are ongoing between a

peaker plant developer and a sanitary treatment facility in the state we could

speak to?

Mr. Smith: I’m not aware of any

Board Member Girard: So what you’re advocating is that we have a state water

resources board that allocates these large withdrawals? Is that what you’re

saying:

Mr. Smith: What we are saying is that we believe a state agency such as the

Illinois State Water Survey should have some oversight over the regional

agencies that normally would have some control over water. We believe that in

most cases, the regional agency has at least some knowledge of the water

resource and how much of that resource can be used safely without impacting

other consumers or their industries. However, if the local agency has

—

unreasonably tries to restrict the use of these water resources, then a state

agency could have oversight of the local agency.

Board Member McFawn: Is your association involved at all with any studies of

water resources, be they groundwater or surface water, and their adequacy or

even just their quantity?

Mr. Smith: Yes, we are. illinois Section of AWWA is involved with the

Mahomet Aquifer Consortium, which has

—

is trying to secure federal funding

to do further studies of the Mahomet aquifer located in the central part of

Illinois. This consortium and the action that we are doing to try to study this

reservoir has already generated interest from other states in that they have

inquired how we have put together the consortium and how we are going about

to try and initiate these studies.

Our friends and neighbors are understandably worried about the impact of so-

called peaker plants on air quality and water supplies.

National Association of Water Companies. Testimony of Brent Gre2ory,

Representative of Illinois Chauter and Exchan2e with Board Members

Melas

and

McFawn

The ability to provide water of sufficient quality and quantity to sustain

commercial, industrial and residential growth goes hand-in-hand with the

availability of electrical power. Water suppliers rely on adequate available

electricity, and generating plants rely on an adequate supply

water.

NAWC

supports the development of new electrical generating capacity as needed for the

economic advancement of Illinois.

We do not believe that peaker plants pose a unique threat to the environment

compared to other types of state-regulated facilities. We believe that existing

environmental regulations are adequate to address air and water quality concerns

from peaker plants.

We emphasize the need for water use decisions to be based on sound scientific

assessment of local and regional water resources. Where existing knowledge is

insufficient, the state technical agencies should provide the scientific studies

needed to permit or deny water withdrawals. State funding must be adequate to

support these efforts. The right of existing public water supplies to condition

withdrawing at theircurrent installed capacities should be grandfathered into any

program that is developed. The state should consider competent third-party

assessments presented by those seeking to utilize the water resource.

We believe that permitting of new peaker plants and siting requirements should

encourage conservation measures such as recycling of cooling water and use of

other discharges for cooling when possible, such as those from sanitary

treatment plants.

In summary, NAWC believes that the ability to expand power and water

resources is important to the economic growth of Illinois.

Board Member Melas: Do you have any comments about the quantity of the

—

or the adequacy of particularly groundwater supplies?

Mr. Gregory: Well, we recognize that in certain areas of the state in particular,

there may be some quantity concerns. We’re traditionally known as a water-

rich state, and yet due to concentrations of industry and populations and other

circumstances, there are areas where, particularly in long-term outlook, water

quantity is a concern. That’s why we concur that there is a need for sound

comprehensive management of the state’s water resources with regard to

quantity.

Board Member McFawn: You mentioned you thought that the quantity

believe it was the assessment of it should be done by an independent third party?

Could you explain that a little bit more?

Mr. Gregory: Yes, I can. If there is some legislative or regulatory control set

up over the use of Illinois water resources, it needs to be based on sound

scientific assessment of the resource, which we believe that the state has

—

the appropriate

—

has the appropriate technical resources to conduct those.

However,

if there would arise a dispute

over the use or the application for the

use of water or withdrawal of water and there is better science to be presented

by a petitioner for the use of that water, that should be allowed.

Board Member McFawn: We are talking about just quantification, not quality?

Mr. Gregory: That is really in the context of quantity.

Mr. Gregory: If somebody wants to withdraw water from an aquifer or from a

watershed and is able to hire a qualified consultant to demonstrate the

reasonableness of that petition, then that should be considered.

Natural Resources Defense Council

—

Testimony of Patricio Silva and Exchange with

Board Member McFawn

Mr. Silva: The water withdrawals were in part because there was some

concern about adverse impact from the water withdrawals on the Hudson River

for several fish species in that section of the Hudson River. I cannot remember

offthe top of my head if there was any impacts for nesting birds, but I don’t

believe so.

Board Member McFawn: You said that NRDC was concerned about water

used in single-cycle units. I’ve always thought that the single-cycles didn’t

cause that concern and it was the combined-cycles.

Mr. Silva: A great many single-cycle combustion turbine projects that we’ve

seen

not just the few that we’ve looked at in Illinois, but

in elsewhere

across the country

rely on once-through cooling. Water is used once for

evaporative cooling at the inlet duct and then essentially discarded. That,

depending on the size of the unit

and remember, the single-cycle turbines,

we’ve seen anywhere from 80, some projects have 1,000 megawatts, so the

water demand is going to be quite dramatic. Some of the combined-cycle units

we’ve seen actually rely on dry cooling where there is essentially a process that

involves a closed loop and onetime withdrawal of water.

So the demands

—

even though the unit

—

the technology’s more efficient, in

some applications the combined-cycle units can be hogs as well. They can be

quite water intensive. So

—

But there is

—

there are technology options.

Exhibit from Reliant Energy

How much water will the plant use?

The plant does not require a large amount of water. Unlike many older plants,

Reliant Energy Aurora does not use steam to generate electricity and its demand

for water is similar to other light industrial uses. The primary use of water will

be to cool the air flowing into the units and to control emissions.

The only other uses of water will be for the purposes of employee sanitation and

for fire

The plant will use an average of only 300 gallons per minute (gpm) during the

summer months and that the peak water usage rate will be gpm. The water will

be provided from a deep aquifer well (Cambrian Ordovician650) which is at

least one mile away from any known deep aquifer wells in the area. Compared

with the water used in the City of Aurora on an annual basis, the maximum

consumption from this well is less than 1 of’ the city’s water use.

Public Comment #3

Ron Molinaro

Thirdly, there is the amount of water used. These plants can consume up tol 2

million gallons of water a day. At a recent Zion City Council meeting a

gentleman who owns a local confectionery company spoke of the possibility of

the expansion of his business. When checking into the accessibility of

additional water he discovered that the city of Zion exceeded its allocated

amount for 1999 by 22 million gallons. If we were to allow these plants to be

constructed in Zion, will there be enough water allocated for the expansion of

existing business or the construction of new homes? This is a question that

needs to be answered before we allow any power plants to be constructed in this

region.

Public

Comment #7

—

Susan

Zingle

Attachments to Public Comment #7 submitted by Susan Zingle

—

three letters

from the Illinois State Water Survey.

Attachments to Public Comment #7 Submitted by Susan Zingle

~LL~NOIS

illinois State Water Survey

Main Oflice

•

2204 GrUlith 

Drive

Chompcig”r. LàI820-7495• 

Tel f217,)333-2210~

Far (217,) 333o540

Peoria Office. P.O. Oox 697’ Peo;ic, 61652-0697-

Tel

(309)671-3196. Fox

(309,)

611-3106

D~p~TUL.~4D0’

~SrouncI.Wwer Section

•

Tel ~2J?~333-4300

•

fox(217):

December 4, 

1998

Mr. Robert Wargaski

Lake-Mel-lenry Environmental Cooperative

P.O. Box 134

Wauconda, IL 60084

Dear

Mr.

Wargaski:

This letter is in response to your request of December?, 1998, concerning the development of two

million gallons per day (rngd) ground-water supplies from the Cambrian-Ordovician-Age aquifer system

for the purpose of steam generation in electrical

power

generating facilities. One site (designated herein

as the Island Lake Project) will be located in the SWV4 of Section 9, T.44N., R.9E, Lake County. The

other site (designated herein as the Libertyville Project) will be located in the NE¼

of Section 12,

T44N., R.1OE., Lake County. The distance between these sites is approximately 9 miles. You have

asked the Water Survey to comment on the potential impacts these ground-water withdrawals may have

on surrounding water wells finished within the same aquifer system. You also inquired about ground-

water

law

and regulation. The following are responses to the specific questions you posed to~LheWater

Survey concerning this matter:

“The

proposed

Island Lake and Libertyr.’ille sites are wIthin JO miles of each other. Each would draw up

,7LiLl

LolL

gaUonx

of water per clay. ?lea~ccomment on the impact they would hcu~’èoperating together

and simultaneously on the aqu(fer and the surrounding community wells. Which com?nw-iity wells would

be affected by the interface drawdown.”

Withdrawal of ground water from a well may cause water levels in nearby wells-tapping-the-source

aquifer to decline. This water-level decline is referred

to

as interference drawdown or, more simply, as

interference. Interference drawdowrt decreases with increasing distance in all directions from a pumping

well, defining an inverted conical water-level surface around the well. This is known as the cone of

depression. The size and shape of the cone of depression created by a pumping well will depend on the

areal extent and hydraulic properties of the aquifer, the pumping rate, and the duration of pumping at the

well. When interference drawdown causes the water level in a well to decline-belowthe-pump-intake-(-ki

which case the pump breaks suction)or below a level at which the pump can lift the desired volume of

water to the surface, remedial measures such as lowering the pump setting or sizing a higher capacity

pump may be necessary to restore a normal supply.’ The risk posed by a pumping ~vellon the ability of a

nearby well to deliver its normal supply is, therefore, a function both of the amount of interference and of

various construction features of the affected well chiefly. the pump setting. dynamic head rating of the

pump, and well efficiency.

For the Island Lake and LibertyviUe Projects, nearby existing wells finished

within the Cambrian-

Ordovician-Age aquifersystem, pre-dating the Lake 

Michigan water

allocations to the area of question,

may not be severely impacted by the proposed well field because those wells were engineered and

I”

‘.~,d

‘j,,

r.~)-c1~~,l

J,’,p~’i

Mr. Robert E. WargaskilPage 2/December 4, 998

constructed when regional water levels were considerably lower 

than at present. Prior to Lake Michigan

water allocations, pump intakes in water wells were set at lower depths and had greater water lifting

capacities because of lower ground-water

levels 

caused by regional pumpage. However, wells fi~ishcd

the deep sandstones within the last few years could see more severe impacts because they were

consiructed after the regional “recovery” of water levels within the Cambrian-Ordovician-Age aquifer

system.

The impact of the withdrawal of 

mgd from two sites on ground-water levels with 

the

Cambrian-

Ordovician-Age aquifer system was determined through the use of ananalyticaLmathematicat model

using regional values for the hydraulic properties of this aquifer system. The use of this model required

that significant assumptions

be made to simplify the natural variability often encountered-in-aquifer

systems. Assumptions include homogeneous and isotropic aquifer hydraulic 

prep-erties~(asopposed to

properties that may vary vertically and horizontally in three dimensions), no ground-water recharge,

infinite aquifer extent (as opposed to geologic and hydraulic features which may limit the size of the

aquifer), and a continuous pumping schedule (as opposed to a time-variantpumping rate).

The hydraulic properties and pumping scenarios were assumed to be identical at the Island Lake

and

Libertyville Projects sites. As you requested,

each 

proposed well field pumped simultaneously in

our

model simulation. For purposes of

construction of

the

model, we

assumed

each

well field would consist

of eight wells (finished in the St. Peter and Ironton-Galcsville Sandstone

aquifers) supplying 5 

rngd

(about 434 gallons per minute each) on a continuous

basis for 20 years. Given these parameters, the

model provided the graphic output shown in accompanying Pignre 1.

Under the pumping and hydraulic conditions described in

the above scenario, mutual interference effects

between the well

fields 

may cause water level declines of as much as 280 feet. Interference effects

decline to approximately 150 feet at 12 miles.

This analytical model also suggests that as much as 520 feet of drawdown would be observed in the

centers of each well field. This would lower the potentiometric head of the Cambrian-Ordovician-Age

aquifer in the study area into the St. Peter sandstone. Dewatering of any artesian aquifer can lead to the

reduction in pumping capacity.

For a properly designed well field, the Cambrian-Ordovician-Age aquifer

should be nble 

yield the desired quantity of water on a suscairtablebasts.

Given the possibility that the aquifer properties, number of pumping wells, well spacing, pumping

rates,

pumping

periods, and total pumpage ofthe proposed wells may be different then 

whet

was

assumed for

this report, we recommend a more detailed analysis be made of th-enumber of existing wells and their

distance from the proposed high-capacity well fields. In addition, static water levels, pumping water

levels, and pump intake settings of

nearby water wells 

could be analyzed to determine if, and which.

domestic, industrial, or municipal water wells would be potentially impacted.

Pumping water from this aquifer in the Island Lake and Libertyville areas has wider ranging effects than

simply being a local phenomenon. Consideration should be given to the effects on the practical sustained

yield of the

entire aquifer system including 

the effects of pumping on ground water within the State of

Wisconsin. The aquifer system is currently being pumped at. or slightly above, its estimated practical

sustainable yield of

mgd per day. Further development is likely to contribute to the mining of ground-

water in northeastern Illinois. A more sophisticated ground-water model of northeastern Illinois, one that

Mr. Robert E. WargaskilPage 3/December 4,

1998

can incorporate regional variations

in aquifer properties (unlike 

the simplistic analytie~-model we

used

to calculate drawdowns for this letter), would be a very important planning tool for state 

and local

governmental leaders

to have available to 

theta

in their efforts tomange-thisnattwaLresource

recommend that a three-dimensional numerical ground-water model be used to better predict what

long-term impacts the proposed ground-water development 

would have on the Cambrian-Ordovician-Age

aquifer 

in northeastern Illinois. The Illinois State WaterSurvey has previously modeled this aquifer

system (Prickett 1971, Visocky 1982, Burch 

1991); however, the WaterSurvey’s most recent model

(Burch 1991)

will need extensive updating. A three-dimensional numerical ground-water model could

incorporate natural variations 

in aquifer

properties, thickness, and withdrawals from existing high- 

capacity wells. Such a model would also allow studying the aquifer in a more regional context.

To reiterate, estimates of water-level decline contained in this letter were determined from a-strictly

theoretical consideration of aquifer hydraulics, making use of regional aquifer property data. More

accurate estimates would be possible given better aquifer property data and recharge rate.s collected

through properly conducted “on-site” aquifer tests. It is possible that the predictions in this letter will

not

prove to be accurate. We, therefore, recommend that further study be made of this particular issue. The

Illinois State Water Survey has the expertise to provide these services to the resid-ents-of-Lake and

McHenry Counties; however, such involved research would require a contractual agreement

(administered through 

the University of illinois) between interested parties and the Water Survey.

As to your question relating to whichmunicipal water wells would be affected by the theoretical well

lields. the total number at wells tmpacted anti corresportdtng economic repercussions are impossible to

quantify at this time without further in-depth study.

‘Does Illinois have any regulations on the limit: of water that ca,~-bc-drawn-from-thc-aq~frr? Do other

States have limits and

which ones,”

The State of Illinois does not have

any

specific laws that limit growid-water-withdrawals. The Rule of

Reasonable Use allows “property owners to unlimited and non-permitted use of the water beneath their

land

as long as the 

use is ‘reasonable’ and injury to a neighboring well does not arise but of malice” as

stated by Bowman (1991). 

We suggest

that you contact Mr. 

Gary Clark of the Office of Water

Resources, Illinois Department of Natural Resources, at (217) 785-3334 for further information on this

matter. Mr. Clark is one of the State’s leading experts on ground-water law, and we are confident he will

be able to address

any ground-water law 

related questions that you pose to

him. For your information,

we have enclosed a copy of an Illinois Department

of Transportation 1985 report to the Illinois

Groundwater Association

Illinois Groundwater Law: The Rule of Reasonable Use.

Mr. Clark is the

author of this document. We are also enclosing a copy of Illinois State Water Survey Report of

Investigation 114

Ground-Water Quantity L.aws and Management,

for additional discussions of Illinois

ground-water laws and the law practiced in several other midwestern states.

“What i.c the cha.~zgcin the level of the deep sandstone aquifer since conm,,ZL,niiies swirch~dfrom aqu~/’er

wells

Lstke Michigan

water.”

For your information 

on this particular subject, we have enclosed Illinois State \Vnter Survey Circular

182

Water-Level and Pumpage in the Deep Bedrock Aquifers in the C’hicago Region, 1991-1995.

This

Mr. Robert E. Wargaski/Page 4/December4, 1998

publication is an excellent resource for the analysis of water level trends in the Cambrian-Ordoviciari-

Age aquifer system. 

Figure 9

on page 30 

of this document shows changes in the potentiometric surface

the deep bedrock aquifers

between 1991 and 

1995.

In Lake County, therewere areas

that observed 

aim

increase in water levels (potentiometric head) of over 250 feet. Wauconda Municipal Well 4, located

Section 24, T.44N., R.9E., Lake County, experienced a rise in ground-water levels of 45 feet between

1991 and

1995.

With the growing population trend in Lake and McHeniy County, what (ilnitations

would

you suggest

be incorporated to protect the aquifer and keep it healthyforfuture gezrerations.”

The Illinois State Water Survey is a strictly an objective scientific organization. We do not make, nor do

we enforce,

rules and regulations. However, 

our research and guidance is often utilized in the

development of water-related laws and statutes. In the case of the issues addressed in this letter, we have

the knowledge and expertise to offer the citizens and their governmental

representatives 

to make

informed decisions about how to develop their natural resources. However, additional research will be

needed before we can more accurately address yotir many concerns.

For your 

information, I have enclosed all prior letter correspondence that deal with power generation in

Lake and 

McHcnry County

arca~.-

can be of

~imy

further assistance, p1ea~efeel free

to call or write.

Sincerely,

Andrew

Cr.

Buck, P.O.

/4\

ANDREW G. BUCK

(217) 333-6800     

\~9O0O65~,,,,J

iLLIN0~S

Enclosures as 

stated

cc~

Winstanley, ISWS

l3howmik, ISWS

Roadcap, ISWS

Clark, IDNR-OWR

I-

Lt)

-‘5

I-

Drawdown

created by

two

welifields

each pumping 5 MGD

from

8 Wells.

(1 15,000 gpd/ft, S 0.0004)

160

~QO~

1;.

240 -~

RQE

R1OE       

RilE

LL N

Illinois State Water Survey

Main Ottice 2204 G4fi~hDrive ‘Cbompcigri. 0.6 820-7495’

Tel (217,) 333-2210- tOx (217) 333.o5~C

Peoria

OlOce. P.O. Box 697’ Peoric.

I~,

61652-0697’ Tel ~3O9~67i-319ô‘Fax

f309,)

67I-3I0~

W.~TU~AL

P,E5OU R (ES

Ground-Wotar Section

Tel

(217,) 333.43w

•

Fax(217) 2~!4-0777

Decembcr 2, 1998

Mr. Kenneth C. Hopps

Natural Gas Pipeline Company of America

747

East

22’~’Street

Lombard. Illinois 60 148-5072

Dear Mr. Hopps:

This lerter is in response to your request concsrning the development of a 2.5- million gallon per day

(mgd) ground-water supply from the Carnbrian-Ordovician-Age aquifer system for the purpose of

steam generation in an electrical power generating facility, We understand that the proposed power

plant wilt be located in the SW’/s of Section 9,T.44N,, R.9E., Lake County. You have asked the

Illinois State Water Survey to comment on the potential impact this ground-water withdrawal may

‘nave on surrounding water wells finished within the overlying unconsoiidatedraad~andgravel

deposits and Silurian-Age dolomite bedrock aquifer. It should be noted that the Water Survey has

previously provided estimates of theoretical water level drawdowns in the Cambrian-Ordovician-

Age aquifer system given several different water withdrawal scenarios. These previous letter reports

to your company were dated September 3 and October 13, l99S, and addressed the interference

effects caused by a theoretical well field on wells finished within the Cambrian-Ordovician-Age

aquifer.

Withdrawal of ground water from a well will cause water levels in nearby ~ve11stapping the source

aquifer to decline. This water-level decline is referred to as interference drawdown or, more simply,

as interference. Interference drawdown decreases with increasing distance in all directions from a

pumping well, defining an inverted conical water-level surface around the well known as the cone

depression. The size and shape of the cone of depression created by a pumping well will depend on

the areal extent and hydraulic properties of the aquifer, the pumping rate, and the duration of

pumping at the ~vcli. When interference drawdown causes the water level in a ~vellto decline below

the pump intake (in which c~sethe pump breaks Suction) or below a level at which the pomp can lift

the desired volume of water to the surface, remedial measures such as lowering of the pump setting

or sizing a higher capacity pump may be necessary to restore a

normal supply. The risk posed by 

pumping well on the abilIty of a nearby well

to deliver its normal supply is, therefore, 

a function both

of the amount of interference and of various construction features of the affected well

chiefly the

pump

SCItiUC,

dynamir head rating of the pump, and well efficiency.

With respect to your question, the key variable when determining whether a well(s) withdrawing

ground water will adversely impact a nearby well(s) is dependent on the hydraulic connection

Pr,,::ed,n~r,’,~Cicd

on’s-i’

Mr. Kenneth C. HoppsfPagc 2lDecember 2, 1998

bc~weenthe source aquifers. In 

this case, you have asked us to address the potential impacts on

wells finished itt the unconsolidated sand and gravel deposits above bedrock and

wefls

completed in

the Silurian-Age dolomite when the deeper lying Cambrian-Ordovician-Age sandstone aquifers arc

pumped. For your reference, we have enclosed an excerpt from Illinois State Water Survey Circular

182, titled

Water-Level Trends and Pwnpagc in (he Deep Bedrock ~4quifcrs in the chicago

Region, 1991-1995

(Visocky et al.,

1985,

page 6 and 7, figure

2), which shows the 

stracigraphy,

water-yielding properties of the rocks, and the character of the ground water in northeastern Illinoi.c.

In this part of Illinois, the Ordovician-Age Maquoketa shale separates the unconsolidated materials

and Silurian-Age dolomite from the deeper lying Cambrian-Ordovician-Age (St. Peter and Ironcon-

Gatesvi I Ic sandstones) aquifers.

The Maquokeca shale is approximately 105 feet thick in the area of interest. Under natural

conditions, the Maquokeca acts as an effective hydraulic barrier between the upper (sand and gravel

and dolomite) andlower (Cambrian-Ordovician-Age sandstones) aquifer systems. Consequently,

changes in ground-water levels in the Cambrian-Ordovician-Age are relatively independent of those

in the shallower aquifer systems. Given this, pumping the Cambrian-Ordovician-Age aquifer system

should not affect water levels in the shallower sand and gravel and-dolomite aquifers. It should be

noted that this assumes that a well finished in the Cambrian-Ordoviciart-A.ge sandstones must be

constructed such that the geologic materials from the Ordovician-Age St Peter sandstone and above

are “cased off”. An “open” bore hole hydraulically connecting the Silurian-Age dolomite and

dcepcr-lyir.g sandstone formations would render the above coaclusions false. Water levels itt the

shallower aquifers probably wilt be impacted by water withdrawals from the Cambrian-Ordovician-

Age sandstone aquifers if the geologic materials above the St. Peter sandstone were not sealed off by

well casing

If we can be of any further assistance, please feel free to call or write.

Sincerely.

Andrew 0. Buck, P.O.

Assistant Hydrogeologist

Ground-Water Section

Phone: (217) 333-6800

agb/psl

Enclosure as stated

I ~.

r~:

0 I S

Illinois State Water Survey

Mom Oltice ‘2204 Gti(fiIh

Dike ‘Cho~pcQn.

II 6l~2C~’.95

Tat (217)333.2210

Fox ~2!7~

33J.o5~0

PeorioOl’Oce -P.O. Cox ô~7

- ?eoriO. II.

olo52.o~c7

Tel (309) 67l’39o ‘Fax

(30c)

671.3106

olrAIT~l~H~a,

N.ATUR.

Ground-Wale; SecTion.

TCI

(2l7)333-~3C0

October I, l99S

Mr. Stan A. Smogorzewski

LS Power, LLC

13522 Calais Drive

Del Mar, California 92014

Dear 

Mr.

Smogorze~vski:

This letter is in response to your request concerning the development of a 10.8 million gallon per day

(mgd) ground-water supply from

the

Cambrian-Ordovician-Age aquifer system for the purpose of

steam generation in an electrical power generating facility. We understand

that you are considering

two sites 

for this facility. One site (designated herein as McHcrtry Project) will be partially Located

in the E½of the NE¼,of SectionS, T.44N., R.9E., McHcnry County and partially

the

NWV4

Section 9, T.44N,, R,9E., Lake County. Thc other site (designated herein as Lee Project) will be

located 

in the NY2 of the SEY3 of Section 32, T.21N., R.8E., Lee

County. You have asked 

the Water

Survey to comment on the potential impacts these ground-water withdrawals may have on

surrounding 

water wells finished

within the same aquifer system given this 

pumping rate over a I-

year period. In this letter report, we will address the theoretical impact that a 7,500 gallon per

minute (gprn) ~velLmay have 

on ground-water leveLs within the Cambrian-Ordovician-Age. aquifer

system.

Withdrawal of ground water from a well will cause water levels in nearby wells tapping the source

aquifer to decline. Th~~water-level decline is referred to as interference drawdown or, more simp!y.

as interference. Interference drawdown decreases with increasing distance in all

directions from a

pumping well, defining an inverted conical water-level surface around the well known as the cone of

depression. 

The size arid shape

of the cone of depression created by a pumping 

well will-depend on

the areal extent and hydraulic properties of the aquifer, the pumping rate, and the duration of

pumping

he well. When interference drawdown causes the water level in a well to decline below

the pump intake (in which case the pump breaks suction) or below a level at which the pump cam’. lift

the desired volume of water to the surface, remedial measures such as lowering of the pump setting

am, sizing a higher capacity pump may be necessary to restore a normal supply. The risk posed by a

pumping well on the ability of a nearby well to deliver its normal supply is, therefore, a function both

of the amount of interference and of various construction features of the affected well

chiefly the

oump setting, dynamic head radng of the pump, and well efficiency.

For the Mci-Ienry Project, nearby existing wells finished within

the Cambrian-Ordoviciarm-Agc

aqui1c~system. pre-dating the Lake Michigan water allocations to the area of question. may not be

severely impacted by the proposed well field because those wells were engineered and constructed

when regional water

levels

were considerably lower than at present. Prior to Lake Michigan water

,.,,,

Mr. Stan Smogorze’.vskifPage 2/October 1, 1998

allocations, pump intakes in water welts were set at lower depths and had greater water lifting

capacities because of lower ground-water levels caused by regional pumpage. Ho~v~ver,wells

finished in the deep sandstones within the last few years could see more severe impacts because they

were constructed after the regional “recovery” of water levels within the Cambrian-Ordovician-Age

aquifer system. This

situation 

does not apply to the Lee Project because water levels in that area

have not been regionally lowered.

The impact of the withdrawal of 7,500 gpm on ground-water Levels with the Cambrian-Ordovician-

Age aquifer system were determined through the use of an analytical mathematical model using

regional valucs fo~the hydraulic properties of this aquifer system. The usc of this model required

significant assumptions be made to simplify the natural variability often encountered in aquifer

systems. Assumptions include homogeneous and isotropic aquifer hydraulic properties (as opposed

to properties that may very vertically, horizontally,

and with direction), infinite 

aquifer extent

(as

opposed to geologic and hydraulic 

features which may limit the size of the aquifer), and a continuous

pumping schedule (as opposed to a time-variant pumping rate).

Because the hydraulic properties and pumping scenarios were assumed to be identical at the

McHenry and Lee Projects, the distance-drawdown estimates shown below apply to both sites. As

you requested, the proposed well field was assumed to consist of only one well (finished in the St.

Peter and J.rotmton-Galesville Sandstone aquifers) supplying 10.8

mgd (7,500 gpm) on a continuous

basis for one year. Given these parameters, the model provided the following distance-drawdown

relationships (also see the enclosed distance-drawdown plot and map):

flic’a,’ee frpni nnrnned well

Drawdown after mm-tome -veer

mile              

350 feet or less

miLe

285 feet or less

I mile

225

feet or less

2 miles

170 feet or less

3 miles

135 feet or less

4 miles

110 feet or less

5 miles               

90 feet or less

Although these impacts are considerable. the available drawdown in

deep sandstone wells is

probably adequate for the desired 

amount of ground-water yield, assuming a properly designed well

field. The number of wells

impacted and corresponding economic repercussions are 

impossible to

quantify at this time without further in-depth study.

Given

the possibility that the

aquifer properties, number of pumping

wejls. well spacing,

pumping

rates, pumping periods, and total pumpage of the proposâd wells may be different than what was

assumed for this report. we recommend a more detailed analysis be made of the number of weLls and

their distance from the proposed high-capacity wefl field. In addition, static water levels, l)U~P~

water levels, and pump intake settings of nearby water wells could be analyzed to determine if, and

Mr. Stan Srnogorzewski!Page 3/October 1, 1992

which, domestic, industrial, or municipal water ~vclIswould be potentially impacted. Also, i would

be prudent to ruti a sophisticated numerical ground-water model to better predicc

~hatlong-term

impacts the proposed ground-water development would have on the Cambrian-Ordovicittn-Age

aquifer in northeastern Illinois. Such a model could incorporate natural variations in aquifer

properties, thickness, and withdrawals from existing high-capacity wells. This would be a very

important planning

tool for local 

governmental leaders to have available to them in their efforts to

manage this natural resource.

Another issue in any use of water from

the

Cambrian-Ordovician-Age aquifer system- is water

quality. There are reports of radioactive isotopes associated with these waters which can be a faccor

in its use.

To reiterate, estimates of water-level decline contained in

this letter were determined from a strictly

theoretical consideration of aquifer hydraulics, making use of regional aquifer property data. More

accurate estimates would be possible given better aquifer property data collected through properly

conducted “On-site” well tests. It is possible that the predictions in this letter will not prove to be

accurate. We, therefore, recommend that further study be made of this particular issue. The Illinois

State Water Survey has the expertise to provide these services to LS Power and the citizens of Lake,

McHenry and Lee Counties: 

however, such involved research would require a contractual agreement

(administered through the University of Illinois) between your firm

and

the Water Survey.

To further your knowledge 

of the water resources of the deep sandstones aquifers of Illinois, we have

enclosed Cooperative Report 10, titled

Geology. Hydrology, and Water Quality of 1/ze cambrian

and Ordovician Syste,ns in Non/tern Illinois

and Illinois State Water Survey Circular 182, titled

Warer-Ler’el Trends and Pw-npage in I/ac Deep Bedrock.Aquifers in the Clrica~jRegion, 1991-

.1995.

If we

can

be ofanyfurthcr assistance, please feel free to call or write.

Sincerely.

Andrew G. Buck

Assistant Hydrogeologist

Ground-Water Section

Phone: (217) 333-6800

ngb/psl

Enclosures as stated

200

400

600

800

1000

1200

Regional drawdown in the Cambrian-Ordovician aquifer

produced by

well pumping 7500 GPM.

(1= 20,000 gpd/ft2,

00004, time

I year)

I~i~rJi

I 1TT11

Tm~TT

li I m

-1

Dist:

(mies)

Regional drawdown in the Cambrian-Ordovician aquifer

produced by

well pumping 7500 GPM.

(T= 20,000 gpd/ft2, S

0.0004, time

1 year)

Distance (miles)

SUMMARY OF WATER QUANTITY LAWS FROM

MIDWESTERN STATES

IOWA

Statute: Code of Iowa, 455B (1999)

Regulatory Entity: Department of Natural Resources; Environmental Protection

Division

Summary: Permit is required for any person who diverts, stores or withdraws more

than 25,000 gallons of water per day (surface or groundwater); Permits are generally

issued for 10 years but, depending on geological conditions, can be for lesser period of

time; Permit program insures consistency in decisions on allocations; Allocations

based upon concept of “beneficial use” the key points of which are (1) water resources

are to be put to beneficial use to the fullest extent; (2) waste and unreasonable uses are

prevented: (3) water conservation is expected; (4) established average minimum

instream flows are protected: Administrative process resolves water use conflicts;

Provisions in place for public involvement in issuing water allocation permits and in

generally establishing water use policies.

MINNESOTA

Statute: Minnestota Siatute 103G.265

Regulatory Entity: Department of Natural Resources; Waters Office

Summary: Permit is required for all users withdrawing (surface and groundwater)

more than 10,000 gallons per day or I million gallons per year (Exceptions include:

domestic uses serving less than 25 persons, certain agricultural drainage systems, test

pumping of a groundwater source, and reuse of water already authorized by permit,

e.g., water purchased from a municipal water system); Permits granted for no longer

than

years; Policy: to manage water resources to ensure an adequate supply to meet

long-range seasonal requirements for domestic, agricultural, fish and wildlife,

recreational, power navigation, and quality control purposes; Water Appropriation

Permit Program exists to balance competing management objectives that include both

development and protection of Minnesota’s water resources; Permitted users required

to submit annual reports of water use; Reported information used to evaluate impacts

and to aid in resolving conflicts.

OHIO

Statute: Ohio Revised Code Sections 1521.16; 1521.17; Sections 1501.30 and

1501.33

Regulatory Entity: Department of Natural Resources; Division of Water

Summary: Permits are required for those making a new or increased consumptive use

of water greater than an average of 2 million gallons per day over a 30-day period;

Registration is required for

any facility 

or combination of facilities with the capacity to

withdraw more than 100,000 gallons of water (surface or ground) daily; Chief of DNR

Division of Water has authority to designate “ground water stress areas” and to require

water withdrawal registration in these areas for users of water less than the normal

100,000 gallon threshold; Annual reporting is required of those who must register;

Purpose of registration and reporting requirements: to gather data to assist in resolving

future water use conflicts; Chief also has responsibility to maintain Water Resources

Inventory which must include information to assist in determining the reasonableness of

water use; While “reasonable use” is used by courts to determine water conflicts,

legislature has set forth nine specific factors (applicable to both surface and

groundwater) which define reasonableness; Consumptive use is defined as a use of

water resources, other than a diversion, that results iii a loss of that water to the basin

from which it is withdrawn and includes, but is not limited to, evaporation,

evapotranspiration, and incorporation of water into a product or agricultural crop.

INDIANA

Statute: Indiana Code, 14-25

Regulatory Entity: Department of Natural Resources (DNR); Natural Resources

Commission (NRC)

Summary: Registration and annual reporting requirement for owners of significant

water withdraw facilities (withdrawal of 1,000,000 gallons per day of surface water,

groundwater, or euiiibiuatioai); NRC has statutory authority to require, by rule, a

permit for most water withdrawals from navigable waters, but authority has not yet

been exercised; NRC is required to develop and maintain inventories, gather and

assess all information needed to properly define water resource availability; NRC can

establish, by rule, minimum stream flows; Where groundwater threat, DNR may

designate a “restricted use area.” Permit then required for withdrawal of more than

100,000 gallons per day beyond use at time of restricted use designation; In granting or

refusing a permit, the DNR considers the concept of beneficial use.

MISSOURI

Statute: Missouri Revised Statutes, Chapter

256

Regulatory Entity: Department of Natural Resources (DNR)

Summary: Major water users must register with DNR; A major water user is defined

as an entity that is capable of withdrawing or diverting 100.000 gallons or more per day

from any water source; Failure to register may result in DNR request that Attorney

General file action to stop all withdrawal or diversion; Purpose of registration program

is to insure the development of information required for the analysis of certain future

water resource management needs.

WISCONSIN

Statute: Wisconsin Statutes, Chapter 281; DNR Rules, Chapter

NR 142

Regulatory Entity: Department of Natural Resources (DNR)

Summary: Wisconsin law provides for (1) development of statewide water quantity

resources plan; (2) registration and annual reporting (with fees) of major withdrawals

(over 100,000 gallons per day in 30-day period); (3) permit approval process (with

administrative hearing process) for construction, development and operation of wells

where capacity and rate of withdrawal of groundwater from

all wells on one property

in excess of 100,000 gallons a day;

Specifics ofPermit Approval Process:

90-day

approval process. Approval withheld or restricted if withdrawal will adversely effect

or reduce availability of public utility water supply or doesn’t meet grounds for

approval which are: (a) No adverse effect on public water rights in navigable waters;

(b~No conflict with any applicable plan for future uses of waters of state or water

quantity resources plan; (c) Reasonable conservation practices have been incorporated;

(d) No significant adverse impact on environment and ecosystem of the Great Lakes

basin or the upper Mississippi River basin; (e) Plan for withdrawal consistent with the

protection of public health, safety and welfare and not detrimental to public interest; (f)

No significant detrimental effect on the quantity and quality of the waters of the state;

(Even more factors apply if the proposed withdrawal will result in an “interbasin

diversion). Regulations define water loss and consumptive use; Also, permit is

required for any diversion of water from any lake or stream for diversions of 2,000,000

gallons per day in any 30-day period; If DNR receives application for a withdrawal

from

the Great Lakes

basin

that will

result

in a new water loss averaging 5,000,000,

gallons per day in any 30-day period, DNR notifies governor of other Great Lakes

States, requesting their input. The rules incorporate methods for citizens to initiate

DNR investigations of alleged violations.