APPENDIX G
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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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
5,
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
1.
Charles Fisher,
Executive Director,
Illinois Commerce Commission
2.
Thomas
Skinner, Director,
JEPA
3.
Christopher Romaine, Manager,
Utility Unit,
Permit Section,
Division
of Air Pollution
Control, Bureau of Air, JEPA
4.
Robert Kaleel,
Manager of Air Quality Modeling Unit,
Division of Air Pollution
Control,
Bureau of Air,
TEPA
5.
Greg Zak, Noise Advisor,
IEPA
6.
Steve Nightingale, Manager, Industrial Unit,
Bureau of Water Permits Section, IEPA
7.
Rick Cobb,
Manager,
Groundwater Section,
Bureau of Water,
IEPA
8.
Todd Marvel,
Assistant Manager of Field Operations Section and
RCRA
Coordinator! USEPA Lialson/IEPA
9.
Brian Anderson,
Director, Office of Scientific Research and Analysis,
IDNR
10.
Derek Winstanley.
Chief,
Illinois
State Water
Survey, IDNR
August 24,
2000
1.
Gerald Erjavec,
Business Development,
Indeck Energy Services, Inc.
2.
Greg Wassilkowsky,
Mauager, Business
Developnient,
Indeck Energy Services,
Inc.
3.
Arlene Juracek, Vice President,
Regulatory and Legislative Services,
CornEd
4.
Steve Nauman, Vice President, Transmission Services,
CornEd
5.
Deirdre Hirner,
Executive Director,
IERG
6.
Richard Bulley,
Executive Director of Mid-America Interconnected Network
7.
Freddi Greenberg,
Executive Director and
General Counsel, Midwest Independent
Power Suppliers
8.
Michael
Kearney, Manager,
Economic Development, Ameren Corp.
9.
Richard Trzupek, Manager, Air Quality,
Huff & Huff
Suburban
Hearings
Naperville
September 7. 2000
I
Mayor George Pradel,
Naperville
2.
State
Senator Chris Lauzen
3.
State Representative Mary Lou Cowlishaw
4.
Mayor Vivian Lund,
Warrenville
5.
Paul Hass, Zoning Manager, DuPage County Department of Development
Environmental Concerns
6.
Richard Ryan, President
and Chairman,
Standard Power and Light, Oak Brook
7.
Diana
Turnball, Consultant to variety of citzen groups, private foundations and
businesses
who have been
in opposition
to some
of the peaker plants
8.
Carol Dorge,
Attorney representing
Lake County Conservation Alliance
9.
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
2
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
1.
Dr.
Thomas Overbye, Associate Professor,
Department of Electrical and Computer
Engineering, University
of Illinois,
Champaign-Urbana
2.
Alan Jirik,
Director,
Environmental Affairs,
Corn
Products
International, Inc.
3.
Carol Stark, Director, Citizens Against
Ruining the
Environment, Lockport
4.
Susan Zingle,
Executive Director,
Lake County Conservation Alliance
5.
Keith Harley, Chicago Legal Clinic
6.
Elliot
“Bud”
Nesvig
7.
Michael
Shay,
Senior Plamier Responsible for Long-Range Planning,
Will Counly
Gravslake
SeDtember 21,
2000
1.
State Senator Terry Link
2.
State Representative Susan Garrett
3.
Tom Lynch, Trustee, Libertyville Township
3
4.
Betty Rae Kaiser, Trustee,
Village of Wadsworth
5.
Daniel
J.
Kucera, Chapman
& Cutler,
appearing
on behalf of the Lake County Public
Water District
6.
Jim LaBelle,
Chairman, Lake County Board
7.
Sandy
Cole, Commissioner, Lake County Board
8.
Bonnie Carter,
Commissioner, Lake
County Board
9.
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
4
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
5.
2000
1.
Roger Finnell, Engineer. Division of Aeronautics,
Bureau of Airport Engineering,
IDOT
2.
John Smith,
Representative of Illinois Section
of American Waterworks Association
3.
Brent Gregory, Representative of National Association of Water Companies,
illinois
Chapter
4~
James R~Monk,
President,
Illinois Energy
Association
5.
Patricio Silva, Midwest Activities Coordinator, Natural Resources Defense
Council
6.
Brian Urbaszewski,
Director, Environmental Health Programs, American Lung
Association
7.
Elliot
“Bud”
Nesvig
8.
Carol Dorge,
Attorney representing
Lake County Conservation Alliance
October
6.
2000
I.
Susan Zingle,
Executive Director,
Lake County Conservation Alliance
2.
Scott Phillips,
Attorney, IEPA
5
3.
Kathleen Bassi, Attorney, IEPA
4.
Chris Romaine, Manager, Utility
Unit, Permit Section,
Division of Air Pollution
Control,
Bureau of Air, IEPA
5.
Greg Zak,
Noise Advisor, IEPA
6.
Todd Marvel,
Assistant Manager
of Field Operations
Section
and RCRA
Coordinator/USEPA Liaison/IEPA
7.
Steve
Nightingale, Manager, Industrial Unit,
Bureau of Water Permits
Section, IEPA
6
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 golfcourse 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
50
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
80
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
5
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.
4
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,
5
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
6
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 ifeither.
Water supply is not a local issue
7
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.
We
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.
8
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
9
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
an
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.
to
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
of
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.
It
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
12
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
5
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
13
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
14
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
15
***
Board Member Kezelis:
I
just have a question.
Can you
for
the record
tell
us
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 ifnumerous
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.
16
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
17
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
18
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
19
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
20
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
65
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
55
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.
-
21
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
of
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, ifpractical,
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
23
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,
ifthe 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
evenjust 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
of
water.
NAWC
supports
the
development of new electrical generating capacity
as needed for the
economic advancement of Illinois.
24
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
--
I
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
—
is
the appropriate
—
has the appropriate technical resources
to conduct those.
However,
ifthere 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.
25
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.
26
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.
27
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.~4D
0’
~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
5-
million gallons per day (rngd) ground-water supplies from the Cambrian-Ordovician-Age aquifer system
for the purpose
of
steamgeneration 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 theLibertyville 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 waterwells 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~Lhe
Water
Survey concerning this matter:
“The
proposed
Island Lake and
Libertyr.’ille sites are
wIthin
JO milesof each other.
Each would draw
up
to
$
,7LiLl
LolL
gaUonx
of water per
clay.
?lea~ccomment on
the impact they
would hcu~’è
operating
together
and simultaneously
on the aqu(fer and thesurrounding
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 apumping
well, defining an inverted
conical water-level
surface around thewell.
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 waterlevel in a well to
decline-belowthe-pump-intake-(-ki
which case the pump breaks suction)or below a
level at whichthe pump
can
lift the desired volume of
waterto thesurface,
remedial measures such as loweringthe pump setting or sizing a highercapacity
pump may be necessary to restore a normal
supply.’
The risk posed by apumping ~vellon
theability
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 ofquestion,
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 considerablylower
than at present.
Prior to
Lake Michigan
water allocations, pump intakes
in waterwells were set at lower depths and had greater waterlifting
capacities
because of lower ground-water
levels
caused
by regional
pumpage.
However, wells fi~ishcd
in
the deep sandstones within the last fewyears could see more severeimpacts because they were
consiructed after the regional “recovery”of water levels within the Cambrian-Ordovician-Age aquifer
system.
The impact of the withdrawal of
5
mgd from two sites on ground-waterlevels with
the
Cambrian-
Ordovician-Age aquifer system wasdetermined through theuse of ananalyticaLmathematicat model
using regional values for the hydraulic properties ofthis aquifer system. The use ofthis model required
that significant assumptions
bemade to simplify thenatural variability often encountered-in-aquifer
systems.
Assumptions includehomogeneous and isotropic aquiferhydraulic
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-variantpumpingrate).
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-GalcsvilleSandstone
aquifers) supplying5
rngd
(about434 gallons
per minute
each) on a continuous
basis for20 years. Given theseparameters, 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 aproperly designed well field, the Cambrian-Ordovician-Age aquifer
should be nble
Co
yield
the desired quantity of water on asuscairtablebasts.
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
proposedhigh-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 waterfrom
this aquifer
in the Island Lake and Libertyville areas has wider ranging effects than
simply being a local phenomenon.
Consideration should
be given to theeffects
on
the practical sustained
yield of the
entireaquifer 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
65
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 calculatedrawdowns for this letter), would be averyimportant planningtool for state
and local
governmental
leaders
tohave available to
theta
in their efforts tomange-thisnattwaLresource
We
recommend that athree-dimensional numerical ground-watermodel be used to betterpredict what
long-term impacts theproposed ground-waterdevelopment
would
have on
the
Cambrian-Ordovician-Age
aquifer
in northeastern
Illinois.
TheIllinois State Water
Survey has previously modeled
this
aquifer
system (Prickett 1971, Visocky 1982, Burch
1991); however, the
Water
Survey’s most recent
model
(Burch
1991)
will need extensiveupdating. A three-dimensionalnumerical ground-water model could
incorporate natural variations
in aquifer
properties, thickness, and withdrawals fromexisting 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 dataand 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 theexpertise 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 WaterSurvey.
-
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 longas the
use
is
‘reasonable’
and injury to a neighboring well does not arise but of malice” as
stated byBowman (1991).
We suggest
that youcontact 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
oneof 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. Foryour 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~d
from
aqu~/’er
wells
to
LstkeMichigan
water.”
For your information
on this
particular subject, we have enclosed Illinois State
\VnterSurvey 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 aquifersystem.
Figure 9
on page 30
of this document shows changes in the potentiometric surface
of
thedeep 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
in
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
informeddecisions about how
to develop their natural
resources.
However,
additional research will
be
needed before we can
more accurately address yotir manyconcerns.
Foryour
information, Ihave enclosed
all
prior letter correspondence that deal
with power generation in
Lakeand
McHcnry County
arca~.-
If
we
can
be of
~imy
further assistance, p1ea~efeel free
to call or
write.
Sincerely,
/4\
Andrew
Cr.
Buck, P.O.
ANDREW G.
BUCK
(217) 333-6800
\~9O0O65~,,,,J
iLLIN0~S
--
Enclosures as
stated
cc~
Winstanley,
ISWS
l3howmik, ISWS
Roadcap, ISWS
Clark, IDNR-OWR
2:
(0
I-
Lt)
-‘5
I-
z
Drawdown
created
by
two
welifields
each pumping
5 MGD
from
8 Wells.
(1
15,000 gpd/ft,
S
0.0004)
160
L
~QO~
1;.
240
-~
R1OE
RilE
RQE
L L
N
0
iS
Illinois State Water Survey
Main Ottice
2204 G4fi~h
Drive ‘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 lerteris
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 theproposed power
plant wilt be located
in
theSW’/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 andSilurian-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 waterwithdrawal
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 ~ve11s
tapping
the source
aquifer to decline.
This
water-level decline
is referred
to as interference drawdown or, more simply,
as interference.
Interference drawdown decreases with
increasingdistance
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 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 waterto 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
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 affectedwell
--
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
characterof 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
geologicmaterials above the St. Peter sandstone were not sealed off by
well casing
Ifwe
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
2
I
~.
r~:
0 I S
Illinois State Water Survey
Mom
Oltice ‘2204 Gti(fiIh
Dike ‘Cho~pcQn.
II6l~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 E½
of the NE¼,
of
SectionS,
T.44N., R.9E., McHcnry County and partially
in
the
NWV4
of
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) ~velL
may 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
ofthe cone ofdepression 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
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
,.,,,
tm
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 theuse 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 hydraulicproperties 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
Vs
mile
350 feet or less
½
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
~hat
long-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 datacollected 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 thewater 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
0
200
400
0
0
600
800
1000
1200
Regional drawdown in the Cambrian-Ordovician aquifer
produced by
I
well pumping 7500
GPM.
(1= 20,000
gpd/ft2,
S
=
00004, time
=
I year)
7
I~i~rJi
I
1TT11
Tm~TT
li
I
m
-1
0
1
2
3
4
5
6
Dist:
~
(mies)
5)
E
0
V
C
a
0
Regional drawdown
in the Cambrian-Ordovician
aquifer
produced by
1
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
5
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
is
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.
