APPENDIX A

Summary of Informational Order

ILLINOIS POLLUTION CONTROL BOARD

December 21, 2000 Contact: Connie Newman

217-782-7630

FAX: 217-524-8508

ILLINOIS POLLUTION CONTROL BOARD ADOPTS INFORMATIONAL ORDER

ON PEAKER PLANTS DOCKET No. R01-10

In response to a request from Governor George H. Ryan, the Illinois Pollution Control

Board (Board) today adopted an Informational Order on natural gas-fired, peak-load electrical

power generating facilities (peaker plants). Peaker plants generate electricity during periods of

peak electricity demand. The recent proliferation of peaker plants has been a source of much

public controversy in the Chicago metropolitan area.

The Informational Order follows seven days of public inquiry hearings across the State

(August 23 and 24 in Chicago; September 7 in Naperville; September 14 in Joliet; September

21 in Grayslake; and October 5 and 6 in Springfield). Over 80 persons testified at these public

hearings, including individual citizens, representatives of citizen groups, representatives of

State and local government, and representatives of industry. The hearing transcripts comprise

nearly 1,300 pages of testimony. The Board also received 195 written public comments. The

transcripts and public comments are available on the Board’s Web site at www.ipcb.state.il.us.

The Board was created by the Illinois Environmental Protection Act (Act) to

“determine, define and implement the environmental control standards applicable in the State

of Illinois.” In addition to the Board’s duty to promulgate environmental regulations and to

decide contested environmental cases, the Board is authorized to conduct such other

noncontested or informational hearings as may be necessary to accomplish the purposes of the

Act. Specifically, the Board can conduct inquiry hearings to gather information on any subject

the Board is authorized to regulate.

Citing public concern over the recent proliferation of peaker plants in Illinois,

Governor Ryan, in a July 6, 2000 letter, asked Board Chairman Claire A. Manning to

undertake Board inquiry proceedings. The Governor’s letter specifically asked that the Board

hold public hearings to address the following issues and to make recommendations on whether

further regulation or legislation is necessary to safeguard Illinois’ environment:

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1.

 

Do peaker plants need to be regulated more strictly than Illinois’ current air quality

statutes and regulations provide?

2.

 

Do peaker plants pose a unique threat, or a greater threat than other types of State-

regulated facilities, with respect to air pollution, noise pollution, or groundwater or

surface water pollution?

3.

 

Should new or expanding peaker plants be subject to siting requirements beyond

applicable local zoning requirements?

4.

 

If the Board determines that peaker plants should be more strictly regulated or

restricted, should additional regulations or restrictions apply to currently permitted

facilities or only to new facilities and expansions?

5. How do other states regulate or restrict peaker plants?

In its Informational Order, the Board provides specific answers to each of the

Governor’s questions and makes recommendations. Copies of the Informational Order will be

available to the public on Friday, December 22. The Board is also preparing a companion

report that it expects to release sometime in January. This report will summarize all of the

information received by the Board in these proceedings. The Informational Order and

companion report, when released, will be posted on the Board’s Web site at

www.ipcb.state.il.us. Copies may be obtained by calling the Board’s Chicago office at (312)

814-3620 or its Springfield office at (217) 524-8500.

  

In its Informational Order, the Board recommends that the State tighten current

environmental regulations concerning peaker plants to ensure the protection of the

environment.

In the area of air emissions, the Informational Order notes that peaker plants burn

natural gas, which is a relatively clean fuel from an environmental perspective. While peaker

plants emit various pollutants into the air, nitrogen oxides (NOx) are of particular concern

because they are ozone precursors. In Illinois, a facility that emits less than 250 tons per year

(TPY) is considered a “minor” source under current State and federal environmental

regulations. Many of the proposed peaker plants are being permitted to allow for emissions

just under this threshold and are intended to emit much less than that. Due to their “peaking”

nature, however, the Board finds that these plants are unique. They can emit most if not all of

their permitted annual amount of air emissions during a concentrated period of time. This time

period is generally the summer months when the ozone risk is highest.

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In its Informational Order, the Board recommends that the Illinois Environmental

Protection Agency (IEPA) and the Board engage in rulemaking under the Act to consider

requiring these plants to use the “Best Available Control Technology” (BACT) in controlling

their air emissions. BACT is a federally-derived regulatory methodology intended to

determine the maximum degree to which air emissions can be reduced in light of energy,

environmental, and economic impacts. Generally in Illinois, BACT only applies to “major”

sources, which are those that emit 250 TPY or more.

Also regarding air regulations, the Board recommends codifying two practices that

IEPA Director Tom Skinner administratively implemented to respond to public concern over

the proliferation of peaker plants: dispersion modeling and public hearings for all proposed

peaker plant construction permits.

Dispersion modeling is intended to ensure that peaker plant air emissions do not cause

or contribute to a violation of the National Ambient Air Quality Standards (NAAQS). While

not required for minor sources, IEPA has recently been requesting this modeling information

from peaker plant developers during the permit process. The modeling should use

conservative parameters to determine the worst-case impact, including any cumulative impact

due to the clustering of peaker plants.

On the question of noise, the Board finds that Illinois’ current noise regulations are

adequate to address most concerns and that citizen’s enforcement actions before the Board are

available to enforce noise standards. Nonetheless, the Board recognizes that a “gap” exists in

current Illinois noise regulation. While the State noise standards are strict, IEPA does not

currently have a program in place to ensure at the time of air permitting that facilities will meet

those noise standards. The Board recommends remedying that problem.

Finally, on the question of whether peaker plants should be subject to siting

requirements beyond local zoning, the Board stops short of making any specific

recommendation on siting. Instead, the Board provides the Governor with an informed

discussion of the concerns raised and potential solutions.

In announcing the Board’s Informational Order, Board Chairman Claire A. Manning

stated: “The Board very much appreciates the valuable and insightful public participation in

these proceedings from all interested persons, businesses, and associations. The huge record

that was created has allowed the Board to address the threshold issues presented to us by the

Governor and by the participants. We have been able to make several valuable

recommendations to enhance the regulations that apply to these plants—and to further

safeguard Illinois’ environment. We commend Governor Ryan for the leadership he has shown

on these issues and thank him for the opportunity to have served him and the citizens of the

State of Illinois on these important questions.”

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The Board is an independent State board comprised of seven technically qualified

individuals, all of whom are appointed by the Governor with the advice and consent of the

Senate. For more information about the Board and its members, please visit the Board’s Web

site at www.ipcb.state.il.us.

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APPENDIX B

PERSONS TESTIFYING

Chicago Hearings

August 23, 2000

1.

 

Charles Fisher, Executive Director, ICC

2.

 

Thomas Skinner, Director, IEPA

3.

 

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

Control, Bureau of Air, IEPA

4.

 

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

Control, Bureau of Air, IEPA

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 Liaison/IEPA

9.

 

Dr. Brian Anderson, Director, OSRA, DNR

10.

 

Dr. Derek Winstanley, Chief, ISWS, DNR

August 24, 2000

1.

 

Gerald Erjavec, Manager, Business Development, Indeck

2.

 

Greg Wassilkowsky, Manager, Business Development, Indeck

3.

 

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

4.

 

Steven Nauman, Vice President, Transmission Services, ComEd

5.

 

Deirdre Hirner, Executive Director, IERG

6. Richard Bulley, Executive Director, MAIN

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7. Freddi Greenberg, Executive Director and General Counsel, MWIPS

8.

 

Michael Kearney, Manager, Economic Development, Ameren

9.

 

Richard Trzupek, Manager, Air Quality, Huff & Huff

Suburban Hearings

Naperville

September 7, 2000

1.

 

Mayor George Pradel, Naperville

2.

 

State Senator Chris Lauzen

3.

 

State Representative Mary Lou Cowlishaw

4.

 

Mayor Vivian Lund, Warrenville

5.

 

Paul Hoss, Zoning Manager, DuPage County Department of Development and

Environmental Concerns

6.

 

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

7.

 

Dianne Turnball, consultant to several citzen groups, a private foundation, and

businesses opposing certain peaker plants

8.

 

Carol Dorge, Director, LCCA

9.

 

Connie Schmidt, representative of the River Prairie Group of the Illinois Sierra Club

10.

 

Mark Goff, resident, Warrenville

11.

 

Cathy Capezio, resident, Aurora

12.

 

Terry Voitik, resident, DuPage County, and founder of CAPPRA

13.

 

Maurice Gravenhorst, member, CAPPRA

14.

 

Lucy Debarbaro, member, CAPPRA

15.

 

Terry Voitik on behalf of Steve Arrigo, CAPPRA

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16.

 

Susan Zingle, Executive Director, LCCA

17. Beverly DeJovine, representative, Bartlett CARE

18. Cathy Johnson, Vice Chair, Rural and City Preservation Association

19.

 

Chris Gobel, member, CAPPRA

20.

 

Elliot “Bud” Nesvig

21.

 

Sandy Cole, Commissioner, Lake County Board

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, CPI

3.

 

Carol Stark, Director, CARE, Lockport

4.

 

Susan Zingle, Executive Director, LCCA

5.

 

Keith Harley, Chicago Legal Clinic

6.

 

Elliot “Bud” Nesvig

7.

 

Michael Shay, Senior Planner, Will County

Grayslake

September 21, 2000

1.

 

State Senator Terry Link

2.

 

State Representative Susan Garrett

3.

 

Tom Lynch, Trustee, Libertyville Township

4.

 

Betty Rae Kaiser, Trustee, Village of Wadsworth

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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 Thomson Carter, Commissioner, Lake County Board

9.

 

Greg Elam, CEO, American Energy

10.

 

Larry Eaton, attorney, on behalf of the Liberty Prairie Conservancy, Prairie Holdings

Corporation, and Prairie Crossing Homeowners Association

11.

 

Toni Larsen, resident, Zion

12.

 

Chris Geiselhart, Chairperson, CCLC

13.

 

Dianne Turnball, representing Liberty Prairie Conservancy, CCLC, 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, Lake County

22.

 

William McCarthy, resident, Libertyville

23.

 

Susan Zingle, Executive Director, LCCA

24.

 

Barbara Amendola, resident, Zion

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25.

 

Mark Sargis, attorney, working with citizens concerned about peaker plants

26.

 

Cindy Skrukrud, resident, Olin Mills, McHenry County

27.

 

Paul Geiselhart, resident, Libertyville

28.

 

Dr. William Holleman, President, Illinois Citizen Action

29.

 

Evan Craig, Volunteer Chair, Woods & Wetlands Group of the Sierra Club

30.

 

Phillip Lane Tanton

31.

 

Sally Ball, on behalf of State Representative Lauren Beth Gash

Springfield Hearings

October 5, 2000

1.

 

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

IDOT

2.

 

John Smith, representative of ISAWWA

3.

 

Brent Gregory, representative of National Association of Water Companies, Illinois

Chapter

4.

 

James R. Monk, President, IEA

5.

 

Patricio Silva, Midwest Activities Coordinator, NRDC

6.

 

Brian Urbaszewski, Director, Environmental Health Programs, ALAMC, and board

member of IEC

7.

 

Elliot “Bud” Nesvig

8.

 

Carol Dorge, Director, LCCA

October 6, 2000

1.

 

Susan Zingle, Executive Director, LCCA

2.

 

Scott Phillips, Deputy Counsel, IEPA

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3. Kathleen Bassi, Assistant for Program and Policy Coordination for Bureau of Air,

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

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APPENDIX C

EXHIBIT LIST

Exhibit Number Description

ICC Exh. 1 (8/23/00) Prefiled testimony of Charles Fisher

IEPA Grp. Exh. 1 (8/23/00) Prefiled testimony of IEPA

witnesses (Thomas Skinner,

Christopher Romaine, Robert

Kaleel, Greg Zak, Steve

Nightingale, Richard Cobb, and

Todd Marvel)

IEPA Grp. Exh. 2 (8/23/00) Set of 20 documents, beginning with

“Simple Cycle Gas Turbine

Application Diagram,” and

including two oversized maps

DNR Exh. 1 (8/23/00) Prefiled testimony of Dr. Brian

Anderson

DNR Exh. 2 (8/23/00) Prefiled testimony of Dr. Derek

Winstanley

Indeck Exh. 1 (8/24/00) Prefiled testimony of Gerald Erjavec

Indeck Exh. 2 (8/24/00) Copy of PowerPoint presentation

and Supporting Documentation

ComEd Exh. 1 Prefiled testimony of Arlene Juracek

(8/24/00) and Steven Naumann

IERG Exh. 1 (8/24/00) Prefiled testimony of Deirdre Hirner

MAIN Exh. 1 (8/24/00) Prefiled testimony of Richard Bulley

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2

MWIPS Exh. 1 (8/24/00) Prefiled testimony of Freddi

Greenberg

Ameren Exh. 1 (8/24/00) Prefiled testimony of Michael

Kearney

Huff & Huff Exh. 1 (8/24/00) Prefiled testimony of Richard

Trzupek, with attachments

CAPPRA Exh. 1 (9/7/00) CAPPRA Mission Statement

and photographs

CAPPRA Exh. 2 (9/7/00) Steven Berning,

et al

. v. The City

of Aurora, et al., 00-CH-0361,

Second Amended Complaint for

Declaratory Judgment pending in

DuPage County Circuit Court

CAPPRA Exh. 3 (9/7/00) Testimony of Michael Warfel

CAPPRA Exh. 4 (9/7/00) Testimony of Steve Arrigo

DuPage County Board Exh. 1 (9/7/00) Versar Report

DuPage County Board Exh. 2 (9/7/00) Map—DuPage County

Municipalities and Unincorporated

Areas

DuPage County Board Exh. 3 (9/7/00) Testimony of Paul J. Hoss, Zoning

Manager for DuPage County

Department of Development and

Environmental Concerns

Standard Power and Light Exh. 1 (9/7/00) Addendum No. 2 to Application for

PSD Deterioration Construction

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Permit for Standard Energy

Ventures, LLC Electrical

Generation Facility

Bartlett CARE Exh. 1 (9/7/00) Testimony of Beverly DeJovine

Zingle Exh. 1 (9/7/00) “Peaker” Electrical Generating

Plants Press Coverage—2000

Zingle Exh. 2 (9/7/00) Testimony of LCCA

Zingle Exh. 3 (9/14/00) Testimony of LCCA, with

attachments

Zingle Exh. 4 (9/21/00) Video Tape

Zingle Exh. 5 (10/6/00) “Typical Daily Load Curve” of

Reliant

Zingle Exh. 6 (10/6/00) “The Status of U.S. Electricity

Deregulation”

Zingle Exh. 7 (10/6/00) Arthur Andersen’s “Impact Analysis

Mallory Parcel—Libertyville,

Illinois”

Zingle Exh. 8 (10/6/00) “Effects of the Proposed Indeck

Facility on Property Values, Land

Use and Tax Revenue”

Zingle Exh. 9 (10/6/00) August 15, 2000 letter from Lake

County State’s Attorney, Michael J.

Waller, to Kenneth L. Larson

Zingle Exh. 10 (10/6/00) News Articles, beginning with

“Ordinance Would Place Provisos

on Peaker Plants”

Zingle Exh. 11 (10/6/00) “Business Overview—Electrical

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4

Generating Companies”

Sierra Club Exh. 1 (9/7/00) Testimony of Connie Schmidt

Overbye Exh. 1 (9/14/00) “Need for New Peaker Generation

in Illinois” PowerPoint presentation

CPI Exh. 1 (9/14/00) Testimony of Alan L. Jirik

Stark Exh. 1 (9/14/00) Testimony of Carol Stark

Stark Exh. 2 (9/14/00) Newspaper article

Chicago Legal Clinic Exh. 1 (9/14/00) Petition to USEPA requesting

revocation of the NOx waiver

Chicago Legal Clinic Exh. 2 (9/14/00) Testimony of Keith Harley

Link Exh. 1 (9/21/00) Statement of State Senator Terry

Link

Lynch Exh. 1 (9/21/00) Comments of Tom Lynch,

Libertyville Township Trustee

Kaiser Exh. 1 (9/21/00) Village of Wadsworth Resolution

R130 and letter of December 21,

1999

Kucera Exh. 1 (9/21/00) Comments on behalf of the Lake

County Public Water District

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Lake County Exh. 1 (9/21/00) Testimony of Jim LaBelle,

Chairman Lake County Board

Lake County Exh. 2 (9/21/00) Testimony of Sandy Cole, Lake

County Board Member

Lake County Exh. 3 (9/21/00) Testimony of Bonnie Thomson

Carter, Lake County Board Member

Lake County Exh. 4 (9/21/00) Testimony of Greg Elam,

CEO of American Energy,

including PowerPoint presentation

and FERC article

Lake County Exh. 5 (9/21/00) Lake County 2000—Legislative

Program

Eaton Exh. 1 (9/21/00) Testimony of Larry Eaton on behalf

of Liberty Prairie Conservancy,

Prairie Holdings Corporation, and

Prairie Crossing Homeowners

Association

CCLC Exh. 1 (9/21/00) Testimony of Chris Geiselhart,

Chairperson

CCLC Exh. 2 (9/21/00) Comments of Richard Domanik

during an April 25, 2000 hearing in

Libertyville, with attached articles

Nesvig Exh. 1 (9/21/00) Testimony of E.M. Nesvig

Nesvig Exh. 2 (9/21/00) “Electric Power Monthly”

(July 2000 edition)

Nesvig Exh. 3 (10/5/00) Written testimony of E.M. Nesvig

Nesvig Exh. 4 (10/5/00) Hard copy of Air Permit Public

Hearing Presentation (September

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28, 2000) by Elwood Energy II and

Elwood Energy III

Nesvig Exh. 5 (10/5/00) “U.S. Electricity Imports and

Exports 1995–1999”

McCarthy Exh. 1 (9/21/00) Correspondence of William

McCarthy, PhD, regarding

proposed Libertyville plant

McCarthy Exh. 2 (9/21/00) Guidance for Power Plant Siting and

Best Available Control Technology

McCarthy Exh. 3 (9/21/00) “Catalytica” publication regarding

“XONON™ Technology”

Sargis Exh. 1 (9/21/00) Written comments of Mark R.

Sargis (dated September 7, 2000)

IDOT Exh. 1 (10/5/00) October 5, 2000 letter from James

V. Bildilli to Chairman Claire A.

Manning

Gregory Exh. 1 (10/5/00) Written testimony of Brent Gregory

Monk Exh. 1 (10/5/00) Written testimony of James Monk

Monk Exh. 2 (10/5/00) “System Peak Load and Capacity—

Historical 1990-2000 & Projected

2001-2003

ALAMC Exh. 1 (10/5/00) Joint Comments of the ALAMC and

IEC

Dorge Exh. 1 (10/5/00) Written comments of LCCA

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Dorge Exh. 2 (10/5/00) “Peaker” Natural Gas Fired

Turbines—Permits Issued

Dorge Exh. 3 (10/5/00) “Peaker” Natural Gas Fired

Turbines Permits Issued—PSD

Dorge Exh. 4 (10/5/00) Group of four exhibits, beginning

with “Lake County Conservation

Alliance written comments in

Carlton air permitting proceeding”

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APPENDIX D

PUBLIC COMMENTS

1 Reliant, submitted by Cindy Conte, Manager, State Affairs

2 Debbie Halvorson, Sentator, 40th District

3 Ron Molinaro

4 Peter J. Cioni, Director of Community Development, City of

Zion

5 Lake County Zoning Board of Appeals submitted by Bob

Mosteller, Deputy Director

6 Larry Eaton

7 Susan Zingle

8 Response to Questions—Charles Fisher of the ICC

9 IEPA Response to Questions

10 John Smith, ISAWWA

11 “The Status of U.S. Electricity Deregulation” submitted by Susan

Zingle, LCCA Executive Director

12 Gary Hougen

13 Robert Brooks

14 Amy Snyder

15 Gary A. Bellak

16 Sally J. Carr

17 Rollin and Sara Shaw

18 Paul and Cyndy Niles

19 Mike Miller

20 Bill O’Donnell

21 Wesley Landmeier

22 Lucille Landmeier

23 Julie and Curt Moon

24 Lester Landmeier

25 Joyce Landmeier

26 Jim Schindel

27 Diane Schindel

28 Joyce Sanders

29 Lawrence H. Robertson

30 Harold and Barbara Snyder

31 Curt W. Peters

32 Walter Quanstrom

33 Byron and Kristin Henn

34 Kris O’Donnell

35 John Geltz,

36 Brian J. Gelf

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37 Veda E. Miller

38 Sheri and Keith Fitzgerald

39 Tim Geltz

40 Gail Geltz

41 Sue Andersen

42 Kenneth Andersen

43 Mrs. Arnold Nier

44 Gary Brigel

45 Jeanette Bower

46 James and Kelly Reuland

47 Linda J. Ott

48 Darrin J. Ott

49 Duane Rhoades

50 Steven R. Weissinger

51 William A. Thompson and Karen R. Thompson

52 Mary Backes

53 Ruth A. Brigel

54 Lisa Weissinger

55 Richard Pave

56 Marcia Lee

57 Leon Backes

58 Scott Ritter

59 Mr. and Mrs. Robert J. Krajecki

60 Dorothy Gum

61 Norman L. Curry, Fox

62 Mr. and Mrs. Jeffrey Berg

63 Doug Tuell

64 Jon and Lori Simon

65 David Young

66 Lynne B. Pave

67 Elaine Tuell,

68 Phyllis Pierson, Sugar

69 Margaret Kathleen McCrimmon

70 A. Gum, Big Rock

71 Robert E. Pierson

72 Nancy Fayfar

73 Ronnie Simpkins

74 Kelly Salazar

75 Sheila M. Simpkins

76 Patricia L. McKenzie

77 Wray V. McKenzie, Jr.

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78 Marilyn Lasecki and Edmund Lasecki, Jr.

79 Patricia McBroom and Roger McBroom

80 Cheryl Romano and Thomas Romano

81 Dorothy Holland

82 Annie Buckmiller

83 Alice Hulka

84 Mary Copp

85 Patrick and Linda Barnes

86 Carla S. Miller

87 John and Carrie Loehmann

88 Helen LeBeau

89 James E. McCrimmon

90 Lynette and Dave Weidin

91 Jane Erdman

92 Frederick C. Runge

93 Julie A. Anderson, Elburn

94 (unable to read name) Elburn

95 Ben Halls

96 Kathryn M. Hellwig,

97 Anita Sennett,

98 Gregory G. Goss and Jo A. Goss

99 William and Cheryl Oeser

100 Debra E. Raymond, Big Rock

101 Lawrence Von Ohlen

102 Ricky Gum

103 John Hellwig

104 Diane M. Howard

105 Orville Howard

106 Rose Marie Diedesch and Bill C. Diedesch

107 Udo A. Heinze on behalf of Ameren

108 Jeannine Kannegiesser, Center for Neighborhood Technology

109 Patricia Silva, Midwest Activities Coordinator, NRDC,

Washington, D.C.

110 IMEA, submitted by Ronald D. Earl, General Manager & CEO

111 AIEC, submitted by Earl W. Struck, President/CEO

112 Verena Owen

113 Simon Klambauer

114 Peter and Dawn Roberts

115 Cathy Jo Magee

116 C. Beau and Sue Carlson

117 Richard A. and Mary C. LaFleur

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118 Jennifer E. Johnson

119 William P. Fischer

120 Karen Yoeler

121 Bill Yoeler

122 Judy M. Hoffman

123 David R. Mag

124 Daniel Salazar

125 JoAnn I. Kline

126 Laurie Kazmiercek

127 Pam S. Wedeen

128 Ramona A. Kline

129 William F. Kline, Sr.

130 Jeff Hoffman

131 Ronald L. Burgess

132 Ed Whatley

133 Elaine and Harold Morris

134 James Scott

135 Lois Long

136 Dale N. Johnson

137 Elaine Fischer

138 Larry Hawhes

139 Cynthia S. Polfer

140 Mr. and Mrs. Mau

141 Ruth Pessina

142 Fritz Landmeier

143 Patricia and Joseph Heimonen

144 Elizabeth Simmons

145 Tom Pattermann

146 Sheela A. Faulkner

147 A. Denise Farrugia

148 Barry and Leah A. Morsch

149 Mary Hankes

150 Andy and Barb Kearns

151 Jackie Beane

152 Michelle Drauz

153 Marilyn Hannemann

154 Sandy Madden

155 James R. Kidd

156 W.R. Hannemann III

157 Mark and Lisa Spangler

158 Allen and Jeanette Krodel

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159 Robert and Sharon Phillips

160 James Gasdiel

161 Mary Thurow

162 Margaret Bock

163 Midwest Generation, submitted by Cynthia A. Faur

164 ComEd, submitted by Christopher W. Zibart

165 Joint testimony of ALAMC and IEC, submitted by Brian

Urbaszewaki, the Director of Environmental Health Programs for

ALAMC and a board member of IEC

166 Final Comments of Carol Dorge, Director, LCCA

167 IEA, submitted by James R. Monk, President

168 IEPA additional comments, submitted by Scott Phillips, Deputy

Counsel

169 Sierra Club Woods & Wetlands Group, submitted by Evan L.

Craig

170 PG&E, submitted by Stephen Brick, Director, External Relations

and Environmental Affairs

171 MWIPS, submitted by Freddi L.

Greenberg, Executive Director and General Counsel

172 Sierra Club, Illinois Chapter

173 Indeck, submitted by

Gerald M. Erjavec, Manager, Business Development

174 Marvin and Eunice Gapinske

175 Ronald and Mary Jane Davis

176 Clifford and Gloria Sisko

177 Donald and Linda Czachor

178 Clara Arm Babel

179 Julie and Karl Kettelkamp

180 Audrey and David Boston

181 Suzanne Pyle

182 Terry and Sherilyn Sorensen

183 Donna Morris

184 Debra K. Galvan

185 Mr. and Mrs. Bradley Scott

186 Ersel C. Schuster, McHenry County Board, District 6

187 IERG, submitted by Katherine D. Hodge

188 Dr. Donna M. Lawlor and Lynn Hoeth

189 CCLC & Liberty Prairie Conservancy submitted by Dianne

Turnball

190 Jim LaBelle, Chairman, Sandy Cole, and Bonnie Thomson Carter,

Members of the Lake County County Board, submitted by Jim

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6

LaBelle

191 Marsha B. Winter

192 Ken Bentsen

193 Lois Scott and Burton Scott

194 Ralph N. Schleifer

195 Marci Rose

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APPENDIX E

ABBREVIATION LIST

Acentech ACENTECH, INC.

Act ENVIRONMENTAL PROTECTION ACT

AIEC ASSOCIATION OF ILLINOIS ELECTRIC COOPERATIVES

ALAMC AMERICAN LUNG ASSOCIATION OF METROPOLITAN

CHICAGO

Ameren AMEREN CORPORATION

American Energy AMERICAN ENERGY SOLUTIONS, INC.

BACT BEST AVAILABLE CONTROL TECHNOLOGY

Bartlett CARE BARTLETT CITIZENS ADVOCATING RESPONSIBLE

ENVIRONMENTS

Board ILLINOIS POLLUTION CONTROL BOARD

CAA CLEAN AIR ACT

CAAPP CLEAN AIR ACT PERMIT PROGRAM

CAPPRA CITIZENS AGAINST POWER PLANTS IN RESIDENTIAL

AREAS

CARE CITIZENS AGAINST RUINING THE ENVIRONMENT

CCLC CONCERNED CITIZENS OF LAKE COUNTY

CEC CALIFORNIA ENERGY COMMISSION

CESQG CONDITIONALLY-EXEMPT SMALL-QUANTITY

GENERATOR

CNT CENTER FOR NEIGHBORHOOD TECHNOLOGY

CO CARBON MONOXIDE

CO2

CARBON DIOXIDE

ComEd COMMONWEALTH EDISON COMPANY

CPI CORN PRODUCTS INTERNATIONAL, INC.

dB DECIBEL

dB(A) A-WEIGHTED DECIBEL

DNR ILLINOIS DEPARTMENT OF NATURAL RESOURCES

EGU ELECTRICAL GENERATING UNIT

EIS ENVIRONMENTAL IMPACT STATEMENT

Illinois Electricity

Choice Law

ELECTRIC SERVICE CUSTOMER CHOICE AND RATE

RELIEF LAW OF 1997

ERMS EMISSIONS REDUCTION MARKET SYSTEM

FAA FEDERAL AVIATION ADMINISTRATION

FERC FEDERAL ENERGY REGULATORY COMMISSION

HAP HAZARDOUS AIR POLLUTANT

Huff & Huff HUFF & HUFF, INC.

ICC ILLINOIS COMMERCE COMMISSION

IDOT ILLINOIS DEPARTMENT OF TRANSPORTATION

---

2

IEA ILLINOIS ENERGY ASSOCIATION

IEC ILLINOIS ENVIRONMENTAL COUNCIL

IEPA ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

IERG ILLINOIS ENVIRONMENTAL REGULATORY GROUP

IMEA ILLINOIS MUNICIPAL ELECTRIC AGENCY

Indeck INDECK ENERGY SERVICES, INC.

IPP INDEPENDENT POWER PRODUCER

ISAWWA ILLINOIS SECTION OF THE AMERICAN WATER WORKS

ASSOCIATION

ISWS ILLINOIS STATE WATER SURVEY

kW KILOWATT

kWh KILOWATT HOUR

LAER LOWEST ACHIEVABLE EMISSION RATE

LCCA LAKE COUNTY CONSERVATION ALLIANCE

MACT MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY

MAIN MID-AMERICA INTERCONNECTED NETWORK, INC.

MEAC MIDWEST ENVIRONMENTAL ASSISTANCE CENTER

Midwest Generation MIDWEST GENERATION EME, LLC

mmBtu MILLION BRITISH THERMAL UNIT

MSSCAM MAJOR STATIONARY SOURCES CONSTRUCTION AND

MODIFICATION

MW MEGAWATT

MWh MEGAWATT HOUR

MWIPS MIDWEST INDEPENDENT POWER SUPPLIERS

NAA NONATTAINMENT AREA

NAAQS NATIONAL AMBIENT AIR QUALITY STANDARDS

NESHAP NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR

POLLUTANT

NIPC NORTHEASTERN ILLINOIS PLANNING COMMISSION

NO NITRIC OXIDE

NO2

NITROGEN DIOXIDE

NOX

NITROGEN OXIDES

NPDES NATIONAL POLLUTANT DISCHARGE ELIMINATION

SYSTEM

NRC ILLINOIS NUCLEAR REGULATORY COMMISSION

NRDC NATURAL RESOURCES DEFENSE COUNCIL

NSPS NEW SOURCE PERFORMANCE STANDARD

NSR NEW SOURCE REVIEW

NYS Siting Board NEW YORK STATE BOARD ON ELECTRIC GENERATION

SITING AND THE ENVIRONMENT

OSRA OFFICE OF SCIENTIFIC RESEARCH AND ANALYSIS

---

3

OTAG OZONE TRANSPORT ASSESSMENT GROUP

PG&E PG&E NATIONAL ENERGY GROUP

PM PARTICULATE MATTER

PM 10 PARTICULATE MATTER NOMINALLY 10 MICRONS AND

LESS

PM 2.5 PARTICULATE MATTER NOMINALLY 2.5 MICRONS AND

LESS

POTW PUBLICLY OWNED TREATMENT WORKS

ppb PARTS PER BILLION

ppm PART PER MILLION

ppmv PARTS PER MILLION BY VOLUME

PSD PREVENTION OF SIGNIFICANT DETERIORATION

RACT REASONABLY AVAILABLE CONTROL TECHNOLOGY

Reliant RELIANT ENERGY POWER GENERATION, INC.

RTO REGIONAL TRANSMISSION ORGANIZATION

SB 172 SENATE BILL 172 (REFERENCE FOR POLLUTION

CONTROL FACILITY SITING PROVISIONS UNDER THE

ACT)

SCR SELECTIVE CATALYTIC REDUCTION

SCW&WG SIERRA CLUB WOODS & WETLAND GROUP

SIP STATE IMPLEMENTATION PLAN

SO2

SULFUR DIOXIDE

TPY TONS PER YEAR

USEPA UNITED STATES ENVIRONMENTAL PROTECTION

AGENCY

UAM-V URBAN AIRSHED MODEL—VERSION V

Versar VERSAR, INC.

VOC VOLATILE ORGANIC COMPOUND

VOM VOLATILE ORGANIC MATERIAL

Water Use Act ILLINOIS WATER USE ACT OF 1983

WRAC WATER RESOURCES ADVISORY COMMITTEE

---

APPENDIX F

Figure 1: Typical Daily Load Curve

Midnight Noon Midnight

Light Load Heavy Load Hours Light Load

Hours Hours

PEAK LOAD

INTERMEDIATE LOAD

BASE LOAD

Based on drawing presented in Reliant’s public comment (PC 1).

---

Storage

Tank

Demineralizer

Evaporative

Cooler

Cooling

Water

Figure 2: Simple Cycle and Combined Cycle Combustion Turbine Power Plant

Based on drawing entitled Peaking vs. Combined Cycle Facility. Indeck Exh. 2.

Air

Hot

Exhaust

Low

Steam

Steam

Turbine

Heat

Recovery

Steam

Generator

Condenser

Cold

Hot

Water

Evaporating

Exhaust

Wastewater

---

Table 1: Existing & New Natural Gas-Fired, Simple Cycle and Combined Cycle Units

based on IEPA Grp. Exh. 2, No. 7 and PC 168, Att. 2

Combined Cycle Units are shaded.

Map #

ID # Company Name City County EGU

Site:

Permit Total

Capacity

Fuel

Used

Load

Type

NOx Rule

Existing

or New

Number Type Status (MW) (tons/

yr)

1 021814AAG Dom. Energy-Lincoln

Generation

Kincaid Christian Existing 00020011 C

Add. Info Ltr

3/6/00

688 NG Peak Major-

PSD

2 025803AAD Aquila Energy/

MEP Flora Power

Harter/

Flora

Clay New 00050050 C

Review

Pending

567 NG Peak 245 NSPS

3 025804AAC Entergy Power-Flora

Peaking Stn

Flora Clay New 00030053 C

Public Notice

292 NG Peak 212 NSPS

025804AAC Entergy Power-Flora

Peaking Stn

Flora Clay New 00030053 C

Public Notice

296 NG Peak 212 NSPS

4 031600AMI Midwest Generation Chicago Cook Existing 95090081 Title

V

Review

Pending

264 JP-4,

NG

Peak None

5 031600GGV People's

Energy/Calumet Power

Chicago Cook New 99100023 C

Permitted

266 NG Peak 233 NSPS

6 031600GHA Calumet Energy Team

LLC

Chicago Cook New 99110107 C

Permitted

305 NG/

Oil

Peak 240 NSPS

7

031801AAI

Duke Energy Chicago

Hts

Chicago Hts

Cook

New

00040068

C

Review

Pending

620

NG

Base

Major

8 041806AAC Ener Star- Montana Stn Newman Douglas New 00060075 C

Review

Pending

322 NG Peak NSPS

041806AAC Ener Star- Montana Stn Newman Douglas New 00060075 C

Review

Pending

40 NG Peak NSPS

9 043090ADB Standard Energy

Venture, LLC

West

Chicago

DuPage New 99120001 C

Draft Permit

800 NG/

Oil

Base/

Peak

732 PSD/BA

CT

10 043407AAF Reliant Energy/Reliant

DuPage Cty LP

Aurora DuPage New 99110018 C

Permitted

680 NG Peak 247 NSPS

043407AAF Reliant Energy/Reliant

DuPage Cty LP

Aurora DuPage New 99110018 C

Permitted

270 NG Peak 247 NSPS

11

043412AAH

Grand Prairie Energy,

LLC/ABB

Bartlett

DuPage

New

99090051

C

Permitted

500

NG/

Oil

Base

213

PSD/BA

CT

---

Map #

ID # Company Name City County EGU

Site:

Permit Total

Capacity

Fuel

Used

Load

Type

NOx Rule

Existing

or New

Number Type Status (MW) (tons/

yr)

12 051030AAD Spectrum Energy/C.I.

C.S.Power

St. Peter Fayette New 99100013 C

Permitted

45 NG Peak 85.9 NSPS

13 051808AAK Cent.Ill. S C Pow./

Spectrum

St. Elmo Fayette New 99060052 C

Permitted

45 NG Peak 85.9 NSPS

14 053803AAL Ameren CIPS Gibson City Ford New 99020071 C

Permitted

270 NG/

Oil

Peak 245 NSPS

15 055803AAB Entergy -Franklin County

Pwr

Thompsonville Franklin New 00080055 C

Review

Pending

295.6 NG Peak 250 NSPS

055803AAB Entergy -Franklin County

Pwr

Thompsonville Franklin New 00080055 C

Review

Pending

291.6 NG Peak 250 NSPS

16 055807AAD Gen Power W.

Frankfort

Franklin New 00090005 C

Review

Pending

0 Peak PSD

Minor

17 063800AAP Kinder Morgan-Aux

Sable Power Plt

Morris Grundy New 00030031 C

Draft Permit

176 NG Peak 247.5 NSPS

18

077806AAA

Ameren CIPs

Grand Tower

Jackson

Existing

99080101

C

Permitted

600

NG

Base

1911.5

NSPS

19 089425AAC DMG (Dynegy/Rocky

Road)

East

Dundee

Kane New 98120016 C

Permitted

35 NG Peak 245 NSPS

089425AAC DMG (Dynegy/Rocky

Road)

East

Dundee

Kane New 98120016 C

Permitted

242 NG Peak 245 NSPS

089425AAC DMG (Dynegy/Rocky

Road)

East

Dundee

Kane New 99050098 C

Permitted

121 NG Peak 245 NSPS

20 089802AAF Fox River Pkng

Stn/Coastal Power Co.

Big Rock Kane New 99110073 C

Final Review

345 NG Peak NSPS

21 091015AAD Indeck-Bourbonnais

Energy Center

Bourbonnais Kankakee New 00060010 C

No Action

683.2 NG Peak NSPS

22

091806AAM

Duke Energy

Manteno

Kankakee

New

00040067

C

Public Notice

620

NG

Base

Major

23 093801AAN Kendall New Cent.

Dev./Enron

Plano Kendall New 99020032 C

Permitted

664 NG Peak 426.4 PSD/BA

CT

24

093808AAD

L S Power/Kendall

Energy

Minooka

Kendall

New

98110017

C

Permitted

1000

NG

Base/

Peak

99

(SCT),

630.7

(CCT)

PSD/BA

CT

---

Map #

ID # Company Name City County EGU

Site:

Permit Total

Capacity

Fuel

Used

Load

Type

NOx Rule

Existing

or New

Number Type Status (MW) (tons/

yr)

25 097190AAC Midwest Generation Waukegan Lake Existing 95090043 Title

V

Consoldation

132 JP-4,

NG

Peak No

Limit

None

097190AAC Midwest Generation Waukegan Lake Existing 00050071 C

Review

Pending

291.6 NG Peak NSPS

26 097200ABB Skygen/Zion Energy

Center LLC

Zion Lake New 99110042 C

Final Review

800

NG/

Oil

(back-

up)

Peak 697.5 PSD/BA

CT/NSP

S

27 097810AAC Carlton Inc./North Shore

Power

Zion Lake New 99120057 C

Final Review

561 NG Peak 245 NSPS

28

103814AAC

Lee Cty Gen. Facility/L S

Power

Nelson

Lee

New

98080039

C

Permitted

1000

NG/

Oil

Base/

Peak

630.8

PSD/N

SPS

29 103817AAH Lee Generating

Stn./Duke Energy

South Dixon Lee New 99090029 C

Permitted

664 NG/

Oil

Peak PSD/BA

CT

30 107815AAC Spectrum Energy-Logan

County

New Holland Logan New 00050025 C

Permitted

270 NG Peak NSPS

31 111805AAP Reliant Energy Woodstock McHenry New 99050089 C

Permitted

510 NG Peak 248 PSD/BA

CT

32

119090AAH

Reliant Energy (Cardinal

Energy)

Roxana

Madison

New

98090064

C

Permitted

633

NG,

Refinery

Gas

Base

330.5

PSD/BA

CT

33 119105AAA Ameren CIPS Venice Madison Existing 95090017 Title

V

Permitted

37 Oil Peak No

Limit

None

34 121803AAA AmerenEnergy Gen.

Company-Kinmundy

Patoka Marion New 99020027 C

Permitted

270 NG/

Dis. Oil

Peak 245 NSPS

35 127899AAA Electric Energy/Midwest

Elec. Power

Joppa Massac Existing 99100060 C

Permitted

216 NG Peak 349.3 Netted

127899AAA Electric Energy/Midwest

Elec. Power

Joppa Massac Existing 99100060 C

Permitted

102 NG Peak Netted

36 145842AAA AmerenEnergy Gen.

Company

Pinckneyville Perry New 99090035 C

Permitted

388 NG Peak NSPS

145842AAA AmerenEnergy Gen.

Company

Pinckneyville Perry New 00090076 C

Review

Pending

192 NG Peak NSPS

37 147803AAA MEP Investments-

DeLand

Goose Creek Piatt New 00090082 C

Review

Pending

567 NG Peak NSPS

38

161807AAN

Cordova Energy

Cordova

Rock Island

New

99020097

C

Permitted

500

NG

Base

306.6

PSD/BA

---

Map #

ID # Company Name City County EGU

Site:

Permit Total

Capacity

Fuel

Used

Load

Type

NOx Rule

Existing

or New

Number Type Status (MW) (tons/

yr)

CT

39 167822ABG CWLP Springfield Sangamon New 94120058 O

Permitted

100 NG/

#2 Oil

Peak 249 NSPS

40 171851AAA Soyland Power Alsey Scott New 98120050 C

Permitted

60 NG/

Oil

Peak old unit

171851AAA Soyland Power Alsey Scott New 98120050 C

Permitted

25 NG/

Oil

Peak old unit

41

173801AAA

Shelby Enrgy Cntr/

Reliant Energy

Sigel

Shelby

New

99090085

C

Permitted

328

NG

Peak

198

NSPS

42

173807AAG

Holland Energy, LLC

Holland

Shelby

New

99100022

C

Permitted

336

NG/Oil

(CT), NG

(D.B.)

Base

342

PSD/BA

CT

43 183090AAE DMG/Tilton Energy

Center

Tilton Vermilion New 98110018 O

Permitted

176 NG Peak 197 NSPS

44 189802AAA MEP Investments-Posen Bolo Washington New 00090081 C

Review

Pending

567 NG Peak NSPS

45 197030AAO Power Energy Partners/

Crete Energy Park

Crete Will New 99120056 C

Draft Permit

393 NG Peak 245 NSPS

46 197035AAG Elwood Energy/Peoples

Gas

Elwood Will New 00010076 C

Permitted

344 NG Peak 217.56 Major-

PSD

197035AAH Elwood Energy/Peoples

Gas

Elwood Will New 00010077 C

Permitted

516 NG Peak 326.34 Major-

PSD

197808AAG Elwood Energy

Center,LLC

Elwood Will New 98060091 C

Permitted

680 NG/

Ethane

Peak 1565.7 PSD/BA

CT

197808AAG

Elwood Energy

Center,LLC

Elwood

Will

New

98060091

C

Permitted

2500

NG/

Ethane

Base

1565.7

PSD/BA

CT

47 197810ABS Rolls-Royce/Lockport

Pwr Gen.

Lockport Will New 00050010 C

Permitted

372 NG Peak 245 NSPS

48 197811AAH Desplaines

Greenland/Enron

Manhattan Will New 99020021 C

Permitted

664 NG Peak 419.4 PSD/

BACT

197811AAH Desplaines

Greenland/Enron

Manhattan Will New 99020021 C

Final Revision

167 NG Peak PSD/

BACT

49 197899AAB Univ. Park Energy/

Constellation Po.

Univ. Park Will New 99120020 C

Permitted

300 NG Peak 245 NSPS

---

Map #

ID # Company Name City County EGU

Site:

Permit Total

Capacity

Fuel

Used

Load

Type

NOx Rule

Existing

or New

Number Type Status (MW) (tons/

yr)

50 197899AAC Univ. Park Power (PPL

Global)

Univ. Park Will New 00080078 C

Review

Pending

530.4 NG Peak NSPS

51 199856AAC Southern Ill. Power

Coop.

Marion Williamson Existing 00070029 C

Draft Permit

166 NG/

Oil

Peak Netting

52 199856AAK Reliant Energy/

Williamson Enrgy Cntr

Crab

Orchard

Williamson New 99090084 C

Permitted

328 NG Peak 198 NSPS

53 201030BCG Indeck-Rockford Rockford Winnebago New 99110088 C

Permitted

300 NG Peak 199 NSPS

TOTALS

36

31

Ozone

Attainment

Nonattainment

58

9

New

Existing

67 Permits 27,329

MW

Capacity

8

56

3

Base

Peak

B/P

16,183+

tons

NOx/yr

Abbreviations:

EGU Electrical Generating Unit

C Construction

O Operating

MW Megawatt

NG Natural Gas

FO Fuel Oil

DFO Distillate Fuel Oil

JP-4 Jet Fuel

---

15

1

8

2

3

7

5

4

6

13

12

9

11

10

14

15

17

16

Existing

New

19

18

21

26, 27

22

52

24

25

23

35

29

28

31

53

38

43

30

37

41

40

34

33

32

Note: Some locations have multiple air permits and gas-fired turbines.

47

46

45

44

39

42

49, 50

48

Winnebago

McHenry

Lake

Kane

Cook

DuPage

Will

Kendall

Logan

Kankakee

Sangamon

Piatt

Ford

Grundy

Lee

Rock Island

Vermilion

Douglas

Scott

Christian

Madison

Shelby

Clay

Marion

Fayette

Wiliamson

Franklin

Perry

Washington

Massac

Jackson

Figure 3: Map of Existing & New Natural Gas-Fired, Simple Cycle

and Combined Cycle Units

based on IEPA Grp. Exh. 2, No. 7 and PC 168, Att. 2

---

Figure 4: National Combustion Turbine Projects

Based on USEPA information provided by Executive Director Charles Fisher, ICC, in PC 8

(Last updated 10-3-00)

AL

15

AK

9

AZ

3

CA

22

CO

8

CT

3

FL

22

GA

5

IL

(see Table

1 of

Appendix

F)

IN

12

KY

2

LA

7

MO

9

MN

3

MS

11

NC

5

NH

2

NJ

17

NM

10

NY

15

OH

1

OK

11

PA

7

SC

3

TX

44

VA

WI

5

WY

2

MI

1

ME

6

MD

1

Numbers represent numbers of facilities with draft permits or recently-issued final permits.

Some facilities have multiple turbines.

RI

2

MA

7

DE

1

TN

4

KS

2

NE

2

SD

1

---

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

6))))

Suuth

S

cund

St

•

Swie

41)2

•

Sprm~)i ki.

IL 6271)4

•

217

524

~5OU

•

x

2

7

~24—S5US

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

—

CHICAGO HEARINGS

Commonwealth

Edison

—

Prefiled Testimony of Arlene A. Juracek and Steven

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

--

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

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.

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

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

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