BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE MATTER OF:
)
)
NATURAL GAS-FIRED, PEAK-LOAD
) R01- 10
ELECTRICAL POWER GENERATING
)
FACILITIES (PEAKER PLANTS)
)
TESTIMONY OF GREG ZAK
Ladies and gentlemen of the Board, my name is Greg Zak. I am the Noise
Advisor for the Illinois EPA. I have been asked to testify today to provide information
relating to potential noise issues at natural gas-fired peaker plants.
I would like to briefly describe my experience and duties at Illinois EPA. I have
over 28 years of experience dealing with noise measurement, noise control engineering
and the effects of noise on people and communities. This experience includes industrial,
commercial, residential, urban, rural and construction noise. I have acted as the Illinois
EPA noise expert in enforcement and regulatory hearings before the Illinois Pollution
Control Board, Federal Bankruptcy Court, and in several Illinois Circuit Court hearings
related to noise zoning and nuisance. I have been a member of a Society of Automotive
Engineering Committee, and a member of the American National Standards Institute
Working Group on the Measurement and Evaluation of Outdoor Community Noise. I was
selected by Governor Edgar to sit on the Blasting Task Force mandated by House Joint
Resolution 133 and chaired by the Illinois Department of Natural Resources.
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I have frequently testified at noise enforcement hearings before the Board
regarding noncompliance and appropriate remedy.
Noise issues dealt with have
frequently involved the technical practicability and economic reasonableness of reducing
or eliminating the noise emissions from the source.
As a national and international author in the area of environmental noise, I have
presented papers on controlling noise at national and international noise conferences. I
am currently a member of the working group for the American National Standards
Institute's American National Standard for "Quantities and Procedures for Description
and Measurement of Environmental Sound -- Part 5: Sound Level Descriptors For
Determination of Compatible Land Use, ANSI S12.9-199x--Part 5.
I have passed the required written examination, and have been elected a member
in good standing by the Officers and Board of Directors of the Institute of Noise Control
Engineering (INCE).
I currently manage the noise program at the Illinois EPA. My annual
responsibilities include assisting approximately 2000 citizens with noise complaints, and
approximately 1000 informational calls dealing with technical questions about noise
pollution measurement and control. I also testify at many noise enforcement hearings and
take noise measurements when necessary. In addition to the Noise Advisor, there is one
additional person in the noise program. This person is an assistant. The current
responsibilities of the noise program consume all of our available work hours.
Since previous testimony has described peaker plants in detail, I will confine my
narrative to the potential noise issues related to today’s topic.
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Peaker plants pose a greater threat than other types of State regulated facilities
with respect to noise pollution because the gas turbine engine used in peakers is one of
the most powerful (loudest) noise sources in the U.S. The noise power that must be
contained and neutralized in the peaker is tremendous. The potential for releasing great
amounts of sound power, poses a greater threat than most other types of State regulated
facilities. Its characteristic emissions can be nuisance noise (35 Ill. Adm. Code 900.102),
broadband noise (35 Ill. Adm. Code 901.102(b)), and tonal noise (35 Ill. Adm. Code
901.106).
Peaker noise emissions can greatly exceed the limits required in 35 Ill. Adm.
Code 900.102, 901.102(b), and 901.106. This can occur if the noise is not controlled in
the peaker housing, and the utilization of whatever land buffer or setback needed is not
considered when choosing a site.
Peaker noise control is accomplished through four noise control strategies. The
first three of these address noise reduction at the peaker itself. Rough approximations are
presented in the form of percentages rather than in the decibel limits found in 35 Ill.
Adm. Code 901.102(b). Percentages are easier for the average person, who is not an
acoustician, to understand. Accurate and adequate noise control of peakers must be based
on the decibel limits in Section 901.102(b).
The first control strategy is comprised of combustion air intake silencers which,
when properly designed and installed in the average peaker, reduce the intake noise by
approximately 99.999% to 99.99999%.
Second, a hardened acoustic enclosure
completely containing the gas turbine. It traps over approximately 99.999% to
99.99999% of noise radiated from the outer shell of the turbine. Third, a combustion gas
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exhaust silencers which, when properly designed and installed, reduce the exhaust noise
by approximately 99.9999% to 99.999999%. Finally, a buffer of land, controlled by the
peaker plant, sufficient to provide enough distance for the noise escaping the plant to
dissipate sufficiently to meet all State noise pollution requirements. This land buffer
should be based on the amount of noise reduction needed at the property line of the
power facility.
Another control strategy involves a new technology called “active noise
cancellation.” This promises the potential of being able to cancel much of the very low
frequency (rumble) noise associated with large gas turbines. This technology should be
viewed with caution due to its unproven record when used in low cost applications.
However, it could be considered when the more traditional silencer technology is not able
to satisfactorily address the rumble problem.
Setbacks are an important concept in addressing peaker noise. A need exists for
setbacks (land buffers) consisting of land owned or controlled by the peaker plant. The
setback distance necessary would depend on what level of noise abatement was included
in the initial design of the peaker plant. The most frequently encountered noise pollution
problem seen in complaints and noise pollution enforcement cases before the Board is
that of residential development eventually coming to the nuisance noise emissions. A
facility may be in compliance, even though noisy, because it is not near residential
property. If the facility does not control the use of the surrounding property, such a
scenario is likely to occur. There is nothing to stop the farm owner (the typical situation)
from selling the land for residential development, and the facility no longer has the
luxury of a large distance to the nearest home.
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To avoid the problem of peaker noise impacting noise sensitive areas, compliance
reviews (on paper) of the facility designs are essential to insure future compliance with
the Noise Regulations. Then, before full operation is started, the peaker should show that
it can be operated at or below the nighttime noise limits (35 Ill. Adm. Code 901.102(b)).
If a peaker plant could not show compliance through a demonstration, the problems could
be resolved at the beginning. All of this argues strongly that the design and noise
compliance review of that design are the most important project events. Designing and
adding on noise compliance after the plant is built may be next to impossible.
Other state noise programs were reviewed to see if new or unique regulatory
methods are in use. My review of a report of noise regulation in the U.S. (see Illinois
EPA Exhibit 19) shows that noise abatement is not regulated by 43 states. Six states have
very little noise regulation. Illinois is more active than the others in regulating noise.
Peaker noise is not regulated by the other Region 5 states, California, Texas, or New
York. However, please remember that the noise may be regulated by local ordinance in
some of these states. It should be noted that in many of these states that have little state
regulation, the larger cities may conduct regulation of noise through local ordinances.
Finally, peaker noise is not regulated on the federal level.
Another concern over potential peaker noise problems is the potential for
impacting property values. As with any other types of industrial noise sources, if the
peakers exceeded the noise regulations, they could have a significant effect on negatively
impacting property values. Noise at such levels would likely be noticeable by prospective
purchasers of property, and any potential commercial investors.
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Local zoning has been a significant factor in many of the noise complaints I have
handled. In my experience with the noise complaints filed with the Board, it appears that
local zoning has not considered the land buffer component of noise control in making
zoning decisions. Of course, the reason may be that the noise level from the facility may
not be appreciated, or even understood, until the facility is built and operating. This issue
also strongly argues for the importance of pre-construction design review.
The Illinois EPA has received no noise complaints regarding existing peaker
plants, so it would be difficult for me to comment on more stringent regulation of the
existing plants. Stricter noise emission control could first be considered for new facilities
and expansions. Upgrading costs would be extremely high, if not prohibitive, for added
noise control. Silencing equipment comprises the bulk of the peaker plant and is carefully
tuned to match the turbine. In some cases it may be less expensive to install a whole new
unit than try to upgrade the old one.
Questions will arise regarding the economic impact of potential additional
requirements. The cost could be anywhere on the spectrum depending on how stringent
the requirements are made. However, I can confidently say that adding additional noise
control in the design stage is much less expensive than adding it on after the installation
is operational.
I cannot say that there are currently any gaps in the regulations. It may be that
there is inadequate pre-construction design work and design review relevant to noise
compliance issues. I believe that considerable information would be ava ilable from the
turbine manufacturer that could be evaluated by a competent noise consultant to help
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design the four components of noise control I mentioned earlier: intake; turbine
enclosure; exhaust; and, land buffer. Failure to adequately plan for any one of the four
could lead to future noncompliance. It may be too late and/or too expensive to look at the
problem only after numerous citizens are impacted to a nuisance level.
Thank you for listening.
Illinois Environmental Protection Agency
By: _____________________________
Greg Zak
DATED: August ___, 2000
1021 North Grand Avenue Northeast
P.O. Box 19276
Springfield, IL 62794 –9276
217/782-5544