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RECEIVED

CLERK’S

OFFICE

NOV

1

3

2000

Illinois

Pollution Control Board

STATE

OF LUNOIS

Docket ~ ROl-lO

Pollution

Control Board

Ms. Dorothy Gunn,

Clerk

Illinois Pollution Control Board

100 WestRandolph

Street,

Suite

11-500

Chicago, Illinois 60602

~::9~7c

,W/f~

Dear Ms. Gunn:

The

following

are

recommendations for actions

that

we believe can be

accomplished

by

administrative orderofthe

Director

of

the illinois Environmental Protection Agency

for

all

gas or

oil

powered electncal generation

facilities

seeking

permit approval in the State of

illinois:

Maintain

a reliableup-to-date

source

ofdata including:

—

Existing

Capacity throughout

MAIN

-

Projected

Need

throughout

MAIN

—

Detailed Projected Capacity

throughout

MAIN (including

status

of

both

Environmental

approvals

and local

zoning approvals)

This

report should be posted

on the IEPA

web site and

be available in

written

form to be

sent out to

anyone

who requests the

information.

The

data should be readily available

from the MAIN

offices.

2.

Create a

additional

form of

infonnation

to be

provided to the agency by

each applicant

seeking

an air pollution

construction

permit for a

gas

or oil

theled

power generation

facility.

The

new

information to be

requested

of

these

applicants

should

include:

—

Analysis

of

the

chemistry ofthe

water

from

any

proposed

private

well

sources including whether

the water contains radon,

barium, arsenic,etc.

—

Detailed outline

ofwhat water

will

be

used for in

the operation ofthe

facility, the quantities proposed to be

used

on an hourly,

daily and annual

basis

with an

analysis

of

alternatives

available for

each

ofthe proposed uses

of

water.

—

Detailed

outline ofhow much wastewater will be producedby

the

operation ofthe facility on an

hourly, daily

and

annual basis; what the

constituents ofthe wastewater will be; what treatment will occur on the

site ofthefacility;

and

where thewater will be

discharged.

This

should

include an

analysis

ofalternatives available for each ofthe proposed

wastewater treatments

included.

—

For

all

emission

data submitted in

the

application, the applicant

shall

provide

actual

test data from all

sites

using

the

sameturbine.

—

For

all

air modeling done, the point ofmaximum impact for each

pollutant modeled must be shown on a

map ofthe area surrounding the

proposed

facility and

clearly identified including the

actual

level of

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Nov-06-00

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dianne turnball

8153370185

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concentration

for

each

of

these

points of

maximum

impact.

—

The

serial numbers ofthe

turbines

proposed for the facility.

—

Modeling

shall be done using

the

months of

Maythrough

September for

those

facilities

proposing to operate on a

part- time

basis

including

using

the

average

temperatures,

humidity,

wind

conditions, weather

conditions,

etc. that occur

during these months only

and not

annual

averages.

3.

Institute a

permit fee structure

to cover the costs ofthe review ofthe applications.

4.

Requirea

noise constniction/operation

permit

to be filed

simultaneously with any

air

construction permit

and require

joint issuanceofthe permits.

5.

Require that

any

significant modification or additions of

information

by the applicant after

the

closing ofthe public record would necessitate at a

minimum

a new public

notice

with a

public

healing if a request is madefor one.

6.

Post all permit applications on the IEPA

web

site.

7.

DeveLop

new air modeling parameters based onthe proposed months of

operation

ofthese

facilities and

not

on

annual

averages.

8.

Requirethat

the applicant

submit

a list of adjacent property

owners within

500

feet

ofthe

proposed facility

and

a list ofmunicipalities within one

and a halfmiles

ofthe proposed

facility.

IEPA would

then

send

the

public notice of

hearing

to these

lists.

9.

All information

submitted by the applicant as well as

all staffcorrespondence

to

the

applicant

and any air modeling

analysis done

by IEPA staff

shall

be maintained

in a

public

file

that

is available for public

inspection at

the

Springfield oftices.

This public

recordfile

shall be available for inspection

at

any

time that the office is

open.

Pleaseforward this communication onto the Board

and

have it

included in the public

Sincerely,

Concerned

Citizens of

Lake

County

and

Liberty Prairie

Conservancy