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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OCT 28 2003

iN THE MATTER OF:

)

STATE OF ILLINOIS

)

Pollution

Control Board

PROPOSED SITE SPECIFIC REGULATION

)

R04-

APPLICABLE TO AMEREN ENERGY

GENERATING COMPANY, ELGIN, ILLINOIS

)

AMENDING

35

Iii. Adm. Code 901

)

PROPOSAL FOR A SITE-SPECIFIC RULEMAKING

NOW COMES the Proponent Ameren Energy Generating Company (hereinafter

“Ameren”), by and through its attorneys, SchiffHardin & Waite, and hereby petitions the Illinois

Pollution Control Board (hereinafter “Board” or “IPCB”) for site specific noise emission

limitations with respect to the operation ofthe Ameren electric generating facilityin Elgin,

Illinois. This proposal is submitted pursuant to Section 28(a) ofthe Illinois Environmental

Protection Act,

415

ILCS 5/28(a), and in accordance with Part 102, Subpart B ofthe Illinois

Pollution Control Board’s Procedural Rules,

35

Ill. Adm. Code 102.Subpart B. In support

hereof, Ameren provides the following information.

I.

INTRODUCTION

Anieren owns a power generating facility in Elgin, Illinois which consists of four simple

cycle combustion turbines capable of generating up to

540

MWof electricity (“Facility”). The

Facility is described as a peaking facility, a power generation plant design~dto start up rapidly to

generate power when critically needed. It was initially permitted to construct by.the Illinois

Environmental Protection Agency, Bureau ofAir on June 8, 2001, and was fully operational in

November, 2002. The Facility is located on

1559

Gifford Road in Elgin, Illinois in an area that

is primarily industrial. Currently and when constructed, the land uses in the immediate area, in

addition to industrial uses, have been agricultural, mining and excavation, and vacant land.

Because the Facility is industrial

(i.e.,

a Class C land use under the Board’s noise regulations)

and its nearest neighbors are likewise industrial, the Board’s noise regulations have generally not

been applicable. The Board’s noise rules provide no noise limitations concerning noise from

industrial facilities to receiving industrial land uses. In those few instances where the Board’s

noise emission limitations for residential and commercial uses have been applicable,

i.e.,

at a few

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nearby single residences and residential developments, the Facility has been able to comply with

the applicable noise limitations. Furthermore, to the best ofAmeren’s knowledge,no noise

cemplaints have been alleged by any ofits neighbors since Ameren began construction and

operation ofthe Facility.

Due to a proposed change in land use in the area ofthe Facility, Ameren must now seek

site specific relief from the Board’s noise emission limitations for receiving Class A and Class B

lands found at

35

Ill. Adm. Code Part 901. The land immediately west of the facility is vacant

and until very recently was in unincorporated Cook County and zoned Industrial. On June 3,

2003, the Village ofBartlett annexed and rezoned this parcel forresidential use at the request of

Realen Homes, a residential development corporation. Realen Homes intends to build single

family residences on this westerly property (hereinafter, “Realen property”.) Amerenhas studied

the implications ofthis land use change and concluded that the Facility will probably not be able

to always meet the Class A noise limitations at

35

Ill. Adm. Code 901.102, which heretofore

were not applicable. For this reason, Ameren is seeking a site specific rule from the Board that

establishes noise emission limitations for this Facility that are applicable to receiving Class A

lands. The Class A site specific limitations requested are equal to the Board’s daytime limits for

Class A receiving land but forthose limits proposed at the

31.5,

1000, 2000, and 4000 Hertz

octave bands.

Ameren also requests that the Board adopt site specific noise emission limitations

applicable to receiving Class B lands. The site specific Class B noise limits, that Ameren

proposes are numerically the same as the generally applicable limitations for six of the nine

octave bands found at 35 Ill. Adm. Code 901.103. As for the remaining three octave band

limitations, the 1000, 2000 and 4000 Hertz octave bands, the current Board noise limits are more

stringent than those requested by Ameren as its site specific noise limits for Class A lands. To

reconcile this inconsistency, Ameren requests that Class B site specific noise limits adopted at

the 1000, 2000 and 4000 Hertz octave bands be the same numerical value as those proposed for

Class A lands.

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The site specific limits sought for both Class A and Class B receiving lands are as follows:

Octave Band Center Frequency (Hertz)

31.5

63 125 250 500 1K 2K 4K 8K

Allowable dB ofSound Emitted to Receiving

Class A Land

80

S

74

69

64

58

58

58

50

40

Allowable dB of Sound Emitted to Receiving

ClassBLand

80

79

74

69

63

58

58

50 45

II. PROPOSED SITE SPECIFIC RULE

35111. Adm. Code 102.210(a)

The Class A and Class B noise emission limitations in the Board’s Chapter Nine are

found at 35 Ill. Adm. Code 901.102 and 901.103. Individual emission limitations are expressed

in each ofnine octave band sound pressure levels with different levels allowed during day and

nighttime periods for Class A receiving lands. Ameren respectfully requests that in lieu ofthose

noise emission limitations, the following language and numerical limits be adopted by the Board

to provide site specific noise limitations for noise from the Facility to receiving Class A land and

Class B land:

The Board requires that a site specific rule be proposed as its own section if proponent

seeks modification ofthe rule ofgeneral applicability. 35 III. Adm. Code 102.2 10(a). Therefore,

Ameren requests that this new language be adopted as an entirely new section at Subtitle H:

Noise, Part 901 ofthe Board’s regulations.

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Section 901.xxx

Ameren Elgin Facility Site-Specific Noise Emission Limitations

The Combustion Turbine Power Generation Facility located at 1559 Gifford Road in

Elgin, Illinois shall not cause or allow the emission ofsound from any property-line-noise

source located on that property which exceeds any allowable octave band sound pressure

level specified in the following table, when measured at any point within the receiving

Class A or Class B land.

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Allowable Octave Band Sound Pressure

Levels (dB) of Sound Emitted to any

Octave Band Center Frequency (Hertz~

Receiving Class A or Class B Land from

Ameren Elgin Facility

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Class A Land

Class B Land’

31.5

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24

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24

1000

2000

‘

58

58

4000

‘

50

50

8000

40

45,

As explained more fully herein, the adoption of these site specific noise limitations will

allow Ameren to continue to operate the Facility as designed to provide the maximum noise

control that is economically reasonably and technically feasible. The only area affected by

adopting the proposed rule is the Realen property in the event it converts to the proposed

residential use, and any environmental impact to that property will be minimal since the area’s

ambient noise is comparable to and oftentimes greater than that attributable to the Facility.

Moreover, the adoption of these proposed limits will allow Ameren to continue to generate

power at the Facility and provide energy to the constantly growing urban community when most

needed.

III. STATEMENT OF

REASONS

In accordance with the Board’s procedural rules at Sections 102.202 and 102.210,

Ameren submits the information required to support this site specific petition. In sum, this

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information demonstrates the need for the requested site specific noise emission limitations, the

reason why compliance with the general rule is not technically feasible or economically

reasonable for the Facility, describes the area affected by the proposed site specific rule, and

addresses the environmental impact ofthe proposed~noiseemission limitations on the affected

area.

A. Character ofthe Area Involved, the Character of Surrounding Land Uses, and

Description ofArea Affected by Change

415 ILCS

5/27(a),

and 35 Ill. Adm. Code 102.210(b)

and (c)

As described more fully below, the character ofthe area is industrial, and the area

affected by the proposed rule change is the property directly west ofthe Facility, the Realen

property, because ofthe recent change in its zoning and proposed change to a residential use

1 Character of Area Involved and of the Surrounding Land Uses

The area immediately surrounding the Facility can be descnbed as heavily industrial

The Facility, as an electric generation plant, is classified as an industnal land use It is located at

1559 Gifford Road To the immediate north ofthe Facility is GE Capital Module Space, a

storage yard oftemporary office trailers Immediately east ofthe Elgin facility is BFI Waste

Systems facility, and Just further east, is Commonwealth Edison’s high powered transmission

line corridor, and the E E & J Railroad, both runmng north and south, crossing Route 20 to the

north To the immediate south ofthe Facility are two construction companies, and further south

at 1717 Gifford Road is U S Can Company, a manufacturing facility To the immediate west,

separated by Gifford Road and currently vacant is the Realen property, which is a portion of

property formerly proposed for use as a balefill operation by the Solid Waste Agency of

Northern Cook County (“SWANCC”). To the northwest and west of Gifford Road is Bluff City

Materials, a quarry and mining operation Elsewhere in the area are different industrial concerns

composed oflight and heavy duty manufacturing, such as the Elgin Sweeper plant.

The predominant industrial character ofthe area creates heavy truck traffic and other

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vehicular traffic on Gifford Road and West Bartlett Road The quarry and mining operation

contributes a great number ofdump trucks and heavy equipment trucks. The nature ofU.S. Can

:

Company’s operations contribute many tractor trailer trucks Gifford Road also serves as an

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alternative route for vehicle and truck traffic traveling south from Lake Street, Route 20.

See

Attachment A: Existing Land Uses.

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The closest residential or commercial use west ofthe Facility is more than a mile away.

A single family residence is located on Spaulding Road to the north. Also on Spaulding Road,

east ofthe EE & J railroad, is the Amber Grove Subdivision. Spring Lakes Mobile Homes on

James Street is due east ofthe Facility and currently is the closest residential use. Two

residential subdivisions and a school are located south ofthe Facility and south ofWest Bartlett

Road They are the Westridge Subdivision on Rushmore Drive, and the Westndge Subdivision

on West Bartlett Road which includes the Nature Ridge School on West Bartlett Road.

2 Description ofArea Affected by Change

At the present time, the Facility is in compliance with the Board’s noise regulations at 35

Ill Adm Code 901 102 and 901 103 As for its industrial neighbors, there are no applicable

numerical limitations As for the nearby residential areas, recent sound measurements taken in

June, 2003 demonstrate compliance with the Class A Land limits found at 35 Ill Adm Code

901 102

The only area affected by the proposed site specific rule proposed for receiving Class A

land is that directly west of the Facilityjust across Gifford Road, the property recently purchased

by Realen Homes The Realen property is bounded on the north by Bluff City Materials, on the

south by West Bartlett Road, and on the west by property recently acquired by the Illinois

Department ofNatural Resources from SWANCC. The Realen property is currently vacant, and

was zoned industrial under the Cook County Code until recently when Realen Homes petitioned

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the Village ofBartlett to annex it. On June 3, 2003, the Realen Property was annexed by the

Village ofBartlett and rezoned as a PD Planned Development Zoning District under the Bartlett

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Municipal Code. Realen Homes intends to build multi-family and single family housing on its

property. Realen Homes anticipates building and selling approximately 210 single family homes

and 119 townhomes in 32 buildings on the property. Realen would like to begin construction

and sale ofthese homes in the Fall. ofthis year.

Zoning classifications are not discussed in detail because the Board’snoise regulations

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and this amendment proposed thereto are premised on land use as opposed to zoning

classifications.

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B. Description of the Facility Site and Operations

35

Ill. Adm. Code 102.210(c)

1. Description ofthe Facility.

The Facility is a power generation facility consisting of four simple cycle combustion

turbines which combined are capable ofgenerating up to 540 megawatts ofelectricity. The

Facility is often described as a peaker facility and is comprised ofmodel W5O1D5A combustion

turbines manufactured and supplied by Siemens Westinghouse. Generally the Facility is

expected to operate during time periods when the demand for electricity is highest, such as on

hot summer days or during very cold weather in the winter. It also operates at other times as

needed to meet the demand for electric power. While all four units can operate simultaneously,

single units or any combination thereofmay operate at any time as the market for electricity may

reqUire.

See

Attachment B: Elgin Facility Site Layout Plan..

The principal part ofeach unit’s combustion turbine is a rotary engine, very similar to a

jet engine but designed only for stationary operation. Natural gas is continuously burned in

combustors and then the hot combustion gases expand through the turbine to rotate a shaft

connected to the electrical generator. Air for the combustion turbine is drawn through an intake

filter and parallel baffle silencer into the intake manifold. Exhaust gases from the turbine flow

through an exhaust duct and stack fitted with absorptive parallel baffle silencers. Please note that

the primary sources ofnoise from the Facility include the combustion process and the flow ofair

and exhaust gases.

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The remainder of the Facility consists of auxiliary equipment needed to support its

operation, including the air-cooled generators, transformers and heat exchangers.

See

Attachment C: Simple Cycle Combustion Turbine Power Plant.

2. Description

of the Facility’s Noise Control Equipment.

The Facility is equipped with several different kinds ofnoise abatement systems which

include highly engineered controls in the air inlet and exhaust systems. Noise enclosures and

silencers are used extensively to control the sound produced by the combustion turbines and

supporting power generation equipment. The turbine ofeach unit is enclosed and equipped with

enclosure ventilation silencing. The majority of noise emitted by the turbine comes first from the

opening needed to get air into the turbine’s compressor, the inlet, and then from the opening

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needed to get the combustion exhaust gases out ofthe turbine. Both areas are difficult to control

acoustically because they are linked directlyto the noisiest internal parts ofthe turbine engine

and, to operate most efficiently, the air and gas flowpaths to and from the engine must be

minimally blocked. Therefore, the intake and exhaust flow paths must be treated with

.

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acoustically absorptive parallel baffles that allow flow to pass through the open gaps that exist

between the absorptive sound baffles. These silencers provide a large amount ofnoise reduction

while offering an acceptable pressure loss to the turbine.

See

Attachment D: Elgin Facility

Noise Control Devices.

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Inlet Silencing.

At the Facility, the air intake for each turbine is enclosed, and each unit’s

air intake is equipped with inlet silencer baffles. This substantial inlet silencing is combined

with extensive duct structural stiffening and lagging as secondary noise attenuation to further

reduce sound radiating from the air intake system.

Exhaust Silencing.

The exhaust silencing installed at each ofthe Facility’s units is state

ofthe art for this type of Siemens Westinghouse combustion turbine. The silencer panels were

dimensionally designed by Siemens Westinghouse specifically for this Facility to attenuate the

low frequency 31.5 Hz and 63 Hz octave bands while also providing substantial mid and high

frequency noise reduction. The silencer panels at this Facility are extra thick and very long

compared to that used at other 5O1D5A plants. In fact, the exhaust silencing system is so long.

that a special horizontal section ofsilencer panels approximately 35 feet in length and supported

on the ground was us.ed to accommodate the massive exhaust silencer. The traditional 50 foot

high vertical exhaust stack was also used to provide an additioflal 15 feet of silencers. Finally, to

keep sound from radiating from the exhaust ducting surfaces, an extra, secondary enclosure

system was provided to encase the expansion joints and exhaust ducting. This enclosure consists

ofacoustically insulated V4 inch or more steel plate.

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Costs ofNoise Control Equipment:

The approximate cost for noise abatement measures

for all four units was a total of$1 1,650,000.

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C.

Demonstration that Compliance with General Rule is not Technically Feasible or

Economically Reasonable,

35 Ill. Adm. Code 102.210(b),

Treatment or Control Options, 35111. Adm. Code 102.210(c).

At the time the Facility was built, the Board’s generally applicable noise limitations for

the most part did not apply because the Facility was a Class C facility surrounded by other

industrial, Class C land uses. Nevertheless, Ariieren commissioned a Design Phase Study to

evaluate the possible impact ofsound pressure levels from the planned facility on the area and to

determine the necessity and value of equipping the planned facility with noise abatement

equipment beyond that standard to the industry. As for the nearby residential areas to the east

and south, Ameren studied and determined that the Facility would comply with the Board’s noise

limitations applicable to those Class A receiving lands. Based upon the study, Ameren installed

a state ofthe art exhaust silencing system and all the other noise abatement controls described

above. The Design Phase Study is discussed at the end ofthis section as background

information.

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Due to immediate proximity ofthe newly proposed residential area, Ameren has

determined that the Facility may not always be able to comply with the Board’s Class A noise

limitations at the Realen property despite the extensive sound abatement equipment already in

place. Therefore, Ameren investigated the technical feasibility and costs of installing additional

noise control equipment at the Facility as a means of meeting the Board’s general noise emission

regulations for Class A receiving lands. That evaluation follows.

See

also Attachment E:

Estimated Costs ofNoise Abatement Measures.

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Although the exhaust-silencing system installed when the Facility was built was state of

the art affording maximum noise control, several experimental methods for reducing low

frequency noise were recently evaluated. These alternatives are not proven technologies.

Therefore, the cost estimates provided are speculative. Methods for reducing mid to high

frequency noise associated with other parts ofthe Facility were also evaluated and projected

costs estimated. While some ofthese options may be technically feasible, most require that

additional equipment must be installed on the units creating additional backpressure that will

cause the unit to be derated. Derating has a significant detrimental, real economic impact upon

the value ofthe Facility. This economical consequence, in addition to the capital costs of

additional equipment must be considered as part ofthe economic reasonableness of any

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technology considered. Finally, the costs for controlling mid to high frequency noise are not

warranted given that much ofthe ambient noise contributed in the area is at the same level and

oflen not discernable from the Facility’s contribution.

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1.

Technical Infeasibility and Economic Unreasonableness of Further Reducing

Low Frequency Noise at the Turbine’s Exhaust.

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Additional Exhaust StackSilencers.

As explained at Section B.2 above, the exhaust

silencer equipment at the Facility was specially designed for the Facility. The cost for that

.

equipment alone, excluding installation expenses, was $2,290,000. Nevertheless, Ameren

investigated whether more could be done to further reduce low frequency sound from the

exhaust One method considered was adding approximately 40 more feet ofvertical exhaust

stack equipped with silencers Even then, the installation ofthe additional vertical stack and

silencers can not guarantee that compliance will be achieved The current aerodynamics ofthe

exhaust silencer may not be able to accommodate additional stack height and silencers. In any

case, the additional backpressure created by the installation ofmore equipment will cause the

units to be derated Furthermore, the installation ofthis type ofadditional control is estimated to

be ~6,000,000, which is nearly three times the cost of the original exhaust ducting and silencers

Redesigned New Stack

Ameren also investigated completely redesigning and installing

a new stack Such a new stack would require full aerodynamic modeling to design a nearly

perfect aerodynamic system for low frequency noise reduction Currently, no such exhaust

stacks are available in the United States that meet that criteria, so there is no guarantee that this

innovative technology could provide the noise reductions necessary to demonstrate compliance

with the Board’s general noise emission limitations. For all four units to be equipped with new,

redesigned stacks, the cost for such an experiment is estimated to be $18,000,000

ExperimentalActive Noise Control

An active noise control system for low frequency

noise reduction has been developed under a NASA contract, but it has never been used in the

power industry The NASA active noise control system would have to work in conjunction with

the existing passive silencing for low frequency noise reductions. The actual technical feasibility

ofusing such an active system with the existing passive system at the Facility is not known The

engineering team which developed the system under contract with NASA would have to first

investigate the feasibility ofsuch a system for the Facility. Even if such an untried system was

determined to possibly be technically feasible, the estimated cost for such a system is estimated

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to be a minimum of $6,000,000, excluding the costs associated with the research and

development efforts.

2. Technical Feasibility or Economic Reasonableness of Further Reducing Mid and

High Frequency Noise.

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a.

Detailed Noise Study.

The first step to determine what additional noise control

options might be feasible at the Facility would be to conduct a detailed noise study to determine

the octave band sound power levels ofeach sound source such as the turbine, inlet system,

exhaust system, generator, transformers, pumps, motors, fans, and coolers. Once identified, the

study would then have to evaluate the feasibility ofthe various sound source treatments

described below to determine if such additional controls could be installed and could achieve

compliance. The systems to be considered include generator sound treatment, barrier walls and

possibly additional inlet system silencing. Power Acoustics, Inc., the noise consultant that assess

the sound impact ofthe Facility during its conceptual stage, estimated the cost for such a study at

$25,000.

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b. Evaluation ofMid to High Frequency Noise Reduction.

When evaluating the cost of

the options described below for further reducing mid or high frequency noise levels, the cost

estimate should be compared to two factors. First, many ofthe area’s ambient noise sources

contribute mid and high frequency noise, such as airplane flyovers, trains, car and truck traffic.

Second, people usually act to reduce these types ofnoise by physically closing out the noise

sources. The Facility’s contributions to these types ofnoise levels usually has little or no impact

because it generally operates during hot or cold weather when most people have closed their

windows and doors and relied upon air conditioning or heating. Therefore, the costs associated

with reducing mid and high frequency noise from the Facility is not warranted given the inherent

reduction brought about by most people’s behavior when the Facility is most likely to be

operating.

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Mid Frequency Noise Reduction Control Methods.

The generator is currently enclosed,

which provides noise reduction. If, however, the above described noise study found the

generator to still be a significant source ofmid frequencynoise, the installation of a secondary

enclosure could be evaluated to determine if it would sufficiently reduce noise.to a level ensuring

compliance. The estimated cost of this additional control method is $1,200,000, installed.

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Mid and High Frequency Noise Reduction Control Methods.

A barrier wall could be

installed on the west side ofeach unit to possibly reduce mid and high frequency noise The

total estimated cost of bamer walls for all four units is estimated to be approximately

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$3,6000,000.

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High Frequency Noise Reduction

The inlet system is already controlled with silencers

However, if the inlet system is found to still be a significant source ofnoise, additional inlet

silencers may be possible depending on whether there is sufficient room in the system to install

them. The estimated cost ofinstalling this such noise control equipment is $600,000. Finally, if

the additional inlet silencers are not sufficient, a secondary enclosure around the inlet ducting

could be considered. The estimated installed cost ofthat type ofnoise control is $1,200,000.

3. Design Phase Study of Facility Pre-Construction, 2000

In November, 2000, Power Acoustics performed an

Acoustical Evaluation and Ambient

Sound Survey

ofthe then proposed Facility As a result ofthis Design Phase Study, the Facility

was designed to meet the Board’s noise regulations protective of the local community. The noise

pollution control measures incorporated in the design included natural buffering by’distance,

shielding noise sources by structures, and add-on controls to further minimize the effect ofthe

plant.noise on the community.

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Primarily there were two components to the Design Phase Study First, background

ambient sound pressure levels were measured to characterize the combined sound pressure level

from all localized ambient sound sources at residential receptors near the proposed Facility

Second, an acoustical model ofthe proposed Facilitywas developed to predict whether

compliance with the Board’s noise emission limitations would be achieved at the critical receptor

points,

i.e.,

nearby residential locations and one possibly commercial facility.

a. Sound Measurement Study

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Sound field measurements were conducted to quantify the combined sound

pressure level from all localized ambient noise sources at critical receptors. Since receptors

,

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closest to the proposed plant would have the highest potential impact, those were the locations

measured The critical receptor locations are listed clockwise from northeast ofthe proposed site

asfollows:

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1 Patio and Ponds Landscaping on Spaulding Road

2. Single Home, Spaulding Road

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3. Amber Grove Subdivision, Spaulding Road

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4. Spring Lakes Mobile Homes, James Street

5.

Westridge Subdivision, Rushmore Drive

6. Nature Ridge School and Westridge Subdivision, West Barlett Road and

Westridge Boulevard.

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See

Attachment F: Ambient Sound Measurement Locations Representative ofCritical

Receptors.

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Since areas to the west ofthe site were vacant, and the closest residential or commercial

use west of the site was more than a mile away, no sound measurements were taken west of the

proposed Facility. Please note that areas further from the Facility will experience lower sound

levels than those closest to the Facility.

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b. SoundSurvey Results

Several sound level measurements were made under representative community

conditions. Daytime measurements were made between 11:30 am and 2:00 pm and 8:00 pm and

10:00 pm on October 10,2000, and between 11:30 am and 2:00 pm on October 11, 2000. Since

noise impacts are greatest when existing noise levels are lowest, the measurements were also

conducted under conditions typical ofa quiet nighttime period for the area. Nighttime

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measurements.were made between 12:30 am and 2:30 am on October 11,2000. The

measurements were made under clear conditions with warm daytime and moderate nighttime

temperatures and low wind. Sounds observed are primarily those associated with heavy

continuous truck and automobile traffic on West Bartlett Road, sounds from the U.S. Can

Company facility, trains and other industrial truck noise in the area. Distant traffic noise from

Routes 20 and 25 were also heard.

The closest residential areas are within the Spring Lakes Mobile Home Park and at the

Westridge Subdivision near Rushmore Drive. The existing daytime background ambient sound

level was found to be approximately 50 dB(A), and the nighttime ambient sound level was found

to be approximately 43 dB(A) at Spring Lakes Mobile Home Park. The ambient sound level

near the Westridge Subdivision was found to be approximately 53 dB(A) during both daytime

and nighttime measurements. The A-weighted equivalent sound pressure level, or Leq, is

generally used as the basis for quantifying or regulating noise.

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c. Sound Propagation Model

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This analysis was conducted to estimate the noise that would be generated by the future

operation ofthe Facility. The computer model used for calculating outdoor noise propagation in

community and industrial environments was a worldwide accepted standard, and conservative

components were used to ensure that calculated sound pressure levels were representative of

favorable (downwind) noise propagation conditions.

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The major noise sources modeled were the combustion turbine air intake systcm, the

combustion turbine stack walls and exit noise, the combustion turbine enclosure, and generator,

transformers, and fan coolers. The source sound power level data for this equipment was

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provided bySiemens Westinghouse and was based on other, similar W5O1D5A projects. The

model factored in the noise abatement measures that were later installed at the Facility

The model predicted that compliance with the Board’s nighttime limitations would be

achieved at all critical residential locations. Although levels at some octave bands were

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estimated to approach the Board’s limits, due to its conservative components, the model

predicted that the Facility as designed would achieve compliance in all octave bands with four

units in operation.

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5

5

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The following table contains a summary of the estimated sound pressure levels predicted

with all four units operating and compared to the Board’s generally applicable noise regulations.

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The sound pressure level data shown at the critical receptors is representative ofthe noise

anticipated to be emitted from only the Facility, aftercorrection for existing ambient sound

sources.

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Octave Band Center Frequency, Hertz

Location

31.5

63

125

250

500

1000

2000

4000

8000

DB(A)

L.1 Patio & Ponds Landscaping (Reference Only)

L-2 Home on Spaulding Rd

L-3 Amber Grove Subdivision

L-4

Spring Lakes Mobile Homes

L.5 Westridge Subdivision

L-6 Nature Ridge School

70

62

62

53

48

43

37

26

0

51

68

59

59

50

44

39

32

17

0

48

66

57

56

47

41

35

27

8

0

45

68

60

60

51

45

41

.

35

22

0

. 49

69

63

61

51

45

40

34

22

0

49

68

62

61

52

45

39

32

16

0

49

Illinois Daytime Class A Regulations

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75

74

69

64

58

52

47

43

. 40

61

Illinois Class B Commercial Regulations

80

79

74

69

63

57

52

48

45

66

d. Conclusion of2000 Design Phase Study

The ambient sound pressure levels measured at the critical receptors near the

proposed Facility were found to be dominated by car and truck traffic, railroad operations and

industrial sounds including idling trucks. The computer noise model ofthe Facility estimated

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the sound pressure level to be at orbelow the Board’s noise nighttime limits at all critical

residential receptors. The noise control features factored into the modeling were included when

the Facility was built. See Section B above.

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D Description

of Other Facilities’ Noise Equipment and Compliance

35

III Adm Code

102.210(b)

The Facility is a Siemens Westinghouse equipped peaker power plant, with four

W5O1D5A combustion turbines. Siemens Westinghouse sells the turbines as part of self-

contained, electric power generation systems offered in a “modular package” format that

includes select choices ofthe standard equipment necessary to build a peakerpower plant

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equipped with this type ofturbine Because the equipment offered in this manner is fairly

standardized, only other W5O1DSA equipped facilities should be considered forpurposes of

comparing equipment and sound pressure levels Comparisons between plants equipped with

other manufacturer’s turbines and associated equipment and those equipped with the Siemens

Westinghouse turbines cannot be accurately made

The standard W5O1D5A package offers only parallel baffle silencing sections for the

inlet and exhaust systems. However, as explained in Section B.2, Ameren significantly improved

upon these standard features by upgrading them and adding additional noise abatement

measures. Ameren had Siemens Westinghouse develop and provide at this Facility extensive

S

inlet silencers sections, state ofthe art expanded exhaust silencer sections, baffles in the stacks,

and a shroud covering the turbine-to-exhaust-duct expansion joint Also included at this Facility

were increased plate thicknesses and many structural stiffeners to prevent resonance ofthe

structural members and plate materials. Siemens Westinghouse told Ameren that these

additional noise control measures were the most extensive ever employed on units of this type

Ameren knows ofno other W5O1D5A power plant equipped with this extensive amount ofnoise

reduction equipment.

S

As for information about compliance by peaker power plants with noise limitations, there

is none generally available about peaker power plants inside or outside of Illinois NQise

emission is not regulated by 43 states, and six ofthe seven states that do regulate noise

emissions, have very minimal noise regulations Therefore, information about compliance with

noise limitations is not generally available Further research indicates that peaker power plant

-15-

5

5

5

---

noise is not specifically regulated on a federal level, in the Region

5

(midwest) states, or in the

states most likely to do so: California, Texas; and New York. Therefore, compliance

information specific to peaker power plants is not available from these resources.

As for Illinois, probably the most active in noise regulation, compliance information is

not generally available for the several reasons. Like the other midwest states, noise from these

plants is not specifically regulated in Illinois.

-

Second, peaker power plants are usually located in

areas that are primarily industrial or rural, as is this Facility. In those cases, the Board’s general

noise limitations are usually not applicable because both land uses are considered Class C

properties. Third, noise is not a subject ofpermitting for the peaker powerplants. Finally, to

Ameren’s knowledge no noise complaints concerning peak power plants have been filed with the

Board, the foremost forum ofnoise complaints in Illinois. For these reasons, compliance

demonstrations with noise limitations have not been required, and therefore, information about

compliance either does not exist or is not publicly available.

E.

Description ofAll Affected Sources and Facilities

35 Ill. Adm. Code 102.202(b)

The only property affected by the site specific rule proposed for receiving Class A land is

the Realen property directly west ofthe Facility, and only afterresidences are constructed there.

The Class A limitations proposed in this site specific petition addresses those future receptors.

As part ofthe study to assess the noise impacts at the Realen property, actual

measurements were also taken at the currently existing residences the critical receptors in the

Design Phase Study. These actual measurements, taken in June 2003, demonstrated that the

existing’residences will not be affected by the proposed rule change. That same sound

measurement survey also confirmed the Design Phase Study that predicted the Board’s Class A

limits would be achieved at these existing residences.

As for commercial properties, Ameren has identified only two facilities that may be

considered Class B lands. However, neither property appears to be used for commercial

purposes at this time and therefore neither should be affected by the proposed change.

Nevertheless, a site specific rule for Class B receiving lands is advisable. As the below chart

demonstrates, if the Class B limits are not changed at the 1000, 2000, and 4000 Hz octave bands,

those limits will be slightly more stringent than three Class A limitations proposed at the same

frequencies.

S

S

-16-

---

Octave Bands

31.5

Hertz

63

125

250

500

1000

2000

4000

8000

Proposed Class

A

Limits

80

74

69

64

58

58

58

50

S

40

IPCB Class B

Limits

80

79

74

69

63

~

57

52

48

45

Proposed Class

BLimits

80

79

74

S

69

63

I

58*

‘

58*

50*

45

I

*proposed Class B Limits that are the same as those proposed for Class A

In the future, a Class A or a Class C facilitymay convert to a Class B land use. Ifso and

the proposed site specific limits are not adopted, the applicable Class B limits will then be more

stringent at three ofthe nine octave bands than those proposed for Class A receiving lands. The

proposed Class A limits at these three octave bands are sufficiently protective ofresidential

receiving property, the most protected type ofreceptor. Therefore, if the same site specific

limitations are adopted as limits for Class B lands as well, receptors at Class B lands will be

equally protected.

F. Assessment of Environmental Impact

35

Ill. Adm. Code 102.210(c)

Ameren conducted two field sound measurement projects to correctly assess the potential

S

environmental impact ofthe sound pressure levels on the Realen property. The studies

demonstrate that the Facility currently complies with the applicable Board noise emission

limitations, and therefore does not now have an adverse environmental impact on that area.

These studies also demonstrate that the Facility may not be able to achieve the Board’s Class A

noise emission limitations at all points on the Realan property when the existing land use

changes to the proposed residential use. The studies also provide the information necessary to

establish site specific sound pressure levels that consistently can be achieved when the Facility is

fully operating. To evaluate the impact of proposed limits, they are compared to other Board

noise emission limitations, including those applicable to Class B commercial receiving

properties. That comparison demonstrates that once the existing ambient noise levels in the area

are accounted for, the environmental impact ofthe proposed site specific limitations on the

Realan property is minimal.

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-17-

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1. Sound Measurement Field Studies and Conclusions

S

When Ameren learned the property directly west ofthe Facility was under consideration

for residential development, it engaged Power Acoustics, Inc. to study and estimate the

acoustical impact ofthe Facility on the Realen property. That study was conducted in June,

2003. ,A second study was performed by Noise Solutions by Greg Zak in September, 2003.

These two studies provide actual measurements ofambient noise levels, and sound pressure

levels associated with the Facility. Along with information collected in the Design Phase Study

discussed above at Section C, these two studies provide the necessary information to assess the

environmental impact ofthe Facility on the area and develop the appropriate site specific noise

emission limitations.

a. Acoustical Measurement Survey

by

Power Acoustics, Inc., June

2003

To define the ambient sound in the area, sound measurements were taken with the

Facility entirely shutdown. Next, this study consisted ofmeasuring the sound generated by the

Facility and other surrounding sound sources during baseloád operation ofa single unit, Unit 4,

the unit nearest the Realen property. These two sets ofdata allowed for the sound from the

Facility to be analytically extracted from the overall or total sound in the area. The critical

receptors were those used in the Design Study ofNovember 2000, as well as five new locations

on the Realen property.

See

Attachment F,.

S

The second component ofthis Survey was to simulate full operation ofthe Facility by

using standard analytical practices to adjust for multiple unit operation.

i. Ambient Sound Measurements.

The background ambient sound levels and

the operating sound levels ofthe unit were measured on June 17, 2003. Survey measurements

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quantified the combined sound pressure level from all localized ambient sound sources at

residential receptors near the Facility. Measurements were made under representative

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community nighttime conditions. Weather conditions were nearly perfect for measuring sound

with moderate temperatures and humidity, and no wind.

The background levels were measured on June 17, 2003 between 10:15 pm to 11 ~25pm

with the Facility totally shutdown. The ambient sound levels measured with the Facility

shutdown are recorded in the following table.

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-18-

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Octave Band Center Frequency, Hertz

Location

31.5

63

125

250

500

1000

2000

4000

8000

L-2 Home (Spaulding Rd) ‘

52.4

53.4

50.8 40.9

39.5

36.4

31.8

33.7

24.6

L-3

Amber

Grove Entrance

49.9

54.4

48.4

37.6

36.2

37.8

30.5

30.9

23.8

L-4

Spring Lakes (at 9th and James)

52.3

52.6

49.6

43.0

38.7

38.2

34.1

30.0

24.2

L-5Westridge(Rushmore)

,

64.6

61.9

54.0

46.2

39.9

39.3

36.2

29.8

23.4

L-6 Nature Ridge School

60.0

60.5

51.5

,

44.9 44.6

45.4

40.8

31.7

24.5

L-41 North Realan

-

54~9 56.2

56.3

45.1

42.6

45.8

40;3

27.0

22.7

L-R2 on Gifford across from Ameren Unit 4

58.1

59.6

55.2’ 48.3

46.9

45.9

40.7

33.7

22.1

L-R3 Midpoint of Realen

59.3

57.6

55.0

46.3

43.3

41.7

36.9

32.0

26.8

L-R4 Treeline of Realen

L-R5 Corner of Gifford and West Bartlett Rd.

~

Illinois Daytime Class A

,

57.5

56.7

57.3

46.0

40.5

40.3

36.9

30.8

23.5

63.9

65.9

66.7

60.1

53.0

50.2

47.0

37.7

26.7

~

75

74

69

64

58

42

47

43

40

Illinois Nighttime Class A

69

67

62

54

47

41

36

32

32

Cook County Ml

to Class A

72

71

‘

65

57

51

45

39

34

32

Examination of the results reveals that in many instances, the ambient background levels

approach and exceed the Board’s daytime and nighttime noise limits, as well as the Cook County

industrial requirements for Class A land. Sources ofambient noise included distant traffic,

insect, and dog barking noise. At the receptors located on the Realen property, the ambient

conditions observed included traffic on West Bartlett and noise from the U.S. Can operation.

ii. Sound Measurement Data with Unit 4 Operating Operational sound measurements

with just Unit 4 operating were taken on June 18, 2003 between 12:35 am and 2:30 am. The

weather conditions were still moderate with no wind. Unit 4 was operating at base load

producing an output of 114 MW. The sound measurements were corrected for ambient sound

sources. The results are shown in the following table.

Octave Band Center Frequency, Hertz

Làcation

‘

31.5

63

125

250

500

1000

2000

4000

8000

L.2 Home (Spaulding Rd)

55.6

nd

nd

nd

40.2

md

md

md

md

L-3 Amber Grove Entrance

52.2

md

nd

42.2

40.9

md

lnd

md

nd

L-4

Spring Lakes (at 9th and James)

54.3

md

md

md

md

md

nd

md

md

L-5 Westridge (Rushmore)

nd

md

md

mdi

md

md

nd

md

23.6

L-6 Nature Ridge School

nd

md

51.9

md

md

md

nd

md

md

L.41

North

Realen

57.7

md

md

md

md

md

nd

nd

nd

L.R2 on Gifford across from Ameren Unit 4

72.4

65.8

57.5

md

, md

49.0

47.2

39.7

25.9

L-R3 Midpoint of Realen

68.8

62.3

md

49.2

49.0

49.2

46.1

36.9

nd

L-R4 Treeline of Realen

62.4

md

md

md

md

md

nd

nd

md

L.R5 Corner of Gifford and West Bartlett Rd.

~ ~:&~z~

~

Illinois Daytime Class A

nd

nd

md

md

nd

md

md

md

nd

~

75

74

69

64

58

52

47

43

40

Illinois Nighttime Class A

69

67

62

54

47

41

36

32

32

Cook County Ml to A

~

72

71

65

57

51

45

39

34

32

Note: When the operational sound pressure levels do not exceed the ambient by more than 3 dB,

the Facility’s sound can not be reliably extracted from the measured total sound. In those cases,

the operational corrected data is present as “md” or indeterminate. The Facility is assumed

-19-

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compliant with the noise regulations if it can, not be extracted from the ambient or is

indeterminate.

This data demonstrates that when Unit 4 is fullyoperational the applicable noise

regulations are met at all currently existing residential receptors. In fact, when these

measurements were taken at the same residential receptor points used in the Design Phase Study,

the Facilitywas not audible or barely audible above the ambient sound. The data also indicates

that the daytime limits for Class A lands are met at the Realen property. However, the data

shows that with just Unit 4 operating, the nighttime Class A limits are likely to be exceeded once

the Realen property is developed for residential uses.

iii.

Extrapolated Data for All Four Units.

The sound measurements taken when Unit 4

was fully operational were then extrapolated to estimate sound pressure levels when all four units

are fully operational using simple analytical procedures. Those analytical correction assumes

that Units 1, 2, and 3 will generate identical sound pressure levels to that measured from Unit 4

operation and that any distance effects or barrier effects from spacing ofthe machines is

insignificant to the far field locations represented by these critical receptor locations.

S

Extrapolated Sound Pressure Levels with Ameren Elgin Units 1, 2, 3 and 4 at 114 MW each

Octave Band Center Frequency,

Hertz

Location

,

31.5

63

125

250

500

1000

2000

4000

8000

L-2 Home (Spaulding Rd)

61.6

md

nd

md

46.2

md

md

mnd

md

L-3 Amber Grove Entrance

58.2

nd

nd

48.2

46.9

md

md

md

md

L-4 Spring Lakes (at 9th and James)

60.3

md

md

nd

md

md

md

md

md

L-5 Westridge (Rushmore)

md

nd

nd

mndm

nd

md

md

md

29.6

L-6 Nature Ridge School

md

md

57.9 , Ind

mnd

md

md

nd

md

L-41 North Realen

63.7

md

md

nd

md

md

nd,

md

md

L-R2 on Gifford across from Ameren Unit 4

78.4

71.8

63.5

Ind

nd

55.0

53.2

45.7

31.9

L.R3 Midpomnt of Realen

74.8

68.3

md

55.2

55.0

55.2

52.1

42.9

md

L-R4 Treeline of Realen

68.4

md

nd

Ind

md

nd

mnd

md

md

L-R5 Corner

~

of Gifford and West Bartlett Rd.

Illinois Daytime Class A

md

md

md

Ind

jnd

md

nd

md

md

~

75

74

69

64

58

52

47

43

40

Illinois Nighttime Class A

69

67

62

54

47

41

36

32.

32

CookCountyMltoA

~

72

71

65

57

51

45

39

34

32

The analytical extrapolation to simulate full base load operation ofUnits 1, 2, ‘3 and 4

showed that the Board’s residential noise limits are likely to be exceeded at the Realen property

if the Facility is under full operation.

-20-

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iii. Conclusion of June, 2003 Sound Measurement Survey

When fully operational, the Facility is in compliance with the Board’s applicable noise

limitations when measured at currently existing residential properties. However, the operation of

all the Units is estimated to cause sound pressure levels from the Facility which may exceed the

Board’s Class A regulations if the Realen property is developed for residential use. Ifthe Realen

property was developed industrially as originally zoned, neither that property nor the Facility

would be subject to noise numerical limits that the Facility may not be able to meet at full or

partial operating levels.

b. Acoustical Measurements with Units 1, 2,3 and 4 Operating

by Noise Solutions by Greg Zak September 2003

On September 2, 2003 sound pressure levels were measured for ambient levels and then

for sound pressure levels with all four turbine units fully operational. This field study was

conducted to provide actual sound measurements when the Facility is operating at full load.

These measurements are then compared to the extrapolated sound pressure levels developed as

part ofthe June, 2003 field study.

i. Sound Survey.

The sound measurements were taken at approximately the same

location on the Realen property directly west of Unit 4 as done during the June, 2003

measurement study, and designated as L-R2 on most tables and as R-2 on the aerial map

included in this Petition. By this time ofyear, that areawas bordered with an overgrowth of

thick weeds and brush, harboring a great number ofinsects. Noise from the large number of

insects is believed to account for the significant difference in the ambient measurements at the

4000 and 8000 Hertz octave bands. At the time the measurements were taken, weather

conditions were clear with warm nighttime temperatures, and wind from the east. The ambient

measurements were taken between 9:00 pm and 9:30 pm before startup ofthe units began. The

set of measurements taken with the all four units operating took place between 10:00 pm and

11:17pm.

S

ii. Sound Survey Results.

As the results reported on the table below indicate, the

sound levels measured were generally lower than or very near the numerical limits extrapolated

and reported in the June, 2003 Power Acoustics report.

-21-

---

Measured and Extrapolated Sound Pressure Levels for Facility’s Units 1 through 4

S

Located at L~R2*nearGifford Road and across from Unit 4

Data

,

Source

Description Date

2003

31.5

Hz.

63

Hz.

125

Hz.

250

Hz.

500

Hz.’

1K

Hz.

2K

Hz.

4K

Hz.

8K

Hz.

dB(A)

PAI** Extrapolated

Total

6-20 78.4 71.8 63.5

S

irid md

~

55.0

S

53.2 45.7

31.9

---

PAI**

Ambient

6-17 58.1

59.6 55.2

48.3 46.9

45.9

40.7 33.7 22.1

---

ZAK***

S

Raw 10

minute

Leq

at447MW

9-2

‘

S

73.4

66.5

62.6 57.0 53.0 53.4

55.6

49.2

S

42.4

S

60.1

~

ZAK***

‘

S~

10 minute

Leq

Ambient

9-2 59.2

S

59.6

54.8

~

49~75

S

49.2

~

44.6

S

44.4 48.7 42.3

S

53.7

ZAK***

s

Corrected

10 minute

Leq

at447

MW

9-2

~

73.4

S

65.5

61.9

56.0

S

‘50.7

SS

S

S

52.7

~

55.6

0

0

S

58.8

S

ZAK***

~

Corrected

and rounded

10 minute

Leq

at 447

MW

9-2

73

S

66

62

56

S

5

51

S

53

56

0

0

5

59

,

S

S

IPCB

Daytime

ClassA

---

75

S

74

69 64 58 52

S

S

47 43

~

40

S

---

S

~

Cook

County Ml

toClassA

‘

---

72

S

71

S

65

57

51

45

39

34

S

32

Site Specific

Rule

Requested

---

80 79 74

S

69 63 58 58

S

50 45

.

S

---

Notes:

*

Reference to location on Attachment F

S

**

Power Acoustics, Inc. Report ofJune, 2003

***

Noise Solutions by Greg Zak Report ofSeptember, 2003

S

‘

Rows 2 and 4 contain the data used to compare the ambient levels measured on June 17

and September 2, 2003, respectively. The sound pressure levels recording during both times are

comparable except for those measured at the 4000 and 8000 Hertz octave bands. The differences

at these levels are believed to be due to excessive insect noise on the night ofSeptember 2, 2003.

This same background noise also caused the corrected values at Rows

5

and 6 to be

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indeterminant, and therefore listed as zero on the above chart

-22-

---

Rows 1 and

5

contain the data used to compare the sound pressure levels when the

Facility is fully operational. The extrapolated information at Row 1 represents data premised

upon actual measurements taken when only Unit 4 was operating and projected in the June, 2003

study to include Units 1, 2 and 3 to arrive at an estimated maximum sound level. Row

5

contains

the sound pressure data collected on September 2, 2003, with all four units at the Facilityrunning

at maximum full load. The actual measurement levels at Row

5

are lower than the extrapolated

levels recorded at Row 1. Thus, the sound pressure levels measure during actual full capacity

appear to be lower than levels anticipated~by the extrapolation procedure used in the June, 2003

study.

iii.

Conclusions.

This data must be conservatively interpreted because two sets

of sound pressure level data cannot be considered a complete statistical representation ofsound

from the Facility. Unfortunately, conducting more actual measurements with the Facility fully

operational is not feasible. The variables involved are far too numerous to run a sufficient

number oftests to create such an extensive data base. Second, the Facility is not operated at full

load often enough to conduct a sufficient number ofsound measurements surveys to collect more

statistical data. Therefore, the noise emission limitations requested for this Facility are based

upon a combination of actual measurements at partial and full load, extrapolated information,

and a safety factor of 3 decibels. Ameren is confident that the requested level are achievable at

full level, but also believes that the safety margin is just the minimum necessary to be able to

consistently demonstrate compliance with the proposed site specific limits.

2. Environmental Evaluation of Proposed Site Specific Noise Emission Limitations

To evaluate the environmental impact’ ofthe proposed site specific limits, a comparison was

made to Board’s generally applicable noise limitations. Consulting the table below makes this

analysis easier and simpler. The comparison demonstrates the following:

• At

31.5 Hz, the 80 decibel limitation requested is equal to the current limit from Class C

to Class B receiving lands, found at 35 Ill. Adm. Code 901.103.

• At

63 Hz through 500 Hz, the requested

limitations are equal to the current limits from

Class C to

Class A receiving lands, found at 35 Ill. Adm. Code

901.102(a), and are

considerablybelow theClass C to

Class B receiving lands limits ofSection 901.103.

-23-

---

• At 1000 Hz, the 58 decibel limitation is only 1 decibel higher than the 57 decibel allowed

under the limits for Class C to Class B receiving lands.

• At 2000

Hz,

the 58 decibel limitation, while exceeding the Class C to Class B land use by

6 decibel, does not significantly penetrate’ a house of modern construction when the

windows are closed, which is the likely situation when the Facility is operating during

periods ofvery hot or cold weather.

S

• At 4000 Hz, the 50 decibel limitation, while 2 decibel greater than the Class C to Class B

land use, does not significantly exceed the levels frequently generated by crickets,

locusts, and other insects. Furthermore, at this level, 4000 Hz, the noise is even less able

to penetrate a house with closed windows than at 2000 Hz.

• At 8000 Hz, the 40 decibel limitation is equal to the present Class A daytime limit and

5

decibel lower than Class C to Class B land use limits.

A Comparison of Current

Noise Limits

in Illinois with the Ameren Elgin Facility Site

Specific Noise Emission Limitations

Center

Frequency in

Hertz

(

Class C to Class

Land Section

Proposed Facility Site

Limitations

Class B to Class B

Class C to Class 4

Section 901.102a

31.5 HZ

80dB

80dB

79dB

75dB

63HZ

79 dB

74

dB

78 dB

74 dB

125 HZ

74

dB

69 dB

72 dB

69 dB

250 HZ

69dB

64dB

64dB

64dB

500 HZ

63 dB

58

dB

58

dB

58 dB

1000 HZ

57dB

58dB*

52dB

52dB

2000 HZ

52

dB

58 dB*

46 dB

47 dB

4000 HZ

48

dB

50 dB*

41 dB

‘

43 dB

8000 HZ

45 dB

40 dB

39 dB

40 dB

APPROX. dB(A)

66 dB (A)

64 dB (A)

62 dB (A)

61 dB(A)

The approximate A-weighted (dB(A)) levels are included to provide additional perspective

regarding noise impact. The A-weighted decibel levels are not proposed for adoption because

the Board’s generally applicable noise emission limitations do not include A weighted decibel

limitations.

-24-

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C. Economic Impact of the Proposed Rule

35

Ill. Adm. Code 102.202(b)

The Facility was built at an approximate cost ofover $200,000,000. The energy

producing value ofthe Facility on an annual basis is estimated to be at least $11,200,000. This

value is premised upon four elements: direct sales; reserved capacity dedicated to Ameren; and

outside supply contracts. To the extent that Ameren is. not able to operate the Facility to meet

these energy needs and additional unforeseen power needs, this value is diminished. The

economic consequences to Ameren’s customers if Ameren is not able to fully operate this

Facility has not been determined, but would be ofsignificant consequence to Ameren and its

customers.

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IV. PROCEDURAL MATTERS IN SUPPORT OF PETITION

S

A. Synopsis ofTestimony to be Presented at Hearing

35 Ill. Adm. Code 102.202(c)

Ameren will introduce several individuals to testif~’in support of the facts set forth in this

Petition and the requested relief. Those witnesses will testify and available for question about

the following topics.

S

1. Richard C. Smith, Manager of Generation Services, Ameren Energy Generating

Company, will testify regarding the Facility’s operations; the current noise reduction equipment’

and its costs; the economic impact of the proposed site specific regulations; and the tecimical

feasibility and estimated costs for add-on controls for noise reduction.

S

2. David J. Parzych, principal and founder ofPower Acoustics, Inc., will testify

concerning the design phase study conducted by Power Acoustics, Inc. for the Facility in 2000.

He will also testify about the sound measurements obtained from the survey conducted in June

2003, the extrapolation ofthat data to evaluate the impact ofthe Facility on the Realen property,

and in the context ofthe proposed site specific noise emission limitations. He will also testify

about the sound pressure levels associated with peaker power plants, the technical feasibility and

economic reasonablenessofthe existing and studied add-on control noise reduction methods,

and the proposed site specific limitations.

S

S

3. Gregory Zak, ofNoise Solutions by Greg Zak, will testify regarding the sound

pressure levels measured in the September, 2003 investigation; the development ofthe site

S

-25-

---

specific noise emission limitations; and the environmental impacts ofthe proposed site specific

limitations.

S

S

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B. Statement of Most Recent Version of Rule

35111. Adm. Code 102.200(h)

The rules proposed in this Petition do not amend any existing Board rule, but instead,

request that the Board adopt a site specific noise emission regulation applicable to the Ameren

Elgin power plant. Therefore, a statement or certification that the proposal amends the most

recent version ofthe rules as published on the Board’s web site is not necessary.

S

Ameren recognizes that portions ofPart 901 ofthe Board’s noise regulations are the

currently the subject ofa Board rulemaking entitled In the Matter of: Proposed New and

Updated Rules for Measurement and Numerical Sound Emissions Standards Amendments to 35

Ill. Adm. Code 901 and 902, R03-9. To the best ofAmeren’s knowledge, that rulemaking is

currently in First Notice under the Administrative Procedure Act The Board’s consideration and

adoption ofthis proposed site specific regulation should not affect the Board’s existing noise

regulations or the proposed amendments to the same that are the subject of that Board

rulemaking.

S

S

S

C. Consistency with Federal Law

S

There are no federal limitations on noise from this type ofpowerplant Therefore, such a

demonstration is not applicable to this site specific rulemaking

D. Attachments to Petition

S

S

The following attachments are included by Amereii in support ofthe site specific noise

S

emission limitation proposed, and are hereby made a part ofthis Petition

1 Attachments Al and A2 Map of Existing Land Uses (Two views)

2. Attachment-B: Diagram of Elgin Facility Layout Plan

S

S

3. Attachment C: Simple Cycle Combustion Turbine Power Plant

S

4. Attachment D: Diagram ofElgin Facility Noise Control Devices

5

Attachment E Estimated Costs of Noise Abatement Measures

6 Attachment F Map ofAmbient Sound Measurement Locations and Cntical

Receptors

-26-

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E. Petition Signature Requirement

45

ILCS 5/28 and 35 Ill. Adm. Code 102.202(f).

5

In a separate Motion filed simultaneously with this Petition, Ameren respectfully requests

that the Board waive the signature requirement applicable to site specific rulemaking petitions

WHEREFORE, Ameren respectfully request that the Board promulgate a site specific

rulemaking limiting noise emission limits from the Ameren power generation plant on Gifford

Road in Elgin, Illinois for Class A and Class B receiving lands as proposed and supported by this

Petition.

S

S

Respectfully submitted,

S

S

Ameren Energy Generating Company,

Petitioner,

By

_______________

S

Marili McFawn

S

S

Dated: October28, 2003

5

5

5

1

•SS

Marili McFawn

S

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SchiffHardin & Waite

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6600 Sears Tower

Chicago, Illinois 60606

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312-258-5519

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CH2\ 046314.!

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-27-

5

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Existing Land Use

Map Legenø

LIII

Elgin

Municipal

Boundary

Single Family Detached

Single FamilyAttached

Multiple Family 2-S Unite

fl

Multiple Family 6-10 Unita

fl

Multiple Family 11 + Unite

Strip Shopping Center

Corridor Retail

Corridor Service

Major Shopping Center

Office

Warehouee/Oietributinn

~

Light Induntrial

~

Heavy Induetrial

Church/Religioun Facility

~

Educational

Open Space

~

Parka & Recreation

Inatitutional

Don ernment Bu/dinga

Vacant Land

Agricultural

Railroad/Utility

Water

eea

0

eno

City of Elgin

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ATTACHMENT Al

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Frucon Cons

Existing Land Use

Map Legend

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Elgin

Municipal

f3orinthry

Sm~~gleFamily Detached

Single Family Attached

Multiple Family 2-5 Units

Multiple Family ~.i i~Units

Multiple Famrry 11+ Units

Strip Shopping

Center

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Corridor Retail

Corridor

Service

Mayor Shopping Center

Office

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Vacant land

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Railroad/Utility

Water

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0

400

600

Feet

ATTACHMENT A2

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DIAGRAM OF ELGIN FACILITY LAYOUT

1~700 s.F.

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ATTACHMENT B

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SIMPLE CYCLE COMBUSTION TURBINE

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DIAGRAM OF ELGIN FACILITY

ATTACHMENT D

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ESTIMATED COSTS OF NOISE ABATEMENT MEASURES

Material

Labor

Sub-total

$500,000

$500,000

$1,000,000

$1,500,000

$1,500,000

$3,000,b00

$500,000

$500,000

$1,000,000

$50,000

$50,000

$100,000

$100,000

$100,000

$200,000

$100,000

$100,000

$200,000

$300,000

—

$300,000

$600,000

..

Additional Exhaust

.

Stack Silencers

.

(Low Frequency

Noise Reduction)

(31.5-63 Hz)

.

New Redesigned

Stack

(Low Frequency

Noise Reduction)

(31.5-63 Hz)

I

.

.

Active Noise

Control System

(Low Frequency

Noise Reduction)

(31.5-63

Hz)

..

Additional Inlet

.

Silencers

.

(High Frequency

Noise Reduction)

(1000-8000 Hz)

..

Additional Inlet

.

Ducting

Enclosure

.

(High Frequency

NoIse Reduction)

z)

Secondary

Generator

Enclosure

.

(Mid Frequency

Noise Reduction)

(

-

z)

Barrier Wall on

.

the West Side of

.

Each Unit

.

(Mid and High

Frequency Noise

Reduction)

125-8000 H

(5)

$150,000

$50,000

$5,000

$10,000

$10,000

$30,000

Management (10)

$100,000

$300,000

$100,000

$10,000

$20,000

$20,000

$60,000

AFUDC(10)

$100,000

$300,000

$100,000

$10,000

$20,000

$20,000

$60,000

(6)

$198,000

$66,000

$6,600

$13,200

$13,200

$39,600

(15)

$150,000

Sub-total

$466,000

Per Unit

$1,466,000

ALL 4 UNITS

$6,000,000

$450,000

$1,398,000

$150,000

$15,0O~

$30,000

$30,000

$90,000

$466,000

$46,600

$93,200

$93,200

$279,600

$4,398,000

$1,466,000

$146,600

$293,200

$293,200

$879,600

$18,000,000

$6,000,000

-$600,000

$1,200,000

$1,200,000

ATTACHMENT E

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MAP OF AMBIENT SOUND MEASUREMENT LOCATIONS

1.

Patio and Ponds Landscaping on Spaulding Road

2.

Single Home, Spaulding Road

3.

Amber Grove Subdivision, Spaulding Road

4.

Spring Lakes Mobile Homes, James Street

5.

Westridge Subdivision, Rushmore Drive

6.

Nature Ridge School and Westridge Subdivision, West Bartlett Road and Westridge

Boulevard

The Realen property to the west of the site is currently vacant and undeveloped. The Sound

Measurement Locations on this property are: Ri, R2, R3, R4 and R5.

ATTACHMENT F

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BEFORE

THE ILLINOIS POLLUTION CONTROL

BOARD

IN THE MATTER OF:

)5

I

)

PROPOSED SITE SPECIFIC REGULATION

)

R04-

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APPLICABLE

TO

AMEREN ENERGY

5)

GENERATING COMPANY, ELGIN, ILLiNOIS

).

AMENDiNG

35 Ill. Adm. Code 901

)

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S

APPEARANCE

S

S

S

Now comes Marili McFawn ofthe law firm

of SchiffHardin & Waite and hereby enters

her appearance on behalf ofPetitioner, Ameren Energy Generating Company, in this proceeding.

Respectfully submitted,

S

S

MariliMcFawn

S

S

S

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Attorney for Ameren Energy

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Generating Company

Dated &t

.I~e~vi

Q2

r

10C3

Marili McFawn

~S

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SchiffHardin & Waite

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6600 Sears Tower

S

S

Chicago, Illinois 60606

5

5

312-258-5519

5

5

5

Ci-12\ 1047936.1

5

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---

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARD

iN THE MATTER OF:

)

S

S

S

)

5

PROPOSED SITE SPECIFIC REGULATION

).

R04-

S

APPLICABLE

TO

AMEREN ENERGY

-)

GENERATING COMPANY, ELGIN,

ILLINOIS

)

S

AMENDING

35

Iii. Adm. Code 901.

)

~S

MOTION TO

WAIVE REQUIREMENT

TO

SUBMITT 200 SIGNATURES

Now

comes

Ameren Energy

Generating Company, by

and through

its attorneys, Schiff

Hardin & Waite and requests that the Illinois Pollution Control Board (“Board”) waive

the

S

requirement under 35 Ill. Admin. Code 102.202(f) to submit 200 signatures with its Petition

for

Site Specific Regulation. In support hereof, Petitioner states:

1. Ameren Energy Generating Company owns a power generation facility in Elgin,

Illinois for which it seeks site specific regulations for noise emission limitations from that Class

C land to Class A and Class B receiving properties

as governed under 35 III. Adm. Code Part

901.

5

5

2 The Board has waived signature requirements for site specific

rulemaking petitions in

the past, including recently In the matter of Petition of Central Illinois Light Company for a Site

Specific Air Rule 35 Ill Adm Code 214 141 R02-21, and In the Matter of Petition ofthe

City of Effingham, Blue Beacon International Inc. and Truckomat Corporation fOr a Site Specific

for a Site Specific Water Pollution Regulation: 35 Ill. Admin. Code 304.105, R03-l 1.

3. Ameren Energy Generating Company is a publicly held company that employs 2,530

and provides electrical power to one million customers in the State ofIllinois. Granting this

motion is in the public interest ofthose customers and others servedby Ameren Energy

Generating Company.

S

S

S

Wherefore, Ameren Energy Generating Companythrough its attorneys respectfully

requests that the Board waive the requirement to submit 200 signatures in support ofthis Petition

fOr site specific regulation.

S

S

S

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Dated: October 28, 2003

Marili McFawn

SchiffHardin & Waite

6600 Sears Tower

Chicago, Illinois 60606

312-258-5519

CH2\

1047699.1

Respectfully submitted,

Ameren Energy Generating Company

By:

Marili McFawn

---

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARD

IN THE MATTER OF:

S

PROPOSED SITE SPECIFIC REGULATION

APPLICABLE

TO

AMEREN

ENERGY

S

GENERATING COMPANY, ELGIN, ILLiNOIS

AMENDING

35

III. Adm. Code 901

)

)

R04-

)

)‘

)

CERTIFICATE OF SERVICE

S

I, Marili McFawn, the undersigned, hereby certify that

I have served the attached Petition

for a Site Specific Regulation Applicable to Ameren Energy Generating Company, the Entry

Of Appearance of

Marili

McFawn in this matter on behalf of Ameren Energy Generating

Company, a Motion for Expedited Consideration, and a Motion to Waive Requirement to Submit

a 200 Signatures by filing the same in person with the Clerk of the Illinois Pollution Control

Board, 100 W. Randolph, Suite 11-500, Chicago, Illinois 60601 on October 28, 2003

and

on

those listed below by depositing said documents in U.S Mail on October 28, 2003:

Division Chief ofEnvironmental Enforcements

Office of Attorney General

S

100 West Randolph Street,

12th

Floor

Chicago, Illinois 60601

Division of Legal Counsel

Illinois Environmental Protection Agency

1021 North

Grand Avenue East

Post Office Box 19276

Springfield, Illinois 62794-9276

Office of Legal Services

Chief, Legal Division

Illinois Department ofNatural Resources

524

South Second Street

Springfield, Illinois 62701

~)14~L~

Marili McFawn

~

Attorney for Ameren Energy

Generating Company

CF12\

1047942.1