1. NOTICE OF FILING
      2. SERVICE LIST
      3. MOTION FOR EXTENTION OF TIME
      4. AMEREN ENERGY GENERATING COMPANY
      5. IN SUPPORT OFAMEREN SITE SPECIFIC NOISE RULE
      6. PRE-FILED TESTIMONY OF GREG ZAK,of NOISE SOLUTIONS BY GREG ZAK
      7. AMEREN SITE SPECIFIC RULE
      8. TESTIMONY OF GREG ZAK
      9. TABLE 1
      10. ACROSS FROM UNIT 4
      11. II. ILLINOIS STATUTES AND REGULATIONS
      12. III. MEASUREMENTS
      13. 1. Measurement Procedures
    1. IV. RESULTS AND DISCUSSION
    2. V. CONCLUSIONS AND RECOMMENDATIONS
    3. Noise Solutions by Greg Zak Noise Report
      1. TABLE 1
      2. Leg_at 447 MW
      3. Site Specific Rule
  1. ATTACHMENT A
  2. ATTACHMENT- B
      1. Greg Zak, INCE
      2. EXPERIENCE
      3. IEPA Noise Advisor 14+ years
      4. -Pollution Control Board (ENFORCEMENT)
      5. INTERGOVERNMENTAL PROJECTS
      6. IEPA Noise Regional Manager 3 years

CLERK’S
OFF~CE
BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
DEC
4
20U3
TN THE MATTER OF:
STATE OF ILUNOIS
Pollution
Control Board
PROPOSED SITE
SPECIFIC REGULATION
)
APPLICABLE TO AMEREN ENERGY
)
R04-1
1
GENERATING COMPANY, ELGIN, ILLINOIS,
)
AMENDING
35
ILL. ADM. CODE 901
)
NOTICE
OF FILING
TO:
See attached Service List
Please take notice that today I have filed with the
Clerk of the Illinois Pollution Control
Board the following documents on behalf of the Petitioner
in this matter, in accordance with
35
Ill.
Adm. Code
102.424 in anticipation ofthe hearing in this
matter:
1.
Pre-Filed
Testimony
of
Richard
C.
Smith
of
Ameren
Energy
Generating
Company
2.
Pre-Filed Testimony ofDavid J. Parzych ofPower Acoustics, Inc.
3.
Pre-Filed
Testimony
of
Greg
Zak
of Noise
Solutions
by
Greg
Zak;
and
the
following documents to
be submitted as exhibits at hearing.
4.
Power
Acoustics,
Inc.:
Compilation
of Sound Assessment
Studies
and
Reports,
and Resume ofDavid Parzych
5.
Noise
Solutions
by
Greg
Zak:
Sound
Assessment
Report
for
Ameren
Elgin
Facility dated November
1, 2003
6.
Resume ofGreg Zak
Also filed today
is Motion for an
Extension
of Time directed to
the Hearing Officer in
this matter, along with a
Certificate of Service
,
a copy of which
is
attached and
hereby served
upon you.
Respectfully submitted,
Marili McFawn
SchiffHardin &
Waite
6600 Sears Tower
Dated:
December 3, 2003
Chicago, Illinois
60606
312-258-5519
Cl-2\
1060935.1

CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served documents described in the attached Motion
ofFiling, by depositing these documents with Federal Express on
December 3, 2003
for service
upon the Clerk ofthe Pollution Control Board
and Hearing Officer John Knittle.
The remainder
of those on the
Service List were served by depositing these documents in regular U.S.
mail
on
December 3, 2003.
~
Marili McFawn
CH2\ 1060957.1

SERVICE LIST
Ms. Dorothy Guim
Clerk of the Pollution Control Board
James R. Thompson Center
100 West Randolph
Suite
11-500
Chicago, Illinois 60601
Mr. John Knittle, Esq.
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Springfield, Illinois
62794
Office ofLegal Services
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Mr. Scott Phillips, Esq.
Illinois Environmental Protection Agency
Division ofLegal Counsel
1021
North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
Realen Homes
Attn.:
Al Erickson
1628 Colonial Parkway
Inverness, Illinois 60047
Mr. Joel Sternstein
Assistant Attorney General
Environmental Bureau
188 West Randolph St.,
20t~1
Floor
Chicago, Illinois
60601
Village ofBartlett
Attn.:
Bryan Mraz,
Attorney
228
South Main Street
Bartlett, Illinois 60103
CH2\ 1060953.1

RECEIVED
CLERK’S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC
4
2003
IN THE MATTER OF:
STATE OF ILLINOIS
Pollution
Control Board
PROPOSED
SITE SPECIFIC REGULATION
)
APPLICABLE TO AMEREN ENERGY
)
R04-1
1
GENERATING COMPANY, ELGIN, ILLINOIS,
)
AMENDING
35
ILL. ADM. CODE 901
)
MOTION FOR EXTENTION OF TIME
Petitioner moves the hearing officer in this matter to
grant Petitioner an
extension oftime
to file the Pre-Filed Testimony and Exhibits intended to be introduced at the hearing now
scheduled in this matter.
These documents were
served on the Clerk ofthe Board and those
persons on the Service List in
this matter on December 3, 2003.
Pursuant to the hearing officer’s order in this matter, these documents were to be filed
November 26, 2003.
That hearing officer order was dated November
17, 2003, but received by
Petitioner’s counsel on or after November 21, 2003.
Until
that time,
Petitioner’s counsel
believed that the filing date was set for December 3, 2003, based upon a telephone conversation
with the hearing officer on November
13, 2003.
Upon receipt ofthe Hearing Officer’s order,
counsel informed the Hearing Officer ofthe difficulty involved in meeting a November 26, 2003
filing date.
Pursuant to
Section
102.424 ofthe Board’s Procedural Rules, the Board’s hearing officer
may extend the date for filing these documents to
prevent material prejudice orundue delay.
Acceptance ofthis filing
at this time will serve for a more efficient hearing, and will not
materially prejudice any participant.
Accordingly, Petitioner respectfully request that the
Hearing Officer grant this motion as allowed under Section
101.522 and 102.242 ofthe Board’s
Procedural Rules.
Respectfully submitted,
Marili McFawn
SchiffHardin & Waite
6600
Sears Tower
Dated:
December 3, 2003
Chicago, Illinois
60606
312-258-5519
CH2\
1060950.1

CLERK’S
OFFICE
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
DEC
4
2003
STATE OF ILLINc~IS
IN THE MATTER OF:
Pollution
ControlBoard
PROPOSED SITE SPECIFIC REGULATION
)
APPLICABLE TO AMEREN ENERGY
)
R04-1
1
GENERATING COMPANY, ELGIN, ILLINOIS,
)
AMENDiNG 35
ILL. ADM. CODE
901
)
PRE-FILEDTESTIMONY OF
RICHARD
C. SMITH
OF
AMEREN ENERGY GENERATING COMPANY
Good Morning.
I am Richard C.
Smith.
I am the Manager ofGeneration
Services
at Ameren Energy Generating
Company.
I am responsible for project management,
engineering, outage planning,
safety, training, laboratory
services, and operation
and
maintenance ofAEG’s combustion turbine fleet as well as two cogeneration facilities.
I
possess bachelor’s and master’s degrees in
mechanical engineering and
am a Fellow of
the American
Society ofMechanical Engineers.
I am a licensed Professional
Engineer in
the States ofIllinois and Missouri.
I was responsible for leading the development of the Ameren Elgin
Energy Center
project
and was responsible for the construction and commissioning ofthe Facility.
In
my current position, I am responsible for operation and maintenance.
The Elgin Energy Center site location was selected because of the fact that the
property was in an industrial
setting that contained appropriate, compatible
land uses and
access
to ComEd’s
Spaulding Road substation.
Natural gas fuel supply would be
available through a proposed pipeline being developed by a joint venture between Nicor
and Natural Gas Pipeline Company ofAmerica.
Additionally, access to railroad
tracks
was in
close proximity
for transportation and delivery ofheavy equipment associated
with the combustion turbines.
When the Facility was still
in the design phase, Ameren considered the possible
noise effect on
the surrounding community.
For that reason, Anieren worked extensively
with the equipment supplier, Siemens Westinghouse, and engaged Mr. Dave Parzych of
Power Acoustics,
Inc. to
survey ambient noise sources at critical nearby receptor

locations which included existing residential locations and a commercial operation, and
to
perform an acoustical model analysis to
estimate the noise that may result from
operation ofthe four gas turbine unit facility.
Mr. Parzych will testify that a computer
noise model ofthe proposed Elgin facility, after taking into account the proposed noise
abatement controls now in place at this Facility,
estimated the sound pressure level to be
at or below the Board’s noise regulations at all then-existing residential receptors.
So,
even before the Facility was built, Ameren was diligent in its
efforts to comply with
applicable noise limitations. In addition, a robust public information program was
conducted in
order to inform local government
and residents ofAmeren’s intentions
which included information pertaining to
plant design.
Since that time, the character and the nature ofthe area has changed little.
The
area is heavily industrial.
As you
can see
on Attachment 2
to our Petition, the Facility is
located in
an industrial park and is surrounded by industrial
uses.
To
the immediate north
is the GE Capital Module Space,
an outside storage yard of temporary office trailers.
Immediately east ofthe Facility is a BFI Waste Systems facility.
Just further east is
Commonwealth Edison’s high powered transmission line corridor and an active railroad.
Also nearby to the
south
is the U.S. Can Company, a manufacturing facility.
To
the
immediate west is currently vacant property owned by Realen Homes, which at the time
of the Facility’s construction was intended for use as a balefill operation by the Solid
Waste Agency ofNorthern Cook Cpunty (known as “SWANCC”).
Just north of this area
is Bluff CityMaterials, a quarry and mining operation.
At the time the Facility was constructed and still today, the predominant industrial
character ofthe area results in heavy truck traffic
and other 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.
During the sound surveys conducted by
Power Acoustics, Inc.
and Noise Solutions by Greg Zak, both monitored
significant noise
from these operations,
as well as from overhead air, traffic
and train noise.
The nature and character of the area has not
changed over the
years, and to our
knowledge, there have been no complaints
about noise from our power generation
facility.
When we learned that the unincorporated, vacated property across Gifford Road

from the facility was proposed for residential development, we engaged Dave Parzych of
Power Acoustics, Inc.
and shortly thereafter, Noise Solutions by Greg Zak to
update our
information about noise in the area and that generated by our Facility.
Both gentlemen
will testify about their investigations and recommendations which are the basis of
Ameren’s request forthe site specific noise limitations proposed in this Petition.
I hope that I have adequately informed you about the industrial nature and
character ofthe area where our Facility is located
and the
steps we took to
construct it to
minimize
any noise impact on that area.
I am also appearing here todayto answer
questions
you may have about our power generation facility in Elgin
and other questions
relevant to Ameren’s operations of this Facility.
I will also testify regarding the
operation ofthe Facility, the noise abatement control in place at the Facility, and the
potential costs of additional noise abatement control.
The Elgin Energy Center consists of four Siemens Westinghouse W5O1D5A
combustion turbines.
Each unit is capable of a rated maximum output of 135MW of
electric power generation.
At this point, you may want to refer to Attachment C of our
Petition filed October
28th
That Attachment is entitled “Simple Cycle Combustion
Turbine.”
Air, taken
in through the inlet filter and silencer, is compressed and
combined
with natural gas.
The air-fuel mixture is combusted and the hot gasses are expanded
through a multi-stage turbine to
produce shaft
rotation/torque.
The turbine shaft is
directly connected to a generator which is used to generate electric power.
Exhaust
gasses exit the system through
the exhaust silencers and stack.
As described in our Petition, the Facility is equipped with several different kinds
ofnoise abatement systems.
The turbine ofeach unit is enclosed and
equipped with
enclosure ventilation silencing.
Because the majority of the noise emitted
comes first
from the opening needed to get air into the turbine’s compressor, the inlet,
and then from
the opening needed
to get the combustion exhaust gasses
out ofthe turbine, both are
equipped with noise abatement controls.
The air intake for each turbine
is enclosed, and
intake is equipped with inlet silencer baffles.
This is combined with extensive
duct

structural stiffening and lagging as secondary noise attenuation to further reduce sound
radiating from the air intake system.
The noise abatement equipment at the exhaust outlet is state ofthe art.
The
silencer panels were designed 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.
They are extra thick and longer than those used as comparable facilities,
in fact so long that a special horizontal section of silencer panels approximately 35
feet in
length and supported on the ground was used to accommodate the massive exhaust
silencer.
The traditional 50 foot high vertical exhaust stack was also used to provide an
additional
15 feet of silencers.
Finally,
to keep sound from radiating from the exhaust
ducting surfaces, an extra, secondary enclosure system was provided, which is
acoustically insulated
with
V4
inch ormore steel plate.
As Mr. Parzych, who was retained
by Ameren during the design phase ofthis Facility to assess potential noise
from this
Facility, will testify further on the unique control characteristics ofthe noise control
system for the exhaust outlet.
As explained in our Petition,
and as I mentioned early, with the help ofPower
Acoustics,
Inc., during the design phase Ameren
evaluated the possible impact ofnoise
from the planned facility on the area to
determine the necessity and value ofequipping
the planned facility with nOise abatement
equipment beyond that standard to the industry.
Based on Mr. Parzych’s study,
Ameren determined that, as planned, the facility could
comply with the Board’s noise limitations at then existing residential areas.
Accordingly,
Atheren installed the state ofthe art exhaust silencing system and all the other noise
abatement controlsjust described.
The estimated cost for the noise abatement measures
for all four units was a total of$l 1,650,000.
More recently, Ameren again retained Mr. Parzych to study whether the Facility
would be able to
comply with the newly proposed residential areajust west and
across
the road from the Elgin Facility.
Mr. Parzych will testify that based upon actual
measurements in the field, he
determined that the Facility does comply with the Board’s
noise regulations at pre-existing residential areas, but may not 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.
For that reason, Ameren investigated the

technical
feasibility and costs of installing additional noise
control equipment at the
Facility.
While we investigated several approaches, prior to proceeding with any particular
abatement measure, a detailed sound
study would be required to
determine first the type
of noise that must be reduced, and then whether the proposed measure would sufficiently
abate the noise to meet the Board noise emission limitation.
Sound testing would
have to
be~
conducted to
determine the octave band sound power levels ofeach sound source, i.e.,
the gas turbine, inlet system, exhaust system, generator, transformers, or coolers.
Such a
study would
then have to evaluate the effectiveness of the various sound source
treatments, including more inlet system silencing,
generator sound treatments beyond the
current enclosure, barrier walls, and exhaust sound
systems beyond the ~tateofthe art
system already provided.
The estimated cost for such a study
is $25,000.
This cost
estimate does not include the cost ofoperating the Facility for the purpose ofrecording
noise measurements of the various plant components.
Based upon Mr. Parzych’s and our past experience, we have examined the
feasibility and the cost of seven additional noise abatement measures.
However, before
explaining the derivation of the cost estimates provided on the Table of Estimated Costs
ofN
ise Abatement Measures, Attachment E to our Petition, I would like to make some
general
clarifications.
The estimates are order of magnitude in
the range of -25
to
+75,
which ought to be interpreted that real costs would likely fall within this range
around the figures presented
in Attachment E to the Petition.
Again, to establish
a more
accurate estimate requires a detailed sound study of the Elgin Facility that I just
described.
Also, some ofthe noise abatement measures have not been proven in
the
power industry and would require extensive research and testing
(e.g.,
a new redesigned
stack, or an active noise control system).
The cost estimate for each option is broken down into material, labor,
engineering, project management, AFUDC (construction interest), overhead and
contingency costs.
These are the major cost categories of a typical project and are used
to
develop cost estimates for Ameren projects.
The material costs were obtained from

Dave Parzych based upon his experience with the Ameren facility and other comparable
power generation facilities.
These estimates are based in part on industry rule ofthumb
pricing.
The labor costs are based on actual Elgin facility installation costs plus
uncertainty which is within the order ofmagnitude range.
The engineering, project
management, AFUDC, overhead and contingency percentages are based on typical
project cost percentages.
I
will
address
in
order
from
right
to
left
each
of the
seven
alternatives
listed
on
Attachment
E:
Estimated
Costs
of Noise Abatement
Measures.
First
considered
is
the
installation ofadditional exhaust stack silencers for low, frequency noise reduction
(31.5
63
Hz).
Installing additional exhaust stack silencers will most likely not provide the required
low
frequency noise
reduction.
The
Facility
is
already
equipped
with
state
of the
art
control
measures
for this type
of noise.
Approximately forty feet of additional
exhaust
stack
with
silencers may be
required to
achieve
additional
reductions
in
low
frequency noise than
that
currently provided.
Because ofthe large amount ofnoise reduction that would be required to
comply with
the Board’s residential standards,
the likely success of this type of treatment
is
small.
Even
then, the
estimated cost
is
$6,000,000.
Also,
installation of such
equipment
would require approval and an ordinance from the
City of Elgin,
which would
be difficult to
obtain. The additional
stack would impair performance ofthe units by increasing backpressure
on
the
turbines,
which
would
degrade
efficiency
and
power
output,
which
would
then
adversely impact economic value ofthe Facility.
The
second approach investigated to reducing low
frequency noise reduction, 31.5-63
Hz, was
installing
a
new, redesigned
stack:
A
new
stack
would
require full
aerodynamic
modeling,
i.e.,
a physical scale model
to assure nearly“perfect” system aerodynamics
,
as well
as significant analytical
work to
insure that the
exhaust
system
would
achieve the necessary
criteria to
reduce low frequency noise beyond
that already achieved by the
equipment at the
Facility.
According to Mr. Parzych, there are no gas turbine exhaust stacks
currently available
in the United States that meets the necessary design criteria.
The
estimated cost for this R&D
approach
is
$18,000,000.
It
is
our judgment
that
this
option
would
also
degrade
unit
performance and economic value ofthe Facility.

The third alternative investigated was the installation of an active noise control system
for low frequency noise reduction, again sound in the 31.5
to
63
Hz octave bands.
This type
of technology
has been developed
under
a NASA
contract, but
it has not
been used
in
the
power
industry.
Such
an
active
noise
control
system
would
be
expected
to
work
in
conjunction with the existing passive silencing for low frequencynoise reductions.
Because it
would
be
experimental to
the power industry and at our Facility, the engineering team ~who
developed the system under contract for NASA would be have to first evaluate the feasibility
ofsuch a system for application to this Facility’s exhaust systems.
The
cost for this approach
is estimated at $6,000,000, and we associate a very low probability ofsuccess.
For additional reduction ofhigh frequencynoise, that is sound within the
1000 to 8000
Hz
octave
bands, the
installation of additional
inlet
silencers was
considered.
A
relatively
short section ofinlet silencing mayprovide noise reduction, only ifthe inlet system is found to
be a significant sound source at the higher frequencies.
However, the feasibility ofthis type of
noise
reduction
and
its
impact
on
the
Facility’s
operations
would
have
to
be
further
investigated.
The estimated cost is $600,000.
Our judgment is that this approach would have
little positive effect on the overall sound emissions from- the site.
Again, this approach would
degrade unit
performance
by
increase pressure drop through
the
inlets
and
would
therefore
negatively impact economicvalue of the Facility.
Also considered for reducing high frequency noise reduction,
the same range of 1000
to
8000
Hz, was
the
installation of an
additional
ducting
enclosure.
If the
inlet
ducting
is
found to
be
a significant
source
at the higher frequencies,
a secondary enclosure around
the
inlet ducting mayprovide noise reduction.
The estimated cost for this approach is $1,200,000.
Again, ourjudgment
is that this approach would
have little positive effect on the overall sound
emissions
from the
site.For mid
frequency noise,
that
is
sound
at
the
125
to500
Hz range,
installing a secondary enclosure around
the generator was evaluated.
However, to obtain the
full
effects
of such
an
enclosure,
additional
silencing
may
be
required
in
the
ventilation
ducting.
The estimated cost is $1,200,000.
Again,
ourjudgment
is that
this approach would
have little positive effect on the overall
sound emissions from
the
site.
This
approach would
be unique to the power industry for this type of Facility, and would require extra engineering
to avoid adverse operational impacts upon the existing generator enclosures.

Finally, to
reduce further mid and high frequency noise reduction at the
125
to
8000
Hz range, the cost of installing a barrier wall on thewest side ofeach unit was estimated.
The
costs factors
included
$35
per square foot,
and a wall
35
feet tall and
250 feet long.
While
installation ofa barrierwall maybe somewhat effective in reducing the midto high frequency
sound, its potential effectiveness would depend on the results of a detailed measurement and
analytical study.
The estimated cost is $3,600,000, and such barrierwalls would not be useful
in reducing emissions oflow frequency sound.
This Facility is already equipped with significant noise control equipment—probably
more
equipment
than used
at
other
combustion
turbine
sites
or
at
any
other
type of noise
source.
Since it is already controlled, and in large partbeyond the levels normally achieved at
peaker power plants, successfully reducing noise further is probably technically infeasible or
may
achieved
subject only to
much
R&D or through
a process of trial
and
error.
The
cost
estimates may appear high, but the actual costs might be much greater due to the experimental
nature of many of the approaches.
When compared
to the environmental
impact of the noise
in this
area,
and the high. levels of extraneous and
ambient noise levels due
to the industrial
activities in the area, Ameren believes that the costs are not economically reasonable.
Thank
you for the opportunity to
testify today,
arid I would
be pleased to
answer any
questions that the Board or its staff mayhave after our two expert witnesses have testified.
*
*
*
*
Petitioner, Ameren Energy Generating Company,
reserves the right to supplement or
modify this pre-filed testimony.
Respectfully submitted,
Ameren Energy Generating Company
/
/T~_~~
/~
.
By:
Marili
McFawn

Dated:
December 3, 2003
Marili McFawn
SchiffHardin & Waite
6600 Sears Tower
Chicago, Illinois
60606
312-258-5519
CH2\
1060367.2

RECE.~VED
BEFORE
THE ILLINOIS POLLUTION CONTROL BOARD
DEC
4
20O~
IN THE MATTER OF:
-
STATE
OF ILLINOIS
o
utlon
Control Board
PROPOSED SITE
SPECIFIC REGULATION
)
R04-l
1
APPLICABLE TO AMEREN ENERGY
)
GENERATiNG COMPANY, ELGIN, ILLINOIS,
)
AMENDiNG 35 ILL. ADM. CODE 901
)
PRE-FILED TESTIMONY OF
DAVID J. PARZYCH, P.E., INCE. Bd. Cert.
OF POWER ACOUSTICS, INC.
IN SUPPORT
OF
AMEREN SITE
SPECIFIC NOISE RULE
Ameren Energy Generating Company
(“Ameren”),
by and
through
its
attorneys, Schiff
Hardin
&
Waite, and
pursuant
to
35. Ill.
Adm.
Code
102.424,
submits
the
following Pre-Filed
Testimony
of
David
J.
Parzych
of
Power
Acoustics,
Inc.
for
presentation
at
the
hearing
scheduled for December
17, 2003
in
this matter relating
to
the request for a
site specific
sound
regulation for the Ameren Elgin
Facility located at 1559 Gifford Road in
Elgin, ‘Illinois.
TESTIMONY OF DAVID J. PARZYCH, RE., INCE
Bd.
Cert.
As
principal
and
founder of Power
Acoustics,
Inc.,
my
career
in
acoustics
and
noise
control
engineering spans
more than
21
years.
Early
in
my
career,
my
acoustical
disciplines
ranged’ from
nuclear
submarines
to
commuter
airplanes.
Over the past
11
years,
however,
my
work has been focused
on power generation facilities
with
gas turbines, or combustion
turbines
as my primary interest.
My résumé is included in
the exhibit containing my written reports.
My testimony today will explain three noise
studies
involving the Ameren
Elgin Facility:
the
first
done
in
2000
and
predating
the
design
and
construction
of the
Facility;
the
second
measuring
sound pressure levels
from
the existing
Facility at existing
residential
areas
and
the
Realen
property; and
the third study to
estimate the
sound pressure levels at locations
at various
locations at the Realen property.
Ameren
also requested that
I assess
the
level of noise
control
equipnient
currently
at
the
Facility,
and
whether
additional
noise
control
measures
are

2
‘—
December 3,
2003
economically
or
techmcally
feasible
to
achieve
compliance
with
existing
residential
noise
emission
limitations
at
the
Realen
property
Finally,
I
will
address
how
the
requested
site
specific
sound
limitations
for
the
Ameren
Facility
were
developed
using
the
information
collected
by
myself and Greg Zak of Noise
Solutions
by
Greg
Zake
in
conjunction
with our
combined expertise in the field ofnoise-and its
control.
I have been involved
with
the acoustics of the Ameren Elgin’ Facility from
the time
the
Facility was in
its
conceptual stages
in
the
Fall of the year 2000
through
the present.
In
the
project’s conceptual stage, Power Acoustics,
Inc.
undertook the task of estimating the impact of
operating
four simple
cycle
Siemens-Westinghouse
501D5A gas
turbines at the Ameren
Elgin
site.
A PowerAcoustics,
Inc. report,
“Acoustical Evaluation and Ambient Sound Survey ofthe Amer~n
Simple Cycle Power Facility Proposed to be Built in Elgin, Illinois”,
was generated in November 2000
summarizing the ‘results of the
study.
My tasks
at the conceptual stage included measuring the
ambient
sound a~nearby
existing
residential
and
commercial
areas
and
estimating
the
sound
produced by
the
proposed Ameren Elgin
Facility
The
impact analysis
showed the
proposed
Ameren
Elgin
Facility,
containing
state-of-the-art
noise
control
features,
would
achieve
the
Illinois State Noise Regulations forthe zoning and property uses that existed at that time
My
most
recent
work
relating
to
this
Facility
started
in
June of 2003
and
continues
through the development of a new site-specific noise emission limitation for the Ameren Elgin
Facility.
Initially,
Ameren requested that I measure the
sound with
the Facility operational and
determine if the Facility met the noise requirements
at the nearby residential areas as projected in
the
initial
analysis performed
in
the
fall of 2000
Ameren
also
requested that
I
measure the
sound pressure
levels
across
the
street
on
the
western
side
of Gifford
Road
to
determine
the
impact of the Facility on what may become a new residential development
The sound tests were
accomplished with only a single gas turbine unit in operation
the one closest to
Gifford Road.
Subsequently, analytical techniques
were
used to
simulate the effects of the three
other’ units.
A
Power
Acoustics,
Inc.
report
dated
June
20th
2003,
“Analysis
and
Results
of
Acoustical
Measurements
Taken Near the Ameren Elgin, Illinois Power Facility During the Operation of the
Unit 4 SW5OJD5A
Gas Turbine
“,
summarizes the results.
-
-
-

3
December
3, 2003
The single unit operation was necessary to minimize the cost ofthe operational testing
and reduce the impact to the power grid since the power generated with all units operating would
exceed
450 MW.
Unfortunately, it is difficult to even give away power in the middle ofthe
night
with the moderate weather conditions that prevail at the time- ofyear Ameren needed to do
the
testing.
The results ofthe study after correcting for four unit operation showed that the
Illinois Noise Regulations were achieved at the existing residential areas.
However, at the
location adjacent to
the Ameren Elgin Facility on the west side of’Gifford Road, the corrected
-
results indicated ‘that the Facilitywould likely be in excess ofthe Illinois Octave Band Noise
Regulations if the property is used for residential purposes.
An additional
study was performed by Power Acoustics, Inc.
in July 2003 to
estimate the
sound pressure levels at locations enveloping the Realen property
To
accomplish this, the
sound
power
level of an individual gas turbine unit was estimated from the June 2003
sound
pressure
level measurements.
Sound
power
levels are different than sound
pressure
levels in
-
that
they are not impacted by sound propagation effects.
Sound power is the measure of sound-
energy that
is available to be radiated by the equipment
It can be
thought of similarly to the
wattage rating ofa light bulb
The bulb wattage crudely defines the amount
oflight
it
can
provide.
Although the actual amount ofthe light produced by the bulb will ultimately depend on
a vanety of factors, for example, its
efficiency, whether
it
has a lamp shade on
it,
and/or the color
of the room it is in.
Operational sound pressure levels from four unit operation were then estimated at various
locations on the Realen property using a theoretical sound propagation method that utilizes the
soundpower
information.
The results ofthat study were summarized in a letter to Bill Morse of
Ameren on July
11th
2003, which is included in the exhibit
containing my three written reports.
Basically, on the Realen property, the highest sound pressure levels were
estimated to occur
directly-west of the Ameren Elgin Facility at the closest position to
the gas turbine equipment,
while sound pressure levels decreased as distance
from the Facility increased to the west, north
or south.
-
Ameren further asked
if
any additional noise control could be added to the Facility to
enable it to
achieve the residential. noise levels.
I concluded that generalizations could be made

4—
December
3, 2003
for known noise controls such as barrier walls andlor buildings that could further reduce the
sound from the Facility.
The monetary cost ofthese treatments, however, would likely be high
since the Facilitywas initially designed to be fully outdoors
Also, the acoustical benefits ofthe
treatments, if any, could not be accurately estimated without performing a detailed design study.
Finally, for a facility such as this that already has substantial noise
abatement built-in, estimating
the effectiveness ofadditional noise treatments is difficult even with results from a design study.
The 501D5A gas turbines and
supporting equipment found at the Ameren Elgin Facility
contain the largest amount
ofsound abatement I have ever seen supplied by Siemens-
Westinghouse for simple
cycle 501D5A gas turbines
Noise enclosures and ventilation
silencers
are used extensiyely to control the sound radiated by the gas turbines
and supporting power
generation equipment.
When the units are “buttoned up” with enclosures and enclosure
ventilation silencing, the majority ofthe noise emitted by a gas turbine is generally observed
from two places:
first,
at
the opening needed to get air into the gas turbine’s compressor, and
second at the opening needed to
get the combusted gases out of the gas turbine.
These “holes” located at the gas turbine’s intake and
exhaust are the most difficult to treat
acoustically because they are linked directly to the noisiest internal
parts ofthe engine.
Ultimately, a gas turbine operates most efficiently with minimal blocking of its flow path
To
accomplish this, the intake
and exhaust flow paths
are treated with acoustically absorptive
parallel baffles that allow flow to pass through the open gaps that exist between the absorptive
sound baffles.
‘The silencers can provide a large amount of noise reduction while offering an
acceptable pressure loss to the gas turbine.
-
The exhaust silencing at the Ameren
Elgin Facility, particularly that used for low
frequency noise control, are state-of-the-art for Siemens-Westinghouse 501D5A units.
The
silencer panels were dimensionally selected by Siemens-Westinghouse
to
attenuate the low
frequency 31.5 Hz and 63
Hz octave bands while also providing substantial mid and high
frequency noise reduction.
This required the silencer panels to be extra thick
and very long.
The
low
frequency silencer panels were so
long that Siemens-Westinghouse had
to’ deviate from its
normal practice ofplacing all the silencing in the vertical exhaust stack.
They developeda

—5—
December 3, 2003
special horizontal section ofsilencer panels supported on the ground, approximately 40 feet in
length,
to accommodate the massive low frequency exhaust silencer.
To achieve even more
noise reduction, an additional
15
feet ofsilencers were included in the vertical portion ofthe
exhaust stack.
Finally,
to keep sound from radiating from the exhaust dücting surfaces, the duct
work includes one inch thick steel acoustically insulated with six inches of insulation
and an
internal steel liner facing the gas flow.
A secondary enclosure system was also provided to
encase the exhaust’ ducting.
This enclosure consists ofacoustically insulated quarter inch thick
steel plate.
A sketch ofthe major noise controls is shown in Diagram
1.
Diagram
1
Elgin Noise Control Features
The exhaust silencer is providing about the maximum attenuation a silencer system of
this type can. Adding
length to the existing silencing will not likely provide any substantial
reduction in sound levels.
In the event that more low frequencynoise reduction is required, the
existing stack would probably have to be removed and a new one designed from scratch.
However, even with a completely redesigned exhaust stack, obtaining
more low
frequency sound
ELGIN
ENERGY CENTER
NOISE
CONTROL,
DEVICES
INLET SILENCER
BAFFLES
OUTLET SILENCER
BAFFLES

-
6
December
3. 2003
-
attenuation than what currently exists would be questionable since the current design has already
challenged the state-of-the-art.
.
-
-
As for the inlet system, substantial inlet silencing and
acoustical duct lagging were
provided for noise control. The silencer consists
of
8 feet ofparallel baffles specifically designed
-
to attenuate the high
frequency compressor noise.
The main inlet ducting consists ofan
external
steel wall that is 3/16 inch thick followed with 4 inches ofacoustical insulation and an internal
steel liner that
faces the air flowing into -the compressor.
To further,reduce the sound radiated by
the inlet ducting, a layer ofinsulation and
lightweight gauge steel were added externally to
encapsulate the main ducting.
The encapsulation is referred to as the “acoustical lagging”.
Other prominent sources ofsound within the simple cycle gas turbine power generation
facility include the air-cooled generator, heat exchangers and transformers.
Each of these
sources ofsound has a common need for air flow to provide cooling. They cannot be completely
enclosed.
For instance, while the generator resides within a sound enclosure, its air flow cannot
have major restrictions without seriously affecting its ability to generate electricity efficiently.
The need for air flow is also
a requirement with all ofthe fin-fan type heat exchangers
Placing
restrictions around the heat exchangers could cause
the equipment they support
to overheat and
ultimately could cause the facility to fail.
Transformers have similar cooling issues.
Any
additional noise control ofthese components could have a negative impact on the operational
efficiency ofthe Facility.
,
-
-
Since the monetary and operational cost asso~iated
with acoustically modifying the
existing Ameren Elgin Facility was prohibitive and its
successful outcome questionable,
I was
asked to help determine obtainable site specific sound pressure level requirements.
This task is-
complicated by the limited amount of available operational data and an endless combination of
weather and operational possibilities that
can exist
On June
18, 2003
I had obtained sound
pressure level data with a single unit operating at base
load
This data was analytically corrected
to
four unit operation
Noise Solutions by Greg Zak had obtained sound pressure level data with
all four units in
base load operation
on September
2, 2003.
Both sets ofdata were taken under
weather conditions favorable
to sound propagation in the westerly direction.
Despite this, the

7
—,
December
3, 2003
data obtained may or may not be representative ofwOrst case conditions,
or conditions where the
equipment
produces its
maximum sound level.
For instance, aerodynamic sound sources, such
as fans and compressors that operate at constant rotational speeds can produce more noise when
the ambient temperatures are cooler and the
speed ofsound is low.
Under cooler conditions the
air is also denser so a larger mass ofair can be drawn into the gas turbine.
Also sound
-
propagation effects, such as atmospheric attenuation, are dependent on various combinations of
air temperature and humidity.
Forthese reasons, and many more, two sets ofsound pressure
level data cannot be
considered a statistical representation ofthe sound from the Facility.
Could
there be occasions under unknown weather and operational conditions when the Facility was
noisier than that measured?
Yes.
But, without several months of continuous operational data to
define the upper envelope of the Facility’s sound spectrum, the maximum cannot be
easily
obtained
However, collecting that amount and type ofdata is not feasible given that these types
of facilities do not operate continuously or at fixed operating levels and the cost ofoperating
them forjust acoustical testing is excessive
Even if that task was undertaken, there
is no way to
duplicate the endless weather conditions and operating levels to collect a statistically valid data
base
To determine the site specific sound pressure level requirements, a combination of the
sound pressure level
data measured by Greg Zak and myselfwas used.
Also factored in was
information supplied by Siemens-Westinghouse in,2000 that defines the equipment sound power
levels’.
The manufacturer’s sound power level data is auseful tool since it was assumed that
Siemens-Westinghouse would
attempt
to provide the upper envelope ofthe sound energy
produced by their equipment.
This
data also removes the unknown sound propagation .effects
related to the weather and ground compositionlcover.
Shown, in PAl Table
1
are comparisons of sound power level data provided by Siemens-
Westinghouse and
sound power levels estimated from June 2003 measurements made by
Power
Acoustics,
Inc.
I have included a small version ofthat
and Table
2
for your convenience.
A full
size version is also
attached.
PAl Table
1
501D5A Sound-Power Level Comparison

—8—
December
3, 2003
-
Description
Octave
Band Center
Frequency.
Hz
31.5
63
125
250
500
1000
2000
4000
8000
Manufucuterersestimate
of Sound Power Level ofsingle
SOIDSA gas
turbine
and
balanceofpl
127.3
120.7
119,6
111.2
105.1
100.9
97.6
98.2
99.6
Saund Power Level
estImated from PM
June2003 measurements (July 11,2003
report)
125.7
119.0
114.4
106.3
103.8
104.5
103.4
99.2
94.5
Deltafrom Sound Power
Level
from PM
Measurements and SiemensWestinghouse
Data
1.6
I
.7
5.2
5.0
-
1.3
-3.6
-5.8
-1.0
5.1
The differences between the Siemens-Westinghouse data and the PowerAcoustics data
are evident.
However, it does not appear that the Siemens-Westinghouse data is necessarily the
i.ipper envelope as was initially expected.
Shown in PAT Table 2 are comparisons ofthe range ofsound pressure levels that were
found to exist under conditions measured and with the Siemens-Westinghouse data factored
in.
PAl Table
2
-
Sound Pressure Levels Found/Estimated On West Side ofGifford Road.
Description
Octave
Band Center
Frequency.
Hz
31.5
63
125
250
500
1000
2006
4000
8000
Sound
PressureLevelof4units(eslimatedjutv
11,2003
PAl report).
Sound
Pressure Level of4
units Corrected
forDelta
from Siemens ~Vestlnghouse
Data
Greg
Zak
Measurements
Sept 2003
77.5
70.8
64.8
53.7
51.0
54.2
52.5
45.1
20.8
79.1
72.5
70.0
58.7
53.1
50.6
46
7
44 I
33.9
73.0
66.0
62.0
56.0
51.0
53.0
56.0
49.2
424
AverageofGreg
Zak Measurements,
PAl
Extrapolation
and
PAl
Entrap wIS-W
sound power
c
76.5
69.8
65.6
56.1
52.0
52.6
51.7
46.1
35.0
STD
Deviation
(POPULATION)
Average PlusSTD
Dcv
2.6
2.8
33
2.0
0.9
.5
3.9
2.2
5.6
79.1
72.5
68.9
58.2
52.9
54.t
95.6
48.3
40.7
t’roposed
Site Specific Rule
80.0
74.0
69.0
64.0
58.0
58.0
58.1)
50.0
40.0
Daytime Regulalion values
shown with
*
,
while
values
with “X”
exceed daytime standard
X
*
*
*
*
X
N
N
Note: Zak
data 4000 and 8000
Hz band was
discounted because of contamination by insect noise
leading to
)~o.~e:35Z)
Ocs.
As we developed the proposed site‘specific limits, we tried ~ostay within the existing
Illinois Daytime Noise standard.
However,
in the 31.5 Hz,
1000 Hz, 2000 Hz and 4000 Hz
octave bands, the Daytime standards did not adequately allow for the sound produced by these
units.
The levels proposed represent the maximum ofeither the Illinois Daytime Standard or the
average ofthe measured/synthesized values plus one
standard deviation and a safety factor as
deemed necessary.
The safety factor allows for unknowns caused by instrumentation
(measurement) uncertainty, uncertainty associated with
the operational parameters ofthe gas
turbine equipment, weather conditions and directivity
effects associated with various pieces of
the power plant equipment.
In my experience, uncertainties of3-5
dB are not
uncommon.
In
fact, many ofthe existing national and
international noise standards state that measurement
uncertainty alone is±3
dB.
My opinion is that the uncertainty could
be even larger than what we
have allowed for given the minimal amount of sound data available from this Facility.
This
analysis served as the basis
for the final requested site specific sound regulation for the Ameren
Elgin Facility.

9
December
3,
2003
This concludes my testimony summarizing my study and assessment ofthe Ameren Elgin
Facility noise levels, sound abatement and the explanation ofthe site specific
sound levels
proposed to the Board for adoption.
Thank you for the opportunity to testify today, and I would
be pleased to answer any questions that the Board may have at this time.
*
,
*
*
*
*
Petitioner, Ameren Energy Generating Company, reserves the right to supplement or
modify this pre-filed testimony.
-
Respectfully submitted,
Ameren Energy Generating Company,
Petitioner,
-
By:
_______________
One ofits Attorneys
Dated:
December 3, 2003
Marili McFawn
SchiffHardin &
Waite
‘6600 Sears Tower
Chicago, Illinois
60606
312-258-5519
CH2\
1060049.1

Table
1.
501D5A
Sound
Power Level Comparison
-
-
Description
Octave Band Center Frequency, Hz
31.5
63
125
250
500
1000
2000
4000
8000
Manufacuterers estimate of Sound
Power Level of single 501D5A gas turbine
and
balance
-
.
ofplantequipment
127.3
120.7
119.6
111.2
105.1
100.9
97.6
98.2
99.6
Sound Power
Level estimated from
PAl June 2003
measurements (July 11,2003 report)
125.7
119.0
114.4
106.3
103.8
104.5
103.4
--
99.2
94.5
Delta from Sound
Power
Level
from PA! Measurements and Siemens Westinghouse Data
1.6
1.7
5.2
5.0
1.3
-3.6
-5.8
-1.0
5.1
-
Table 2.
Sound Pressure
Levels
Estimated
at Gifford Road Location
-
-
Description
-
Octave Band Center Frequency,
Hz
31.5
63
125
250
500
1000
2000
4000
8000
Sound
Pressure Level of 4
units (estimated July 11,2003
PAl
report)
77.5
70.8
64.8
53.7
51.8
54.2
52.5
45.1
28.8
Sound
Pressure
Level of 4
units Corrected for Delta from Siemens
Westinghouse Data
79.1
72.5
70.0
58.7
53.1
50.6
46.7
44.1
33.9
GregZakMeasurementsSept2003
-
73.0
66.0
62.0
56.0
51.0
53.0
56.0
49.2
42.4
Average of Greg Zak Measurements, PA! Extrapolation and
PA! Extrap
w/S-W
sound
power corrections
76.5
69.8
65.6
56.1
52.0
52.6
51.7
46.1
35.0
STD Deviation (POPULATION)
2.6
2.8
3.3
2.0
0.9
1.5
3.9
2.2
5.6
Average Plus
STD Dev
79.1
72.5
68.9
58.2
52.9
54.1
55.6
48.3
40.7
Proposed Site Specific Rule
80.0
74.0
69.0
64.0
58.0
58.0
58.0
50.0
40.0
Daytime Regulation values shown
with
*
Vt.
while values with “X”~exceeddaytime
-
standard
X
*
*
*
X
X
X
Note:
Zak data 4000 and
8000 Hz band was discounted because of contamination by
insect noise leading to large
STD Dcv.
C112’
1060410.1

CLERK’S
~
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
PEC
4
20Q3
STATE
Of’ ILLINOIS
iN THE MATTER OF:
Pollution
Control Board
-PROPOSED SITE SPECIFIC REGULATION
)
APPLICABLE TO AMEREN ENERGY
)
R04-1
1
GENERATING
COMPANY,
ELGIN, ILLINOIS,,)
AMENDING
35
ILL. ADM. CODE 901
.
)
PRE-FILED TESTIMONY OF GREG ZAK,
of NOISE SOLUTIONS BY GREG ZAK
-
IN SUPPORT OF
-
AMEREN SITE
SPECIFIC RULE
Ameren Energy Generating
Company (“Ameren”),
by
and
through
its
attorneys,
Schiff
Hardin
&
Waite,
and
pursuant
to
35
Ill.
Adm.
Code
102.424,
submits
the following Pre-Filed
Testimony
of Greg
Zak
for presentation
at the
December
17,
2003
hearing
scheduled
in
the
above-referenced matter.
-
TESTIMONY OF GREG ZAK
Ladies and gentlemen, my name is Greg Zak.
I am the owner of Noise Solutions by Greg
Zak.
I am appearing here today on
behalf of the Petitioner,
Ameren, in
support of its
proposal
for a site specific rule for the noise
levels applicable to
its Elgin Facility.
I will testify regarding
the
sound measurements
taken by Noise Solutions by Greg Zak on
September 2,
2003,
and the
information
developed
based
upon
those
measurements.
I
will
also
explain
how
those
measurements compare to
the measurements taken and
developed
by Power Acoustics
Inc.,
and
how the site specific limitations
proposed by
Ameren
compare
to
the Illinois Pollution
Control
Board’s generally applicable noise emission, limitations.
I would
like
to
begin by briefly describing my experience in
both
the public
and private
sectors.
I have owned and operated Noise Solutions by Greg Zak since March of2001.
Prior to
entering
the
private
sector,
I
was
employed
by
the
Illinois
EPA.
I
have
over
31
years
of

experience dealing with
noise measurement,
noise control engineering,
and
the effects ofnoise
on people and
communities.
This
experience includes industrial,
commercial, residential, urban,.
rural and construction noise.
Many of you know me.
I have acted as a noise expert for my
firm
in
enforcement hearings before
the
Illinois
Pollution
Control Board.
When employed
by
the
Illinois EPA, I was a recognized noise expert
in
enforcement and regulatory hearings before the
Illinois Pollution
ControlBoard,
Federal Bankruptcy Court,
and in several Illinois Circuit Court
hearings related to
noise zoning and nuisance.
I have been a member ofa Society of Automotive
Engineering Committee,
and
a member of the American
National
Standards
Institute
Working
Group on
the Measurement
and
Evaluatio,n 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.
I represented
the Illinois
EPA, as
its
Noise Expert,
when testifying before the Illinois
Pollution
Control Board’s hearings
on
August
23,
2000
and
October
5,
2000
in
the
matter
of:
“Natural
Gas
Fired,
Peak-Load
Power,
Generating
Facilities
(Peaker
Plants)”,
PCB
ROl-lO.
I have
also
frequently
testified
at
noise
enforcement hearings before the Board regarding noncompliance
and
appropriate
remedy.
The
noise
issues
I
have
dealt
with
frequently
involved
the
technical
practicability
and
economic
reasonableness ofreducing 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 ofCompatible 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 (1NCE).
At
Ameren’s
request,
on
the night of September
2,
2003,
Noise
Solutions by
Greg Zak
conducted
a
sound measurement test at the Elgin Facility while the facility was not operating and
while it was fully operational, that
is, with all
four units
at maximum load capacity.
The results
2

of this test are contained in
the noise
report attached to
my testimony.
In Table
1
of the
noise
report,
my
data
taken- September
2,
2003
is
compared
to
the
measurements
taken
by
Power
Acoustics, Inc. (PAl) during its June, 2003 tests.
I will be referring often to this Table
1.
On September 2, 2003,
the measurement location was
on the west side of Gifford Road,
directly across from Unit 4
and at the same approximate location ofthe measurements taken by
Power Acoustics,
Inc.
and
identified as “L-R2” in PAT’s reports
and in my report.
The weather
conditions
went from
clear to partly cloudy
and
the wind was
from
the east at approximately
5
mph
during
the
measurement period.
In order
to
closely
duplicate the
measurement
location
used
by
Power
Acoustics,
the
microphone
was
located
at
the
edge of a
very
weedy,
insect-
infested, field.
The close proximity of the microphone to the thick
4 to 6
foot high weeds would
later prove
to
be
problematic,
due
to
insect
noise
in
the high
frequency portion
of the
sound
spectrum.
The ambient measurements began around
9:00 pm to
ensure that the time between the
ambient
and
full load operation
would be as close together
as possible.
Ambient measurements
ceased at 9:30 pm,
as the Ameren Facility was in start-up mode by that time.
The-measurement
was
taken during
a
30-minute
period with
only
the quietest
10
minutes
of data being
used to
compile the
10 minute ambient.
This
very selective data gathering produced ambient
results
free of any extraneous noise
or noise
associated
with
the plant
start-up process.
It
should
be
noted
that
the area
was very
noisy due to
ground and air traffic.
The ambient was gathered
by working around
(pausing the
analysis instrumentation) the roar ofoverheadjet
traffic, the rumble ofdistant
railroad trains and
their whistles,
and
also
truck
and
automobile
traffic
on
Gifford
Road.
The
large
amount
of
extraneous
noise
is
not
reflected
in
the
ambient
measurements
at
all,
per
the
Board’s
measurement procedures.
One ofthe primary sources of ambient noise
was the US
Can
facility
located south ofthe Ameren Facility on Gifford Road.
Sounds that could be heard
from US
Can
included idling
trucks, back-up beepers,
and intermittent shouting by
workers.
These extraneous
noises are the type that mask and even drown out the noise from the Facility.
3

The results
from
this measurement period are found at Table
1,
row 4:
“10
minute
Leq
Ambient.”
A
brief ‘explanation
of what
is
meant
by
the
measurement
of a
10-minute
Leq
ambient
is
in
order
here.
The term ambient
refers
to
-
all
of the sound
in
the area,
except
for
extraneous sound and
any sound emanating from the Ameren Facility.
Extraneous sound is
of
relatively
short
duration
and
comes
and
goes,
such as vehicle
passbys,
aircraft flyovers,
train
whistles,
and
so
forth.
The measurement instrumentation is
put
in
a
“pause mode”
to
avoid
including
extraneous sound during measurement.
It should be noted
that, the
same‘exclusion of
extraneous noise is used to measure the sound levels produced by the noise source ofinterest, the
Elgin Facility.
“Leq
as defined in the Board’s noise regulations and in this context means that
the
sound
energy
is
averaged
over
a
period
o.f
600
seconds
(10 minutes).
The
ten
minutes
referenced here are
a composite
of all
“chunks
of time” within the
30-minute
time
span (9
to
9:30 pm) that were previously defined as ambient.
-
Measurements commenced at
10:00
pm
and
ceased at
11:17
pm.
The facility was fully
operational
from
approximately
10:10
to
10:51
pm.
That is,
all
four units
were running
at full
load during that
time.
Of the
41
minutes ofmeasurements
collected,
I selected
the
10
minutes
representing the
loudest
sound
levels.
These measurements
were
recorded between
10:25
and
10:42 pmwhich
was
a
17
minute
time
span required
to
eliminate extraneous noise
from
other
sources.
The results of these
measurements are recorded in Table
1, row 3:
“Raw
10 minute
Leq
at 447 MW” as raw data.
This
Table
also
includes two
other versions of the data, rows
5
and
6:
“Corrected
10
minute
Leq
at 447 MW”
and “Corrected and
rounded
10 minute
Leq
at 447 MW”.
The latter data
was rounded for ease of comparison with the existing Board noise emission limitations
and those
ofDuPage County and Cook County, as well as the site specific levels requested by Ameren.
Once
the
data
was
collected,
we
also
compared
the
results
with
the
measurements
obtained by Power Acoustics,
Inc.
on June 18, 2003.
At that time, just one unit was operating
at
full load and
an
extrapolation of that data was performed by Power Acoustics,
Inc.
to
simulate 4
units
at full operational load.
The sound pressure levels contained in
the Power Acoustics,
Inc.
4

(PAT)
report are found
at Rows
1
and
2 of Table
1,
and
the measurements
obtained
by
Noise
Solutions by Greg Zak’(ZAK) are shown in Rows 3 through
6.
Row
1,
which
is
Table
9
of the
PAT
report,
shows
extrapolated
data
from
actual
measurements (10
minute
Leq)
taken of Unit
4
and
projected
to
include
Units
1
through
3
to
arrive at an
estimated sound
level
maximum.
Row
2
contains ambient measurements taken on
June
17 that are shown in the PAl report at its
Table
6.
The ZAK data in Row
3 describes a
10
minute
Leq,
without
corrections,
measured
on
September
2
when
the
facility
was
fully
operational.
Row
4
represents
an
ambient
10
minute
Leq
measurement
which
shows
little
deviation from the PAl data, until the high frequency octave bands were measured.
The comparison documents a significant difference in
decibel levels at the
4000 Hz and
at
8000
Hz.
The difference of 15
dB higher at 4000 Hz and
20
dB
higher at
8000 Hz
is
largely
due
to
excessive
insect
sounds
that
were
unavoidable
during
the
measurement
period.
We
surmise
that
when
PAT
took
its
measurements
in
June,
2003,
this
property,
including
the
measurement location, was not yet bordered by an
overgrowth of thick weeds and brush that
are
conducive
to
the harboring of a variety of insects.
This overgrown and
insect infested area was
to
the west ofthe microphone during the ZAK ambient measurement period
and would
account
for these high readings.
-
When the ZAK corrected levels in Row
5
are compared to
the levels obtained by
PAT, the
operational measurements at full capacity are considerably lower, with the exception of 2000 Hz.
At that octave band,
the PAl projection was
53.2 dB, while the ZAK measurement was
55.6
dB,
a difference of 2.4
dB.
Bear
in
mind that the PAl data represents a projection
from
the actual
measurement
of
1
unit running
to
the theoretical
sound
levels for
all
4
units.
Based
upon
my
experience,
a
2.4
dB
difference between
extrapolated
data
and
actual
measurements
falls
well
within the many sources of potential
error in
making
an
extrapolation
from
the measurement of
one
running
unit
to’ the
actual measurement
of 4
units,
each with
its
own subtle characteristics
even though
each consists of the same turbine model and
other necessary equipment
and
noise
abatement controls.
5-

Finally,
I
compared
Ameren’s
requested site-specific
noise
emission limitations
for the
Elgin Facility with a portion ofthe Board’s
current limits
listed
on the attached Table 2.
This
comparison demonstrates that the limitations proposed in this rulemaking are not significant.’
At the
31.5
Hz octave band,
the
80
dB
limitation requested
is
equal
to
the current limit
for “Industrial Noise Commercial Receiver Limits”,
that
is,
C to
B
land use, at Section 901.103
of the
Board’s
rules.
The
limitations
requested
at
63
Hz
through
500
Hz
are
equal
to
the
“Industrial Noise to Residential
Receiver Limits”, that
is C
to
A land use, at Section 901.102(a)
of the Board’s rules,
and
are considerably below the
C
to
B
land use limits of Section 901.103.
At the
1000
Hz level,
the
58
dB
limitation proposed is
only
1
dB
higher than the 57
dB allowed
under the
limits for C to
B
land use.
At 2000 Hz, the 58 dB
limitation, while exceeding the C to
B
land use by
6
dB, would not
significantly penetrate a house ofmodern construction when the
windows
are closed, which
is the likely situation when the peakers are operating during periods
of very hot or cold weather.
At the .4000 Hz,level, the 50 dB limitation, while exceeding the C to
B
land use by
2
‘dB,
would
not significantly
exceed
the levels frequently generated by crickets,
locusts,
and
other insects.
Additionally,
4000 Hz
is
even
less
able
to
penetrate
a
house with
closed windows
than
is
2000
Hz.
And,
at the
800
Hz level,
the proposed 40
dB
limitation
is
equal to
the present Section
901.102(a) limit,
and
5
dB
lower than C to B land use limits.
Let me note here that the approximate A-weighted levels expressed
dB(A) are included in
Table
2
to provide
additional
perspective regarding the
noise
impact.
The A-weighted decibel
levels are not
proposed
for adoption
because
the Board’s
generally applicable
noise
emission
limitations dc~not include A-weighted decibel
limitations.
Yet
another ,perspective
may
be
helpful.
The character of the
sound
from
this
type of
power plant
is
often described
as similar
to
that
of noise
generated by airflow
from
ventilation
within an
office building.
This
type of noise, whether indoors or out of doors, often
is absorbed
into ambient noise.
And, furthermore, the
sound
emanating from this Facility has been reduced
6

with noise abatement equipment.
Care should
be taken not to
compare
it to
uncontrolled noise
sources.
-
Site specific
noise
emission
limitations
applicable
to
receiving
Class
B
lands
are
also
requested by Ameren.
Six ofthe nine numerical levels are the same as those
currently found at
Section 901.103 ofthe Board’s Class
B receiving lands.
However, at the remaining three octave
bands, the
1000,
2000,
and 4000 Herz octave bands, the Board’s noise limits are more stringent
than those requested by Ameren as its
site specific
limits for Class
A receiving
lands.
Ameren
proposes
that
the
Class
B
site
specific
noise
limits
adopted
at those
octave
bands
be
the same
numerical
value
as
those
proposed
for
Class
A
receiving
lands.
In
my
opinion,
any
environmental
impact
based
upon
those
numerical
changes
would
be
of
insignificant
consequence.
-
I also reviewed other state noise programs to
see if new or unique regulatory methods are
in
use.
My review of a report of noise regulation in
the U.S.
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.
I also
found that peaker noise is not regulated by the other Region
5
states,
California,
Texas,
or New
York.
And,
finally,
peaker noise
is
not
regulated
on
the
federal level.
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
frequently
not
considered
the
land
buffer
component
of noise
control
in
making
zoning
decisions.
It
should
also
be
noted
that
the
Illinois
EPA
has
received
no
complaints
regarding peaker plant noise during my nearly 30-year career there.
To
conclude.
in
my
opinion, based
on the thousands
of measurements I have taken and
several
thousand
noise
complainants
I
have
interviewed,
the
likelihood
of noise
complaints
regarding the Ameren Facility from
the Realen property, should it
be
developed
residentially,
is
remote.
As
demonstrated
by
my
prior
comparison
to
other
acceptable
noise
levels,
any
environmental
impact
to
the Realen
property if
converted
to
residential
use will
be
minimal.
7

-
Likewise,
any
environmental
impact to
receiving
Class
B
lands,
if those
proposed numerical
values are adopted to
make the limitations for both types ofreceiving
lands consistent, would be
insignificant.
Tn
both
cases,
this
is
true
in part because
the
extraneous
noise
of the
-
area
is
comparable to and oftentimes greater than that attributable to the Ameren Facility.
As always,
I enjoyed testifying
before you
today.
Thank you
for the opportunity,
and
I
woufd be pleased to answer any questions
that the Board may have at this time.
*
*
*
*
*
Petitioner,
Ameren
Energy
Generating
Company,
reserves
the
right
to
supplement
or
modify this pre-filed testimony.
Respectfully submitted,
____5
S
~
/
By:
~‘
~
..-~,-
~
Marili McFawn
Dated:
December 3, 2003
Marili
McFawn
SchiffHardin
& Waite
6600 Sears Tower
Chicago, Illinois
60606
312-258-5519
-
8.

TABLE
1
MEASURED AND EXTRAPOLATED SOUND PRESSURE LEVELS
FOR AMEREN ELGIN UNITS 1,2,3
AND
4, LOCATED AT L-R2
ON GIFFORD
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
PAT’
-
Table
9, Extrapolated Total
6-20
78.4
71.8
63.5
rnd
md
55.0
53.2
45.7
31.9
---
PAl1
Table 6, Ambient
6-17
58.1
59.6
55.2
48.3
46.9
45.9
40.7
33.7
22.1’
---
ZAK2
Raw
10
minute Leg
at 447
MW
9-2
73A
66~5
62~
57M
53.0
53.4
55~5
492
42A
60.1
ZAK2
10
minute
Leg
Ambient
9-2
592
59~
54~
49.7
49.2
44~ 44.4
48.7
423
517
ZAK2
ZAK2
Corrected
10 minute
Leg
at 447
MW
Corrected and rounded
10 minute
Leq
at 447_MW
9-2
92
714
73
65~5
66
61.9
62
56M
56
507
51
527
53
55~5
56
0
0
0
0
5&8
59
Ii Daytime Class A and DuPage Co.
,
---
75
74
69
64
58
52
47
43
40
---
II Nighttime Class A
and DuPage Co.
,
---
69
67
62
54
47
41
-
36
-
32
32
---
Cook CountyMl toA
---
72
71
65
57
51
45
39
34
32
---
901.103C-~A
---
75
74
69
64
58
52
47
43
40
61
901.103 C
-~
B
---
80
79
74
69
63
57
52
48
45
-
Site Specific Rule Requested C
-~
A
---
80
-
74
69
64
58
58
58
50
40
---
Site Specific Rule Requested C ~3B
.
---
,
80
79
74
69
63
58
58
50
45
Power Acoustics, Inc.
Report ofJune, 2003
***
Noise Solutions by Greg Zak Report of September, 2003
Notes:
**
Table .1
above describes the
comparison of sound pressure
levels contained in the
Power Acoustics, Inc.
(PAl) report
(Rows
1
and 2) with measurements
obtained by Noise
Solutions by Greg Zak (ZAK)
as
shown in Rows
3
through
6.
L
9

TABLE 2
ACOMPARISONOF
CURRENT
NOISE LIMITS IN ILLINOIS
WITH
THE
AMEREN
ELGIN
FACiLITY SITE-SPECIFIC NOISE
EMISSION LIMITATIONS
OCTAVE BAND
CENTER
FREQUENCY IN
HERTZ (HZ)
INDUSTRIAL NOISE
TO COMMERCIAL
RECEIVER LIMITS
Section
901.103
AMEREN
ELGIN
FACILITY SITE-
SPECIFIC
NOISE
EMISSION
LIMITATIONS
COMMERCIAL
NOISE TO
COMMERCIAL
RECEIVER LIMITS
Section 901.103
INDUSTRIAL N0
TO RESIDENTIAl
RECEIVER
LIMIT
Section
901
.1 02a
31.5
HZ
80dB
80dB
79dB
75dB
63HZ
79 dB
74
dB
78 dB
74 dB
125HZ
74dB
69dB
72dB
69dB
250
HZ
69dB
64dB
64dB
-
64dB
500HZ
63dB
58dB
58dB
58dB
1000 HZ
57dB
58dB
-
52dB
52dB
2000 HZ
,
52dB
58dB
46dB
47dB
4000HZ
48dB
50dB
41dB
43dB
8000HZ
45dB
40dB
39dB
40dB
-
APPROX.
A-WT
66
dB (A)
64 dB (A)
62 dB (A)
61
dB
(A)
-
CH2\
1059845.1
10

-
-
RECEIVED
NOISE
SOLUTIONS
BY
GREG ZAi~LE~’so~
-
36
BIRCH DRIVE
-
DEC
4
2003
CHATHAM, ILLINOIS 62629
(217) 483-3507
STATE OF
ILLINOIS
(217) 483-5667-FAX
Pollution Control Board
E-mail: ~re~zak~justice.com
Sound Assessment Report
for
Ameren Elgin Facility
by
Greg Zak, INCE
Member of the Institute of
Noise Control Engineering
November
1,
2003

I.
INTRODUCTION
Ameren Energy Generating Company, through its attorneys,
retainedNoise Solutions by Greg Zak to conduct a
sound assessment at its
Elgin Facility located at
1559
Gifford Road in Elgin
on
September 2
and
3, 2003.
The
designated
location for measurement was to be
across from
the Facility,
on
the west side of Gifford Road,
in
close
proximity
to
a
potential
residential
development
proposed
by
Realen
Homes
(“Realen
or
Realen
Property”).
The
objective
was
the
determine
the
current
sound
ambient
levels
at
the
Elgin
Facility,
as
well
as
the
operational sound levels, while
all
4
peaker units were operating
at maximum
load.
We would then document
those
levels, analyze for compliance with Illinois noise regulations, report the results,
and compare those results
to
previous studies.
Based
upon
the results
of that
survey and
evaluation,
the conclusion, with,a
reasonable
degree of scientific
certainty,
is
that
noise
emissions
from
the
peaker
units
at
the
Ameren
Elgin
Facility,
would
exceed
the
allowable
limits
of Section
901.1 02b
for
Class
C
Land impacting
Class
A Land under
Title
35,
Sub-Title
H,
-
Chapter I ofthe Illinois
Administrative Code (Illinois Noise Regulations)
at the Realen property if converted to
residential use.
As
for the Board’s limitations
at Section 901.103
for Class
C
Land impacting
Class
B
Land,
noise emissions from
the Elgin Facilitymay exceed those limits if any commercial
facilities are located near the
Elgin Facility.
II.
ILLINOIS STATUTES AND REGULATIONS
The
land use, where the
Elgin Facility peaker units
are located,
is
classified
under Appendix
B (Standard Land
Use
Coding Manual), of Part
901
of the
State of Illinois
Noise Regulations
(Title
35,
Sub-title
H,
Chapter I of
the Illinois
Administrative Code).
The appropriate classification is
code
# 4812,
which
designates an
“electric
generation plant.”
This represents
Class
C in terms ofPart
901.
Any residential property in
the vicinitywould
be
designated as Class A and any commercial property as Class B.
In terms of compliance, it is
the Class
C
to
Class
A
regulatory
limits
of 901.102(b)
and
the
Class
C
to
Class
B
regulatory
limits
of 901.103
that
are
controlling, peaker
facilities
are
considered a
Class
C
land use,
and
need
to
achieve
the
compliance
levels
specified
in
each octave
band
for Class
C
(emitter)
to
Class A (receiver)
during
daytime
and
nighttime
hours
and
Class
C to Class
B at all hours.
See Illinois Noise Regulation Tables below.
Illinois
Noise Regulation Tables
Section
901.102
-
Sound Emitted to Class A Land
a)
Except as elsewhere in this Part provided, no person shall
cause or allow
the emission ofsound
during daytime hours from
any property-line-noise-source located
on any Class A,
B or C land to
any receiving Class A land which exceeds any allowable octave band sound pressure level
specified in
the-following table, when measured at any point within such receiving Class A land,
provided, however, that no measurement of sound pressure levels shall be
made less than 25
feet
from such property-line-noise-source.
-
Noise Solutions by
Greg Zak
.
Noise
Report

-
3
Octave Band Center
Allowable Octave Band
Sound Pressure Levels (dB) of Sound
Frequency
(Hertz)
Emitted to
any Receiving Class A Land
from
Class
C Land
Class
B Land
Class A Land
31.5
75
72
72
-
63
74
71
71
-
125
69
65
65
250
-
64
57
57
500
58
51
51
1000
52
45
45
-‘
2000
47
-
39
39
4000
43
34
34
8000
40
32
-‘
-
32
b)
Except as elsewhere in this Part provided, no person
shall cause or allow the emission of sound during
nighttime
hours
from
any property-line-noise-source located on any
Class
A,
B
or
C
land
to
any
receiving Class
A land which exceeds any allowable octave band sound pressure
level specified in the
following table, when measured at any point within such receiving Class A land, provided, however,
that no measurement ofsound pressure levels shall be made less than 25 feet from such property-line-
noise-source.
Octave Band Center
Allowable
Octave Band
Sound Pressure Levels (dB) of Sound
Frequency(Hertz)
Emitted to anyReceiving ClassA Land from
Class C Land
ClassB Land
Class A Land
31.5
69
63
‘63
63
67
61
61
125
62
55
55
250-
54
47
47
500
47
40
40
1Q00
-
41
35
35
-
2000
36
30
30
4000
-
32
-‘
25
25
8000
32
25
25”
Section
901.103
Sound Emitted to Class B
Land
Except as elsewhere in this Part provided, no person
shall
cause
or allow the emission of sound from any
property-line-noise-source located on any Class A, B or C land to any receiving Class B land which exceeds
any allowable octave band sound pressure level, specified in the following table, when measured at any
point
within suchreceiving Class B land, provided, however, that no measurement of sound pressure levels shall be
made less than 25 feet from such property-line-noise-source.
Noise Solutions
by Greg Zak
,
Noise
Report

4
Octave Band Center
Allowable Octave Band Sound Pressure Levels (dB) ofSound
Frequency (Hertz)
Emitted
to any Receiving Class
B Land from
Class
C Land
Class
B Land
Class A Land
31.5
80
79
72
63
79
78
71
125
74
72
65
250
69
64
-
57
500
63
58
51
-
1000
57
52
45
2000
52
46
39
4000
48
41
34
8000
45
39
32”
III.
MEASUREMENTS
-
Upon arriving in the area, we proceeded
to
select a
measurement location
and
then become
familiar with the
topography, weather conditions,
and suitability of
the site for testing purposes.
Various photographs were also
taken
before proceeding to the plant office. A preparatory meeting was held at the Arneren Elgin
Facility
Office located at 1559 Gifford Road, Elgin, IL at 7:35PM on September 2, 2003. We discussed the best time
(most
representative) to obtain measurements ofthe ambient or background noise present in the areawhen the
Facility was not operating. The Facility personnel suggestedcompleting the ambient noise measurement before
the 9:30 PM start-up, as shutting everything down after 11 PM could take several hours, thus delaying the
ambientmeasurement until the early hours ofthemorning.
After
this brief meeting, we
set
up
our instrumentation at
Site
1.
See
Diagram, Attachment A.
This
location
would be on the west side of Gifford Road, as close as possible to the measurement location used by David
Parzych ofPower Acoustics,
Inc. and
identified by him as “L-R2
on Gifford across from Ameren Unit
4.”
(See
“Analysis
and
Results
of Acoustical
Measurements
Taken
Near
the
Ameren
Elgin,
Illinois
Power
Facility
During the Operation of theUnit 4 SW5O1D5A Gas Turbine”, 6-20-03,page 16, Table 9).
We decided
to begin ambient measurements around 9 PM in order to
ensure that the
time between the ambient
and full-facility operation would be as close together as possible, since the Facility personnel anticipated they
would begin their start-up at, 9:30 PM. During the entire measurement period, for both ambient and operational
measurements taken,
it became necessary to pause the analyzer a number of times in order to avoid recording
extraneous noise
sources,
such as
airplane flyovers,
truck,
train
ahd
other
types
of vehicle
sound emissions.
One of the primary sources
of ambient noise
was the
U.S.
Can
Company
to
the
south
with
its
idling
trucks,
back-up beepers, and intermittent shouting
by workers.
See
attached Table
1, row
4, “10 minute
Leq
Ambient”.
The dominant noise source in the area in
terms of the highest
Leq
levels present,
when we
were
taking
our
measurements that evening,was extraneous noise.
The
Ameren
Elgin
Facility, with its
4
peaker units,
is
located
at
1559 Gifford Road in Cook County,
Ilinois.
The Ameren Facility borders the GE Capital Module Space to the north, and BFI Waste Systems Facility and
Commonwealth Edison’s high-powered
transmission
line
corridor to
the
east.
Running both
north
and
south,
the E E & J Railroad crosses Route 20 to the north.
South of the facility are two construction companies and
U.S. Can Company.
To the west
is Gifford Road, and to the west of Gifford Road,
is the Realen property.
Noise
Solutions by Greg Zak
Noise Report

5
Also, bordering the Facility to the northwest and west is Bluff City Materials.
The area also consists ofvarious
industrial plants, whose business is light and heavy-dutymanufacturing.
The Facility personnel were
instructed by
Ameren to
run the
4
peaker units
at maximum load capacity from
approximately 10
PM to
11-PM and
to
run the wet compression pumps on the two units so-equipped.
No water
would be injected as it would not increase power output due to the atmospheric conditions present that evening.
These pumps were being run
to simulate as noisy a condition for plant operation as possible.
The Facility was fully
operational from approximately
10:10
to
10:51
PM.
Measurements commenced at
10:00
PM
and ceased at
11:17
PM.
We then returned to
the office to
discuss our findings
and
verify the operational
conditions
occurring at the Facility, while
we were
taking
sound
level
measurements
at Site
1.
We’ left the
Elgin Facility at
12:10 AM on September 3, 2003.
The
final
portion
of the
sound
assessment
project
was
the
analysis
of
fieldwork
measurement
data,
a
comparison with the State ofIllinois regulatory limits, and the preparation of a written report that documentsthe
measurement results.
-
-
1. Measurement Procedures
Since
1987
the Illinois
Pollution
Control Board
has required a
1-hour ambient
corrected
Leq
measurement for
-
noise
sources, while ambient measurements of 10 minutes
duration have been accepted by the Board.
For the
purposes ofthis
study,
it was decided to take all measurements using a duration long enough to obtain
a steady,
non-changing reading rather than 1 hour.
This methodologyproduces the same sound level measurements that
would be obtained over a full hourbut in
a shorter period of time, in this case, several measurements were taken
over a period of 41 minutes. Themain factor that went into this decision was the difficulty experienced by the
Elgin Facility in keeping all 4 peakers running at full loadwithout
any equipment interruption at the Facility for
a
full hour.
For all measurements, it was noted
that
after the analyzer ran
for a very short period of time, there
was no significant change in the level measured from that point until all of the data hadbeen gathered.
It was
obvious
that to
extend any ofthe
short duration measurements
to
a
full
1-hour would not
have changed any of
the results. The
1 0-minute sample in Table
1 was chosen as the mostrepresentative for compliance purposes as
it represents the longest and loudest sample.
It also compares very closely with the 10-minute measurement
preceding it and the 10-minute measurement following
it.
Lastly, the Board
has opened a rulemaking to
make
regulatory changes to
its noise measurement procedures and has proposed to adopt the type of short
period
measurement procedures we used in this study.
Ambient daytime measurements
were
taken from
9:00
PM
to
9:30 PM on
September
2,
2003
to
determine the
background sound levels at Site
1.
See Attachment
1 and Table
1.
The analyzer was calibrated before and after the ambient measurements were taken.
Battery condition of all
equipment was monitored continuously.
Weather observations were made prior to and
at the end of the
measurement period.
During this
test, the weather conditions
went
from clear to partly cloudy,
wind speeds of
0
to
5 mph from the east were blowing directly from
the peakers
to
the microphone,
and
the wind
was from the
east.
In order to closely duplicate the measurement location used
by
Power
Acoustics,
the
microphone
was
lOcated at the edge ofa very weedy, insect-infested, field.
The close proximity ofthe microphone
to the thick 4
to
6
foot high weeds would
later prove
to
be problematic, due to insect
noise
in
the high
frequency portion of
the sound spectrum.
-
Noise Solutions by Greg
Zak
Noise Report

6
The ambient measurements began around 9:00 PM to ensure that the time between the ambient and full load
operation
would
be
as close together
as possible.
Ambient
measurements
ceased at
9:30
PM,
as the Ameren
Facility was in
start-up mode by that time.
The measurement was taken during
a 30-minute
period with
only
the quietest
10 minutes ofdata being used to compile the 10-minute ambient.
This very selective data gathering
produced
ambient results
free of any extraneous
noise or noise
associated
with
the plant
start-up
process.
It
should
be
noted that
the
area was very
noisy
due
to
ground
and
air
traffic.
The
ambient was
gathered
by
working around
(pausing
the analysis
instrumentation)
the roar of overhead jet
traffic,
the
rumble of distant
railroad trains
and their whistles,
and also truck
and automobile traffic
on Gifford Road.
The
large amount
of
extraneous noise is not reflected in the ambient measurements at all,
per Board measurement procedures.
Given
the large amount of extraneous noise recorded,
and
based on
the thousands of measurements I have taken aiad
several thousand
noise complainants I have interviewed, my opinion is
that the likelihood of noise
complaints
from theRealen development regarding theAmeren Facility is remote.
During the period of time when the ambient was measured, the temperature was
65°
F at the beginning
ofthe
measurement period and
65°
F at the
end.
The humidity was 87
at the beginning of the measurement period
and
87
at the
end.
The barometric pressure was 30.06 in. Hg. at the beginning ofthe measurement period and
30.06 in. Hg.
at’ the end.
The measurement protocol generally followed that portion of the Illinois Pollution
Control Board’s (Board)
Leg
requirement for obtaining
an
ambient.
Measurements were
taken simultaneously
in one-third-octave band, octave band, and dB(A). Theprimary noise source
was the U.S.
Can Company to the
south, with idling trucks, back-up beepers,
and employees shouting.
Plane flyovers and
other traffic noise were
audible. Distance from
the testing site to
the exhaust stack on Unit
#4 was
169 yards
(507’).
The distance was
measured with Our firm’s
laser range finder
which is accurate to
+1-1
yard.
-
The peaker noise measurements started at
10:00 PM,
at Site
1, when the peaker units were
operational.
During
this test, wind speeds of 0
to
5
mph from th,e east were meas,ured at the microphone.
The temperature was
65°
F
at the beginning of the measurement period and 62°F at the end.
The humidity was 90
at the beginning of the
measurement period
and
96
at the
end.
The barometric pressure
was
30.06
in.
Hg.
at the beginning
of the
measurement period
and
30.06
in.
Hg.
at the
end.
Measurements
were
taken simultaneously
in
octave
band,
one-third-octave
band,
and
dB(A).
Measurements
commenced at
10:00
PM
and
ceased
at
11:17
PM.
The
Facility personnel told us that all
4 peakers
were
fully operational
from approximately
10:10
to
10:51
PM.
Of
the
41
minutes
of measurements -collected,
we
selected the
10
minutes
representing
the loudest
sound
levels.
These measurements were recorded between
10;25
and
10:42 PM
which was a 17-minute time span required to
eliminate extraneous noise
from other sources.
The results ofthese measurements are recorded in
Table
1, row
3: “Raw
10 minute
Leg
at 447 MW” as raw data.
This
Table also includes two
other versions ofthe data, rows
5
and
6:
“Corrected
10
minute
Leg
at 447
MW and
“Corrected
and rounded
10
minute
Leg
at
447
MW”.
The
latter data was rounded
for ease of qomparison with
the existing Board noise
emission limitations
and those of
DuPage County and Cook County,
as well as the site specific levels requested by Ameren.
The one-third octave
band
measurements
indicated the presence
of no
prominent
discrete
tones
which
are regulated
under
Section
901.106 ofthe Board’s noise regulations.
2.
Eciuipment
A Larson-Davis Laboratories Model 2900B
Real Time
Analyzer with
associated microphone
and
pre-amplifier
was used to perform the measurements.
This combination ofinstrumentation meets the requirements for a Type
1
Sound Level Meter, as defined in
American National Standards Institute
(ANSI) 5 1.4-1983 and
ANSI S1.4A-
1985.
This
instrumentation
also
meets the requirements of International
Electro-teclmical Commission
(IEC)
651
for a Type
1
SLM and IEC
804
for a Type
.1
Integrating SLM.
(Note:
An integrating’ SLM
is preferred for
this
type
of measurement).
The
octave
band-filters
in
the
Model
2900B
Real
Time
Analyzer
meet
the
Noise Solutions by
Greg Zak
,
Noise
Report

7
requirements of IEC 225
and
ANSI S1.11-1985.
The microphone and pre-amplifier
were mounted
on
a tripod
-
and separated from the analyzerby a 10-foot cable.
Calibration was performed using a
Larson-Davis
Laboratories
Model
250
calibrator that
meets
the
Type
1
requirements for acoustical calibrators.
Calibration was performed before
and after the measurements, and did
not vary by more
than
0.1
dB.
The measurements
were performed
in accordance with applicable American
National Standards.
The Larson-Davis Laboratories
the factory
-
for
calibration
in
Attachment B,
2 pages).
Model
250
November
calibrator and
Model 2900B
Real Time Analyzer were returned
to
and
December
of
2002
(see
copies
of
Calibration
Certificates,
Photograph taken at Site
1
with camera pointed east toward Ameren Elgin Facility (see Attachment A, Map).
PHOTOGRAPH 2
Photograph taken on east side of Gifford Road with camera
pointed toward the west at Site
Diagram ofFacility.
See Attachment A,
I i-i-u iuu.i~~.i-’H
1
Noise Solutions by Greg Zak
Noise Report

8
IV.
RESULTS
AND DISCUSSION
The sound
study
objectives were to
determine by
field measurement the current noise daytime
and
nighttime
ambient levels, the operational levels with
all of the peakers running and compare
those levels to
the
State of
Illinois noise regulations.
The results
from
this measurement
period are found at
Table
1,
row 4:,
“10
minute
Leg
Ambient.”
A brief
explanation of what
is
meant
by
the
measurement of a
10-minute
Leg
ambient
is
in
order
here.
The term
ambient refers to
all of the sound in the area, except for extraneous sound and
any sound emanating from the
Ameren Facility.
Extraneous sound is ofrelatively short duration and comes and goes, such as vehicle passbys,
aircraft
flyovers, train whistles,
and so forth.
The measurement instrumentation is
put in a
“pause mode”
to
-
avoid
including
extraneous
sound
during
measurement.
It
should
be
noted
that
the
same
exclusion
of
extraneous noise is used to measure the sound levels produced by the noise source of interest (Ameren Facility).
The term
“Leg”
is
defined in
the Board’s noise regulations
and
in this
context means
that the
sound
is
energy
averaged
over
a period
of 600
seconds (10 minutes).
The ten minutes referenced
here- are a
composite of all
“chunks oftime” within the 30-minute time span (9 to 9:30 PM) -that were previously defined as ambient.
Once the datawas collected, we also compared
the results with the measurements obtained
by Power Acoustics,
Inc.
on June
17, 2003.
At that time, just one unit was operating
at full load and an extrapolation ofthat data was
performed by Power Acoustics,
Inc.
to
simulate 4
units
at full operational
load.
The
sound
pressure
levels
contained
in
the
Power
Acoustics,
Inc.
(PAT)
report
are
found
at
Rows
1
and
2
of
Table
1,
and
the
measurements obtained by Noise Solutions by Greg Zak (ZAK) are shown in Rows 3 through 6.
Row
1,
which
is Table
9
of the
PAT report, shows
extrapolated data from actual measurements (10 minute
Leg)
taken ofUnit 4 and projected to
include Units
1
through
3 to
arrive at an estimated sound
level maximum.
Row
2
contains ambient measurements taken on
June
17 that are shown
in
the PAl report at
its
Table
6.
The ZAK
data in Row
3
describes a
10-minute
Leg,
without corrections, measured on
September 2
when the
facility was
fully operational.
Row 4
represents an
ambient -10-minute
Leg measurement which
shows little
deviation
from
the PAT data, until the high frequency octave bands were
measured.
The sound levels we recorded were generally lower than or near the numerical limits
extrapolated by the June
Power Acoustics
report.
For example,
the levels at the
31.5
Hz
octave
band
were
5
decibels
lower than the
Power Acoustics’
number of 78.4, i.e.,
73.4
decibels
(the nighttime
standard
is
69 dB).
However, at the 2000
Hz
octave
band,
the
noise
level
was
measured
at
2.4
decibels
higher
than
projected
by
Power
Acoustics.
Therefore,
this results in sound levels approximately 20 decibels over the nighttime standard.
See Table
1.
The
comparison
documents
a
significant
difference
in
decibel
levels
at
the
4000
Hz
and
at
8000
Hz.
The
difference of 15
dB higher at
4000
Hz and
20
dB
higher at
8000 Hz
is
largely due
to
excessive insect sounds
that were
unavoidable during
the measurement period.
We surmise
that
when PAl
took
its
measurements
in
June, 2003,
this property, including
the measurement location, was
not yet bordered by an overgrowth of thick
weeds and brush that are conducive to the harboring of a variety of insects.
This overgrown and
insect-infested
area was
to
the west of the microphone
during
the ZAK ambient measurement period
and
would
account for
these high readings.
When
the
ZAK
corrected
-
levels
in
Row
5
are
compared
to
the
levels
obtained
by
PAl,
the
operational
measurements at full
capacity are considerably
lower, with
the exception of 2000 Hz.
The PAl projection was
53.2
dB, whilethe
ZAK measurement was
55.6
dB,
a difference of 2.4
dB.
It must be
borne
in
mind that the
Noise Solutions by
Greg Zak
-
-
Noise
Report

9
PAT data represents a projection
from
the
actual measurement of
1
unit running
to the theoretical
sound levels
for all
4
units.
It
has been my experience that
only a 2.4
dB
difference between
extrapolated
data and
actual
measurements
falls
well
within
the
many
sources
of potential
error
in
making
an
extrapolation
from
the
measurement of one running
unit to
the actual measurement of 4 units,
each with its
own subtle characteristics
even though they consist ofthe same modern construction and model of unit.
Finally,
we compared Ameren’s requested
site-specific noise emission
limitations
for their Elgin
Facility with
a
portion of the Board’s
current
limits
listed
in
Table
1.
This
comparison demonstrates
that
the
limitations
proposed in this rulemaking are not significant.
At
the
31.5
Hz octave
band,
the
80
dB
limitation requested
is
equal to
the current limit for “Industrial
Noise
Commercial Receiver Limits”, that is,
C to B
land use, at Section 901.103
ofthe Board’s rules.
The limitations
requested at
63 Hz through 500 Hz are equal
to the “Industrial Noise to
Residential Receiver Limits”,
that
is
C
to A land use, at Section
901.102a ofthe Board’s rules,
and are considerably below the C to
B land use limits of
Section
901.103.
At
the
1000
Hz
level,
the
58
dB
limitation proposed
is
only
1
dB
higher than the
57
dB
allowed under the limits for C to
B land use.
At 2000 Hz, the 58 dB
limitation, while exceeding the C to
B land
use by
6
dB, would not
significantly penetrate a house with the windows
closed during
periods of very hot or
cold weather.
At the 4000 Hz level, the
50 dB
limitation, while exceeding the
C to B
land use by 2
dB, would
not
significantly
exceed
the
levels frequently
generated by
crickets,
locusts,
and
other insects.
Additionally,
4000 Hz is
even less
able to penetrate a house with closed windows than is 2000
Hz.
At
the 8000 Hz level, the
proposed 40
dB
limitation is
equal to the present
Section
901.1 02a limit, and 5
dB lower than C
to
B land use
limits.
When
ambient levels fall ten or more decibels below
the noise
source,
there is
no
correction needed.
This
is
because the actual correction is less than 0.5
dB, which is lost in the rounding process.
Ambient levels, within
3
dB
or less ofthe levels measured for a noise sOurce, call
for assigning a zero to
any octave band measurements,
meeting this criteria per the ANSI standards.
The corrections
made for ambient effects are illustrated
in
Table
1,
row
5.
It
should
be
noted
that
4K Hz
and
8K
Hz
ambient
levels
are within
3
dB
or
less
of the
levels
measured for the Ameren Elgin Facility, thus
these two octave bands are assigned a zero.
The measured data was compared to
the applicable
Illinois noise regulations,
in the case ofthis
study,
Sections
901.102
(C -~A)and 901.103
(C -~B)
ofthe Board’s regulations.
Noise Solutions
by
Greg Zak
-
Noise Report

10
V.
CONCLUSIONS AND RECOMMENDATIONS
It
is
concluded
with
a
reasonable
degree of scientific
certainty
that
noise
emissions
from
the Ameren
Elgin
Facility’s
four
peaker
units
will
exceed
the allowable
limits
of Section
90l.lO2b
of Title
35,
Sub-Title
H,
Chapter I of the Illinois Administrative Code (Illinois Noise Regulations) at the Realen property if that property
is developed residentially.
-
-
In
order
to
avoid- exceeding
the
numerical
limits
at
Section
901.1 02b
for
Class C-)~Class
A
and
Section
901.103
for Class C-~ClassB
listed
in
Table
1,
our recommendation would be
for the Ameren Elgin Facility to
pursue a
Site Specific
Rule change with
the Illinois
Pollution
Control
Board.
This
recommendation
is
based
upon the comparison of the Board’s existing
noise limitations
which may apply at the Realen
property and
the
minimum noise limitations considered necessary for Ameren
to comply with if the Realen property is developed
-
residentially.
In our opinion,
that
comparison
demonstrates
that
the difference
in
the between the
two
sets of
numerical
limits
is
not
significant.
Furthermore,
the
likelihood
of noise
complaints
based
upon
the
noise
emissions
from
the Ameren
Elgin
Facility is
remote due in
large part
to
the high
levels of extraneous noise in
-
the
area of the
this
Facility.
Finally,
for the
purposes
of continuity,
we
also
recommend
that
site
specific
numerical values be proposed for Class
B
receiving
lands
so
those
limitations
conform the Class
A limitations
requested by Ameren.
-
-
cc4ld
-
Greg Zak, MA,
INCE
Member,
-
-
-
Institute ofNoise Control Engineering
Noise Solutions
by Greg Zak
Noise Report

CH2\
1060118.1
TABLE 1
-11
MEASURED
AND
EXTRAPOLATED SOUND PRESSURE LEVELS FOR
AMEREN
ELGIN
UNITS 1,2,3
AND
4, LOCATED AT L-R2 ON GIFFORD 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)
PAT’
Table 9, Extrapolated
Total
6-20
78.4
71.8
63.5
md
-
md
55.0
53.2
45.7
31.9
---
PAl’
Table 6, Ambient
6-17
58.1
59.6
55.2
48.3
46.9
45.9
40.7
33.7
22.1
---
ZAK2
Raw
10 minute
Leg
at
447 MW
9-2
73.4
66.5
62.6
57.0
53.0
53.4
55.6
49.2
42.4
60.1
ZAK2
lOminuteLeg
Ambient
9-2
59.2
59.6
54.8
49.7
49.2
44.6
44.4
48.7
42.3
53.7
ZAK2
Corrected 10 minute
Leg
at 447 MW
-
9-2
73.4
65.5
61.9
56.0
50.7
52.7
55.6
-
0
0
58.8
ZAK2
Corrected and
rounded
10 minute
Leg_at 447 MW
9-2
73
66
-
62
56
-
51
53
56
0
0
59
,
Ii
Daytime Class
A
and
DuPageCo.
---
75
74
69
64
58
52
,
47
43
-
40
---
Il Nighttime
Class A
and DuPage Co.
---
69
67
62
-
54~
47
41
36
32
32
---
Cook County Ml
to A
---
72
71
65
57
51
45
39
34
32
---
-
901.103 C
-~
B
---
80
79
74
69
63
57
52
48
45
---
Site Specific Rule
Requested
C
-~
A
---
80
74
69
64
58
58
58
50
40
---
-
Site
Specific Rule
Requested C
-~
B
---
80
79
74
69
63
58
58
50
45
---
Noise Solutions
by, Greg
Zak
Noise
Report

MAP

Back to top


ATTACHMENT A
~~
r
~
I
~-,
~
XE
Location
of
microphone
on September
2,
2003
I
___________________________________________________
I

Larson Davis
~2559
Larson Davis
2900
Schaevilz
P3061
-1 5PSI
Hewlett Packard
34401A
Hewlett Packard
34401A
Larson Davis
MTS10001~1
Larson Davis
PRM9O2
Larson
Davis
j~~915
2504
12 Monthr~()3f~2~’)3
0661
12 Months
04.V512003
17590
12 Months
04/1712003
3146A10352
12 Months
0~l7/2O03
US36033460
12
Months
08/22/2003
0111
l2Moritfls
09112P2003
0480
12 Months
09/17/2003
0112
-
12 Months
108)4/2003
10476-1
2002~0630
~890
230848
243025
09121-2002
2002~3989
Relative Humidity: 24
Affirmations
This
Certificate
attests that
thIs instrument
has been
calibrated
under
the
slated
conditions
with Measurement
and
Test
equipment
(M&TE) Standards
traceable to
the
U.S.
National
Institute
of
Standards
and
Technology
(NIST).
All
of
the
Measurement Standardshave been calibrated
to their manufacturers’ specified accuracy
I
uncertainty.
Evidence of traceability
and
accuracy is
or,
fits at
Corporate
Headquarters.
An
acceptable
accuracy ratio
between the
Standard(s)
and
the item
calibrated has been rnalntamed.
This instrument meets or exceeds themanufaciure?s
publishedspecification unless noted.
This
calibration complies with the
requirements of ISO 17025
and ANSI Z540.
The collective uncertainty
of
the Measurement
Standard used does notexceed 25
of
the applicable tolerancefor each characteristic calibrated unless otherwisenoted.
Due to
state-of-the-art lImitations,
4:1
calIbration
ratios
are not possible
on
pressure measurraTrent standards,
microphones
and acoustic Calibrators.
Calibration ratios for thesetypes ofdevices
are
limited toil.
-The
results
documented
in
this
certificate
relate
only
to
the
item(s)
calibrated
or
tested.
A
one
year
calibration
Is
recommended, however calibration
interval assignment and adjustment
are the responsibility
of
the end
user.
This certificate
may not
be reproduced, except
in
full, without the written approval
of
the
issuer.
Before:
114.02
dB,
250.0 Hz ~
1013 mbar.
Afler
114.02dB,
250.0
Hz
~
1013
fiber.
Technician:
Scott
Montgomery
Service
Ceriter
Larson Davis Laboratories. Utah

Back to top


ATTACHMENT- B
Certificate
of Calibration
and Conformance
Certificate Number
2002-45865
Instrument
Model CAL25O,
Serial
Number 0761,
was
calibrated
on
11-22-2002.
The instrument meets factory specifications per Procedure D0001.8192.
Instrument
found to be in calibration as
received: YES
Date Calibrated:
11-22-2002
Calibration due:
11-22-2003
MANUFACTURER
MODEL
Calibration Standards
Used
SERIAL
NUMBER
INTERVAL
CAL
DUE
-
TRAcEABILrrV
N0
Reference Standards are
traceable
to
the National
Institute of Standards and Technology
(14151)
Calibration Environmental Conditions
Temperature:
22
Centigrade
820
140,5
-
Pveo.
Lit~h
-
84601
-
Phone
801)
375-0177
(
4:-~’
/

ATTACHMENT B
Certificate of Calibration and Conformance
Certificate Number 2002-46556
Instrument
Model
2900,
Serial
Number 1070. was
calibrated
on
12-18-2002. The
instrument
meets
factory
specifications
per
Procedure
00001.8146,
ANSI S1.11
1986,
ANSI 81.4
1983,
-
1EC651-Typel
1979,
and
IEC 804-Type
11985,
1EC1043 Class
1
wt’ien normalized.
-
Instrumentfound to be in calibration as received: YES
Date
Calibrated: 12-18-2002
Calibration due: 12-18-~20O3
Calibration
Standards
Used
MANUFACTURER
MODEL
SERIAL
NUMBER
INTERVAL CAL DUE
TRACEABILITY
NO.
I
Larson
Davis
I
LDS~(3n,2~
I
0617/0104
12Months
OlI31I~
~-~473
Reference
Stisidardsare traceable tothe National Institute
of
Standardsand Technology (141ST)
Calibration Environmental Conditions
Temperature:
22
Centigrade
Relative Humidity: 26
Affirmations
This
Certificate
attests that this instrument
has
been calibrated
under the
stated
conditions
with
Measurement arid Test
Eqthprneitt
(M&TE)
Standards traceable to the U.S.
National
Institute
of
Standards and Technology (14151).
All
oil
the
Measrsrnent
Standards trase been calibrated totheir n,anufactiirws specifiedaccuracy! uncertainty.
Evidence of traceability
and accuracy
Is
on The
at Corporate
Headquarters.
An
acceptable accuracy
ratio between the Standard(s) and the
item
calibrated has been maintained.
Thisinstrument medsorexceeds themanufacturer’s published specification terleas noted.
This calibrator, complies
with the requirements
of
ISO
17025 arid
ANSI Z540.
Thecollective
uncertainty
of
the Measurement
Standard used does notexceed
25
of
the applicable tolerance for each characteristic calibrated
unless otherwise noted.
Due to state.ot-the-azt limitatIons,
41
calIbration
ratios
are
not
possible on prmmte messinernent standards,
microphones
and acoustic calibrators.
Calibration ratios for these tyeesof devicesare limited
to
1:1.
The
results
docurnenled
in
this
certificate
relate
only
to the Item(s)
calibrated
or
tested.
A
one
year
calibration
is
recommended, liceevercalibration interest assignment end adjustment
are the responsibility
of
the end user.
This certificate
may
notbe reproduced,
except in (Ut,
withoutthe writtenapproval ofthe issuer.
Pot
receiveddata billie sameasshipped
data.
ri-
Technician: Brent Heaton
Service Center~
Larson DavIs Laboratories.
tibeT
Signed:
~
-
1681 Was
820
NorW
P1000.
LISt~-
84801
-
Phone (401) 375.0177

RECEWED
CLERKrS
OFFICE
NoIsE
SoLuTIoNs
BY
GREG Z~K
42003
-
36
BIRCH DRIVE
-
STATE OF ILLINOIS
CHATHAM, ILLINOIS 62629
pollutIon
Control Board
(217)483-3507
-
-
(217) 483-5667-FAX
-
e-mail: 2re2zak(~justice.com
Greg Zak, INCE
-
RESUME
EXPERIENCE
Greg Zak has over 31
years of experience dealing with noise
measurement, noise control engineering
and the
effects of noise
on people and communities. He established Noise Solutions
by Greg
Zak
in
March of 2001,
which has become
a full time activity since August
1, 2001.
Since
its inception, Noise
Solutions by Greg Zak
has served 41
clients from the power industry,
government, as well as private citizens.
Currently, Greg Zak has
appeared
before
the
Illinois
Pollution
Control
Board
as
a
private
noise
consultant
recognized
as
an
expert
witness.
In the past,
he
has acted
as
the- Illinois
Environmental Protection Agency’s noise
expert in nearly all
enforcement and regulatory hearings before the
Illinois Pollution Control Board, and in several Illinois Circuit
Court hearings related to noise zoning and
nuisance. His experience includes industrial, commercial,
residential,
urban,
rural
and
construction
noise.
He
represented
the
Illinois
EPA,
as
the
EPA’s
Noise
Expert,
when
testifying
before the
Illinois
Pollution
Control
Board’s hearings
captioned “NATURAL
GAS
FIRED,
PEAK-
LOAD ELECTRICAL POWER GENERATING FACILITIES (PEAKER PLANTS)”, PCB ROl-lO, -August 23,
2000 and
October
5,
2000.
-
He has been
a member of a
Society
of Automotive
Engineering Committee,
and
is
currently
a member ofthe
American National Standards Institute Working
Group
on
the
Measurement
and
Evaluation
of
Outdoor
Community Noise.
He was selected
by
Governor Edgar to
sit
on
the Blasting
Task Force
mandated by
House
Joint Resolution 133 and chaired
by the Illinois Department ofNatural Resources.
Noise
issues
dealt
with
have frequently
involved
the technical
practicability and
economic
reasonableness of
reducing or eliminating the noise
emissions
from
the
source.
The ability to
work
with
the
public,
elected and
appointed
officials,
and
consultants
has been
a hallmark of Greg
Zak’s noise
program at
IEPA.
The
needs
of
both
the
Agency
and
the
public
have
been
carefully
balanced.
Thousands
of
Illinois
residents
with
noise
complaints have been assisted through his
self-help program.
-
-
As
a
national
and
international
author
in
the area of environmental
noise,
Greg Zak
has presented papers
on
controlling noise at national and
international noise conferences.
He is 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 ofEnvironmental Sound
--
Part
5:
Sound Level Descriptors
For Determination of
CompatibleLand Use,ANSI S12.9-199x--Part
5.
Greg Zak has passed the required written examination,
and
has been elected
a member in
good
standing by the
Officers
and
Board
of
Directors
of
the
Institute
of Noise
Control
Engineering
(INCE).
Sat
for
INCE

Greg Zak Resume’
7-29-03
-
2
Membership Exam on’December
14,
1995.
Received letter of notification of acceptance
for membership
from
the-President ofINCE dated
January
12, 1996.
-
CHRONOLOGY OF EXPERIENCE
-
IEPA
Noise Advisor
14+ years
Responsible for the I.E.P.A. Noise Program. Responsibilities included:
-
1) noise
control efforts in the solid waste area
and
assisting citizens with noise complaints.
Technical assistance
for federal,
state,
and
local governments
to
establish the degree of (or lack of) compliance
with Illinois
Noise
Regulations;
2) making noise
control engineering recommendations
for abating noise
emissions
for federal,
state,
and
local
governments;
-
3) working with
both solid waste sites,
and manufacturers of acoustical materials and devices,
to
insure system
compatibility and obtain the desired noise reduction;
-
-
-
4) assisting the public with
a self-help procedure to obtain relief from various noise pollution sources (3000
to
4000 phone calls annually);
5)
Advising counties and cities in the process ofdeveloping noise ordinances and noise
measurement standards
(provided classroom
instruction
for the
Will
County Sheriffs Department
in
July
‘99, and
for the Taylorville
Police Dept. in Jan. ‘98);
-
-
6) Answering questions from
industry,
consultants,
and
legislators,
as to
how
the various
noise
regulations
apply in different situations;
7) Advising
the State
Police, Crime
Lab on
measuring noise
from
guns equipped-with
silencers and
taking the
measurements for the lab;
-
8)
Testifying
under
subpoena
as
an
expert, numerous
times,
in
environmental
noise
in
enforcement
cases,
variance
hearings,
and
regulatory
hearings
before
the
Illinois
Pollution
Control
Board.
Testifying
under
subpoena
as an
expert, numerous
times,
in
environmental
noise
in
enforcement
and
zoning
cases
before
an
Illinois
Circuit
Court.
Addressing environmental
noise
issues
in
zoning
cases
before county zoning boards
at
their request.
Below is a partial list of recent noise
hearings in which Greg Zak qualified as an
expert witness:
-Pollution Control Board
(ENFORCEMENT)
PCB 00-140, Knox v. Turns Coal Company, June 11,
2002.
PCB00-163, McDonough v. Robke (carwash),November 13, 2001.
PCB 00-2 19, Brill
v. Latoria d/b/a TL Trucking Foodliner, September 26, 2001.
PCB 00-221,
Glasgow, et.
a!. v.
Granite City Steel, July
10
&
11,2001.
PCB 00-90, Young v.
Gilster-Mary Lee Corporation, April
10, 2001.
-
PCB 99-19, Roti, et.
al. v. LTD Commodities, Inc., November 2,
1999.
PCB 98-8 1, Cohen, et. al. v. Overland Trucking,May 13, 1998.
PCB 96-110, Sara Scarpino & Margaret Scarpino v.
Henry Pratt Company, October
11,
& July
19,
1996.
PCB 96-53, David and Susi Shelton v. Steven and Nancy
Crown, August 21,
& July 3,
1996.
PCB 93-15, Dorothy & Michael Furlan
v. University ofIllinois School ofMedicine, July 29,
1996.
PCB 96-22, Lew & PatriciaD’Souza v. Richard & Joanne Marraccini, December 12, 1995.
PCB 94-146, DorothyHoffman v. City ofColumbia, Illinois, December 11, 1995.
PCB 90-146, Village ofMatteson v. World Music Theatre et al., July 27, 1992.
PCB
91-195,
Thomas
v.
Carry Companies of Illinois, Inc., July 22,
1992.
PCB 9 1-50, Christ v. Compost Enterprises, Inc., June 2,
1992.
PCB 90-182, Tex
v. Coggeshall, et al., January 9,
1992.
-

Greg Zak Resume’
7-29-03
-
-
3
PCB 91-30,
Curtis, Diesing,
Vii.
Crystal Lake
v. Material Service Corp.,
Vii. of Lake
in the
Hills,
December 17& 18, 1991.
-
PCB 90-149, Moody
& Madoux v. Strader’s Logging
& Lumber, 6-27-91.
PCB 90-148, Moody & Madoux v. B&M Steel Service, June 26, 1991.
PCB
90-59,
Christianson v. American Milling Company, 6-27 &
9-6-90.
-
PCB 90-108, Stratton
v. Little Caesar’s Pizza, August 30, 1990.
PCB 89-169,
Zarlenga v. Partnerships Concepts, et a!., July
7 &
24,
1990.
PCB 89-205, Zivoli v. Prospect Dive
and Sport Shop, June 14, 1990.
-
PCB 89-179, Martin v. OakValley Wood Products, Inc., 2-2& 4-6-90.
PCB 88-171, Hagan v. Brainard, January 17,19-89.
PCB 87-171, Moore v. Archer Daniels Midland, August
5
&
29,
1988.
-
PCB
87-139, Annino
v. Browning Ferris Industries, Jan. 13,
1988.
-
U.S.
Bankruptcy Court,
Northern Dist.
Ill., East. Div., Case # 91 B 11678, (re. One B!oomingdaie Place,
PCB92-178)
-
Testimony, January 3, 4, & 28, 1994; Deposition,
January20 & 21,
1994.
-
-
Deposition, January
5,
1993; Testimony, June 29,
1993.
-
Pollution Control Board (RULEMAKING);
R91-25,
Amendments to.
35
I.A.C.
Subtitle H: Noise
-
Pertaining to Definitions,
Measurement Procedures,
and Sound Emission Standards Relating to
Certain Noise Sources.-- November 25
& 26,
1991.
Pollution
Control Board
(VARIANCE);
-PCB
88-188, Shell Oil, September 18, 1990.
-
Circuit
Court (ENFORCEMENT);
98-CH-16, People v.
Bobby-T’s, Inc., Mason County, October
13,
1999.
-
-
91-CH-242, People v. Watts
(Sangamon Valley Landfill), Sangamon County.
Deposition, October 15,
1993
;
Testimony, December
19,
1993.
-
-~
93-CH-230, People v. Metro Ice Company, Inc., St. Clair County, October 14, 1993.
-
88-L-35, Lang v. Rangemasters Pistol
Club, Williamson County, December 4,
6,
&
12,
1990.
-
Circuit
Court (ZONING);
-
89-L-95, Brown v. White, Adams County, Re. Factory noise, June 4
& 5,
1990.
89-CH-23, Lambrecht v. Will County, Re.
Limestone
quarry development, February 22,
1990.
86-CH-22,
Anderson v. CityofEffingham, Effingham County, Re. Truck stop, July 25, 1988.
-
-
County Zoning Board (ZONING)
At the request of local
authorities, Greg Zak testified regarding deficiencies
in
the
noise
study
and
report
prepared by INDECK for Petition No.
99-04, Public Hearing, McHenry County Zoning Board ofAppeals,
INDECK Request for a Conditional Use Permit
to
Allow the Construction
and
Operation
of an
Electrical
Generating Facility (gas turbine), April 16,
1999.
-
Petition No. 96-61, Construction & Operation of a Gravel Pit in McHenry County, March 27, & April
8,
1997.
City Planning Commission
(ZONING);
-
Hoffman Estates, residents v. Tyre Works, Inc., July 7, 1999.
Hoffman
Estates, residents v.
Tyre Works, Inc., June 19,
1996.
-
Effingham,
Anderson v. Petro, Re. truck
stop, April
6,
1989.
Below
is
a
partial
list
of
Pollution
Control Board
noise
hearings
in
which
Greg
Zak
was
involved
as
a
consultant
in resolving the conflict:
-
PCB 98-18, Metz, et.
al. v. U.S.
Postal
Service and
Bradley Real Estate,
Springfield, September
1, 2000.
PCB 98-84,
Behrmann
v.
Okawville Farmers Elevator-St. Libory, February 4,
1999.
PCB 96-20, Norman,
et. al.
v.
U.S.
Postal Service, Barrington,
January 2,
1997.

Greg Zak Resume’
-
7-29-03
-
4
-
PCB 96-69, Coming
v. Hegji, June 20,
1996.
-
PCB 92-38, Howard v. Caterpillar, Inc.,
September 3,
1992.
PCB 90-146, Village ofMatteson v. World Music Theatre et al., July 27,
1992.
-
-
PCB 90-201, Dravis v.M& D AG, April 29, 1992.
PCB
9 1-128, Druen v. Leonard, January 30,
1992.
PCB 89-44, Western v. Moline Corporation, October, 1991.
-
-
PCB 90-145, Corner v. GallatiñNational Balefill, September 3, 1991.
PCB
91-51,
Collins v. Roberts Fish & Food, June 14,
1991.
PCB 89-168, Daidone et a!. v.
Lexington Square, January 19,
1990.
-
PCB 88-199, People ofthe State of Illinois v.
Seegers Grain,
Inc., MarchlApril,
1989.
-
ACOUSTICAL SOCIETY OF AMERICA
-
-
-
Currently a member ofthe Model Ordinance Working Group, that is in the process ofdeveloping procedures for
-
regulating community noise.
-
-
ANSI COMMITTEE
Currently a member on the American National Standards Institute Working Group on the Measurement and
-
Evaluation of Outdoor Community Noise (S12-15).
SAE COMMITTEE.
-
Served as a member of the Society ofAutomotive Engineers Construction
Site Sound Level
Committee,
S.-A.E.
ConAg Committee (10-7-92 to
2-25-93).
-
INTERGOVERNMENTAL PROJECTS
City of Taylorville, Illinois,
in
1997-8, input was provided to
the City Attorney regarding how to
simplify the
state noise regulations
for inclusion into a local ordinance.
Noise monitoring equipment recommendations were
given
to
the Chief of Police.
A
seminar was given
to
the patrolmen
based
on
the newly
adopted ordinance,
equipment purchased, and measurement procedures used by the Illinois EPA. A written exam was prepared and
administered to all
attendees.
-
Illinois
State
Police,
in
1997,
noise
measurements
of
gunfire
were
taken
at
the
Chicago
lab.
These
measurements established that abatement
recommendations
totalling
approximately $30,000
were
successfully
implemented
at the Chicago lab after plans
for
3
shooting rooms
in the Lab
under construction
were reviewed
and
recommendations -were
made
to
minimize
gunfire
noise
impact
for areas
not
originally
designed
as
a
shooting
area (1996).
Noise
abatement
recommendations
totalling
approximately
$10,000
were
successfully
implemented
at the Springfield lab (1993), and
$8,000
at the Morton
lab (1995). Measured
gunfire noise
at the
forensic labs in
Springfield, Metro-East, Morton, Joliet, Carbondale,
and Rockford
for potential hearing damage
(1992-95).
-
-
-
-
-
Illinois Department of Conservation,
Reviewed plans
for shooting range (Des Plaines Range)
in Will
County
and
met with
design
engineers
to
suggest noise
abatement strategy (3-4-93).
Conducted a one
day
seminar for

Greg Zak Resume’
7-29-03
5
Conservation Police Officers on how to use
a
sound
level
meter
to measure boat
noise
to
enforce
the newly
enacted noise regulations for watercraft (7-2-92).
Illinois Department ofNuclear
Safety, Low Level Nuclear Waste Sites, reviewed, suggested changes, and met
with developers regarding
needed modifications
to
comply with Noise Regulations,
11-1-90.
Illinois Department of Agriculture,
measured noise emission levels from
HVAC and
emergency generator
at
headquarters,
submitted
detailed
noise
control
engineering
plans
to
mitigate
complaints
from
neighbors.
Attended several
meetings
and
assisted
the
Capital
Development
Board
with
technical
details
of solution.
Noise problems were solved, 6-1-90.
Illinois
Department
of Commerce
and
Community
Affairs,
reyiewed
and
suggested
changes
for plans
to
comply with Noise Regulations
fOr:
1.
proposed Toyo
Koki
plant,
5-26-89;
and
2.
proposed
UPS
facility in
Willow Springs, 5-4-89.
-
Illinois
Attorney
General.
Visited
K-5
Asphalt
Plant
in
DuPage
county
at
invitation
of,
and
with
representatives
of AG
to
make
recommendations
to
mitigate
noise
problems
(6-22-92).
Written
opinion
for
Howard Chinn, ChiefEngineer, on measuring
gunfire
noise on Fast meter response versus Leq
(52089).
Reviewed
detailed
1987-8 blasting
noise
and
vibration
study
at
Columbia
Quarry
in
Columbia.
Suggested
procedural changes in blasting protocol to minimize complaints from neighbors (4-7-89).
Noise measurements at Mervis
Industries
in
Danville with
a representative ofthe Attorney -General’s
Office,
along with consultant
and
attorney for Mervis regarding a pending enforcement action (7-15-88).
-
-
CHRONOLOGY OF PUBLISHED WRITINGS
Acknowledged
for
assistance
and
input,
as a
member of the
Blasting
Task
Force
in
the publication
entitled,
“Blasting Task Force Final Report, House Joint Resolution
133,
May, 1997.”
Acknowledged
for assistance
and input, as a member of the Working Group,
into ANSI S12.9-199x/Part
5
by
Dr. Paul D.
Schorner, Chairman ofthe Accredited Standards Committee entitled, “Quantities and Procedures for
Description and Measurement ofEnvironmental Sound
-
Part 5:
Sound Level Descriptors
For Determination of
Compatible Land Use, March,
1997.”
Acknowledged for assistance and input into; an
article prepared for the Construction Safety Council ofChicago
by Don Garvey, CIH, CSP, entitled,
“Community Noise Regulations,
1997.”
Acknowledged for assistance and
input,
as
a
member of the Working Group,
into ANSI
S 12.9-1996/Part 4
by
-
Dr.
Paul
D.
Schomer,
Vice
Chairman
of
the
Accredited
Standards
Committee
entitled,
“Quantities
and
Procedures
for Description and
Measurement of Environmental
Sound
-
Part
4.
Assessment Methods,
January,
1996.”
Acknowledged
for
assistance
and
input
into;
two
reports/studies prepared
for
the
Illinois
Pollution
Control
Board
by
Dr.
Paul
Schomer entitled,
“Impulse Noise
Study,
December
1990,”
and
-“Proposed
Revisions
to
Property-Line-Noise-Source Measurement Procedures, June
1991
.“
-

Greg Zak Resume’
7-29-03
NOISE
CONTROL AT THREE HAZARDOUS/TOXIC
WASTE
CLEANUP
AND INCINERATION SITES
IN ILLINOIS USA. Presented at INTER-NOISE 89 (International Noise Conference) in Newport Beach, Calif.
December
5,
1989. Published in the INTER-NOISE 89 PROCEEDINGS.
Co-author
of,
“Illinois’
Experience
in
Tracking
Hazardous
Waste
Activities Through
Manifests
and
Annual
Reports”
presented
at
the
HAZPRO
PROFESSIONAL
SYMPOSIUM
in
Baltimore,
Maryland
on
May
16,
1985.
-
ESTABLISHMENT
OF
A
CALIBRATION
LABORATORY
FOR
THE
ILLINOIS
ENVIRONMENTAL
PROTECTION AGENCY, DIVISION
OF NOISE
POLLUTION CONTROL, presented at the National Noise
and
Vibration
Control
Conference
and
Exhibition,
April
1979,
and
published
in
the
1979
NOISEXPO
PROCEEDINGS.
Contributing
author
of Insertion
Loss
(or Gain)
of Windscreens
presented at
1978
Society of Automotive
Engineers Conference and published in Society ofAutomotive Engineers Proceedings.
Acknowledged for assistance and
input
into;
The Transfer Function of Quarry Blast Noise
and Vibration
into
Typical Residential
Structures, February
1977, prepared by Kamperman
& Associates, Inc.
under Contract 68-
01-4134
for the U.S.
Environmental
Protection Agency
Office of Noise Abatement
and
Control, Washington
D.C., 20460.
-
Performed
the
function
of Technical
Reviewer
for
the
U.S.
Department
of the
Interior,
Bureau
of Mines,
manuscript titled;
-“Blast Noise Annoys.” (1976)
Co-author of, “Quarry Blasting and
the Neighbors” presented at Inter-Noise
76
in
Washington D.C.
on April 6,
1976.
Acknowledged for assistance and
input into;
“Quarry Blast Noise Study”
by Kamperman & Associates,
Inc.
for
the Illinois Institute for Environmental Quality, December,
1975.
Acknowledged
for
assistance
and
input
into;
Blast Noise
Standards
and
Instrumentation,
Bureau
of Mines
Environmental Research Program Technical Progress Report 78,
May 1974, U.S. Department of the Interior.
Co-author of,
Comparison ofNoise Levels and
Citizen Complaints
presented at Inter-Noise 74
in
Washington
D.C.,
1974.
IEPA
Compliance Assurance Unit Manager
5 years
Responsible
for
the
supervision
of
sub-unit
managers
(2).
The
scope
of
responsibility
covered
insuring
compliance
by
all
facilities
required
to:
1)
report
ground
water monitoring
data;
2) report
on
underground
injection
control wells;
3)
submit copies of manifests
for individual
shipments of special
waste
(300,000 per
year); 4) issue hauling permits
to
transporters of special
waste;
5)
submit annual reports (10,000) on hazardous
waste
activity;
6)
insure
collection
of
all
fees
due
the
State
for
disposal,
treatment,
injection,
or
hauling
hazardous (special) waste; and 6) insure computer tracking of items
1
through
5.
IEPA Noise Regional
Manager
3 years

Greg
Zak
Resume’
7-29-03
7
Responsible
for
the
supervision
of four
Environmental
Protection
Specialists
and
all
noise
field
operation
activities
in
central
and
southern
Illinois.
Responsible
for
the
calibration,
programming,
and
-
systems
development for all electronic systems
and
transducers.
IEPA
Environmental Protection Specialist I through
III
6 years
Responsible
for investigating
noise
complaints.
Investigation
included in
field interviews of complainants
and
alleged violators,
along with
sound level data gathering using precision sound level
meters and tape-recorders.
Detailed analysis was performed by Greg Zak in the laboratory.
Noise control engineering solutions were drawn
up
to
demonstrate the economic and technical
practicability solving noise problems
in
cases before the Illinois
Pollution Control Board (Board).
-
Meetings
were
held with
alleged violators to
arrive at
an, agreeable program of voluntary compliance with the
Illinois Noise
Regulations.
Technical data was prepared and
submitted
to
the Illinois
Attorney General for use
in
litigation.
-
Acted as the primary Agency representative
during
the
last
3
years
in
various
studies of air blast
and
ground
vibration peculiar to quarrying
and surface mining. In addition to
appearing as an expert witness for the Agency
before the Board, Greg Zak drew up
interim blasting noise and
vibration regulations
and presented these to the
Mining Industry Task Force on Impulsive Noise and
Vibration to which he was a member.
Greg Zak has appeared
as an
expert witness
for the Agency
at
the request -of the Board
as
to
the
acoustic
effectiveness
of the noise
barriers
he
designed
for
the
Terminal
Railroad
Association
of
St.
Louis
in
their
Venice, Illinois Classification
Yard.
-
Greg
Zak
established
a
Calibration
Laboratory
for the
Division
of Noise
Pollution
Control
along
with
the
laboratory
procedures
for insuring
traceability of calibration
work
to
the
National
Bureau
of Standards.
In
addition,
he
was
responsible
for
electronic
checks
to
insure
proper
functioning
of
field
and
laboratory
instrumentation.
-
-
-
-
USMC
Military Electronics Instructor
1
year
Responsible for discipline and
instruction of 30 marine students in basic electronics.
USMC
Radar
Technician
2 years
Responsible for maintenance and repair of several military radar systems.
-
CERTIFICATIONS
He has passed the required written examination,
and in December,
1995
was elected a member in good standing
by
the Officers and Board ofDirectors ofthe Institute of Noise Control Engineering
(INCE).
Sat
for
the
examination
for
certification
by
the
BOARD
OF
HAZARD
CONTROL MANAGEMENT
as
a
CERTIFIED
HAZARDOUS
MATERIALS
MANAGER
on
May
17,
1985.
Received
certification
as
a
CERTIFIED HAZARDOUS MATERIALS MANAGER at the MASTERS LEVEL
(CHMM).

Greg
Zak
Resume’
-
7-29-03
8
-
-
EDUCATION
-
B.S., Biology, SanDiego State University, 1971.
-
-M.A., Public Administration, University ofIllinois at Springfield,
1974.
VETERAN
-
U.S.M.C.,
1963-1966, Radar Technician, Electronics Instructor. Honorably discharged as a Sergeant.
zak\resume.doc
CH2\
1060558.1

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