1. 52-252
      2. 52-259

ILLINOIS
POLLUTION CONTROL BOARD
May
19,
1983
IN THE MATTER OF CHAPTER 8:
NOISE
)
POLLUTION, RULE
206, SITE SPECIFIC
)
OPERATIONAL LEVELS FOR FORGING SHOPS
)
R82—31
Amforge Division of Rockwell
)
Dockets
A,
B,
and C
International
Modern
Drop
Forge
Company,
and
wyman-Gordon
Company
)
IRST
NOTICE.
PR~O~ED
OFIiII(~
OF
THE
BOARD
(by
J.
D.
Dumelle):
On
November
3,
1982,
the Amforge Division
of
Rockwell
International
(Amforge),
Modern
Drop
Forge
Company
(Modern)
and
the Wyman-Gordon Company (Wyman—Gordon) individually petitioned
for site—specific operational
levels for their forging shops,
as alternatives to compliance with the noise limits contained in
Rule 206 of Chapter
8:
Noise Pollution.
All three petitions
were accepted by the Board on November 12, 1982.
By Board Order
Amforge was assigned to Docket A of this proceeding,
Modern to
Docket
B,
and Wyman-Gordon to Docket
C.
That Order also served
to incorporate the record in R76—14,
the general rulemaking on
impulsive noise
from forging shops.
The Illinois Environmental
Protection
Agency
(Agency)
filed
its
Recommendations
on
February
9,
1983,
The
requisite
public
hearings
were
held
in
Rarvey,
Illinois
on
February
15,
1983.
No
members
of
the
public
attended
and
no
public
comments
have been received
on
any of the
three
Dockets.
Each petition was filed pursuant to paragraph
(d) of Rule
206:
Impact Forging Operations,
which was adopted on July 21,
1982 as a part of the R76—14 rulemaking, and became effective on
September 1,
1982.
As indicated above,
Rule 206 contains the
numerical limits
for noise generated by forging shops.
It also
provides an alternative.
Specifically, paragraph
(d) allows an
existing forging shop to petition the Board for a site—specific
operational plan which
in effect will limit the shop’s noise
emism.
sions.
The petitioner, must demonstrate that
it
is technically
and economically impractical
for its shop to meet the numerical
limits.
Each petitioner must not only explain its inability
to
comply with the numerical limits,
but must also propose the means
for reducing impulsive noise as much as possible and assess
the
consequential health and welfare impacts on the surrounding
community.
Paragraph
(d) also sets out the procedural format for
this type of relief.
The petition must include the nine
points
52-251

2
of information delineated in the Rule;
the Agency is to submit a
Recommendation on the petition;
and a public hearing must be held.
For each Docket, all three requirements were satisfied.
Following
is a separate discussion of each Docket,
including
a description of the individual facility, its inability to abate
noise through structural or operational changes, its past abate-
ment efforts, and its proposed plan, if any, to reduce impulsive
noise.
The economic ramifications and acceptability of each
proposed plan are also discussed.
DOCKET
A:
AMFORGE DIVISION OF
ROCKWELL
INTERNATIONAL
The Ainforge complex is located on 119th
Street, between
Loomis and Racine Avenues in Chicago, covering approximately four
city blocks,
or seventeen acres.
Two
buildings, the axle and
hammer shops, house the Arnforge forging operation which
manufactures, among other items,
parts
for the agricultural, off
highway equipment,
trucking,
railroad, and construction industries.
Ainforge has twelve hammers ranging from 3,000 to 12,000 pounds to
manufacture forgings ranging in size from three to three hundred
pounds.
Very simply a forging hammer consists of two dies, each
of which is attached to a guided rain and an anvil.
The metal to
be shaped,
i.e.
forged,
is placed between the ram and anvil.
The
guided.
ram
with its die is then driven against the lower die atop
the anvil.
The impulsive sound is generated by the resulting
impact.
Fifteen furnaces service Ainforge’s hammers, each with
the capacity of heating approximately 5,000 pounds of metal per
hour.
To bring the steel
to forging temperature,
the furnaces
must reach 2,350 to 2,400 degrees Fahrenheit.
(Pet.
3,4 and R.21).
The hammer shop
is forty feet high,
ninety feet wide and one
hundred and seventy feet long.
The axle shop is likewise forty
feet high,
but fifty feet wide and one hundred feet long.
Both
buildings are similarly structured with fiber—glass doors on the
bottom,
windows
above
that, and roofs of corrugated sheet metal.
The
buildings
have
been
designed
to
create
the
“stack
effect”,
that
is natural ventilation of the furnaces’ heat.
Inside air,
heated by the furnaces, induces the outside cooler air into the
building
through
the
multiple
large door openings,
causing air
currents
to
rise
and
exhaust
through
vents
on the roofs.
The
shop’s
noise,
impulsive and otherwise,
is also emitted through
these vents.
The axle and hammer shops were built about
forty years ago.
At that time the surrounding area had few residential houses.
Now,
the areas south and east of the complex are primarily
industrialized,
including a junkyard,
a railroad switching yard
and other noise generating industries.
(Exs.
D
& E).
Only to
the
north
and
west
are
there
residential
properties,
most
of
them
constructed
since
1945.
(Pet.
2,3
and
R.19).
These
residential
areas qualify for Class A protection.
Petitioner estimates,
based
52-252

3
on the daytime noise limits of 58.5 Leq,
that its operation’s
noise levels could affect one hundred and fifty—five residences.
If the nightime level
of 53.5 Leq is used, this number is
increased by four hundred and eighty-eight possibly affected
residences
(Pet.10).
Amforge currently employes 145 persons.
It employed as many
as
600
in
1979.
It can operate three shifts,
six days a week;
that
is
from
7:00
a.m.
until
3:00
p.m.,
3:00
p.m.
until
11:00
p.m.,
and
11:00
p.m.
until
7:00
a.m.
It
has
not,
however,
since
1979
operated
the
third
shift,
and
as
of
January
19,
1983
the
facility
was mothballed for at least six months.
The chart below provides
the approximate number of forgings, the total
tonnage of forgings,
and number of blows creating impulsive noise for the years 1979
through 1981
(Pet.5).
At hearing Amforge added that 10,142 tons
were forged in 1982 and estimated that less than 5,000 tons would
be forged this year.
(R.25).
No.
of
Forgings
No.
of
Tonnage
of
All
On
Hammers
Blows
1979
1,016,744
14,234,416
26,422
1980
698,025
9,772,350
15,806
1981
474,940
6,649,160
14,566
Having monitored its noise
levels in 1980 Amforge represented
that the highest level recorded at nearby residences was
70 Leq.
(Ex.C,
R.27).
In order to reduce this level to that required at
Table
7 of Rule 206,
Amforge investigated three different means
for
abating
the impulsive noise.
The first would have required
that the ground
level openings, the windows,
and the roof vents
be enclosed.
This alternative would have meant that the “stack
effect” of the buildings would he forfeited and replaced with
mechanical ventilation.
Mechanized ventilation would entail
exhaust
fans and silencers placed on the rooftops.
A single fan
and silencer would weigh approximately 2,410 pounds.
(R.37).
Amforge estimated that eight fans with silencers would have to
be installed atop each building.
The cost per ventilator was
estimated at $4,325 apiece, or $69,200 total, while the cost per
silencer was estimated at $2,650 apiece,
or $42,400 total
(Ex.I),
Regardless of cost,
Ainforge did not believe that the rooftops of
either building could support the weight.
(R.37).
In addition to mechanical ventilation, Amforge considered
building barriers outside of the building
to obstruct the noise
emitted
through
the
ground
level
doors.
The
barriers
were
proposed
to
be
one
hundred
to
two
hundred
feet
to
the
north,
west1
and
east
of
the
shops.
Not only do personnel
and
air
move
through
these doors some eighteen feet wide,
hut also materials
to
and
from the operation, e.g.
fuel oil,
steel used
in the operation,
and cooling forgings.
Should the barriers be constructed, A;nforge
testified that they would obstruct these essential movements
thereby impairing the shop’s operations.
(R31-34).
Arnforge also
~52-2~

4
cited testimony given by forge shop workers during the R76-14
rulemaking.
That testimony indicated that should the doors be
closed and barriers be constructed,
the shop employees would
suffer
from
the
furnaces’
heat
and
experience
a
discomforting
effect
from
the
loss
of
natural
light,
which
in
turn
would
greatly
affect
productivity
(R.76—14,
February
23,
1981,
pp.
270—274
and
429—431).
(R..34—35).
Initially the barriers were proposed by
Ainforge’s
noise
e*pert.
Their distance and height from the shop ~‘iere
based on
the
classical diffraction theory for optics.
However, sound
measurements have since indicated that the wind changes the
diffraction patterns
so significantly that the barriers would not
be effective downwind (R.59).
This same phenomena means that
should
the bottom half of the shop be enclosed and the sound
directed upwards through the roof and towards the sky, the wind
could direct the noise waves towards the ground.
Thus the shop
would have to be totally enclosed.
The last alternative considered by Amforge was to pad the
hammers.
Absorbent pads made out of Fabrika, could be placed on
the hammers’ mechanical parts when each individual hammer is
overhauled.
(R.39).
Aniforge’s noise expert believed that proper
placement of the pads might reduce the acceleration forces,
thereby reducing some of the forge frame’s vibrations.
Reducing
the ringing on all the structures may seem to somewhat lower the
total
sound omitted, however,
the pads would not effectively
rethice the highest sound
level
impacts, that is the
impulsive
sound.
(R. 57).
This same noise expert took the noise readings
in the area
of the Amforge shop.
As stated earlier,
these measurements
indicated the highest Leq to be
70
The isopleths developed from
these measurements demonstrated that residences downwind suffered
from higher noise
levels.
The difference between downwind and
upwind was as much as approximately two decibels per 100 feet
from the shop.
Therefore,
at 1000 feet the difference between a
downwind or upwind location would be twenty decibels.
Given
this,
the number of affected residences mentioned above must be
qualified.
During the daytime
it is
likely that only a part of
the one hundred and fifty—five residences,
those directly down-
wind, would experience levels greater than the allowable 58.5 Leq
whereas the
levels upwind may be below that level.
The same
holds true for the additional
four hundred and eighty-eight
residences originally considered to he exposed to levels greater
than the nightime level of 53.5 Leq.
The Agency’s Recommendation assessed the ability of the
Amforge facility to abate sound, and the health and welfare
effects on the nearby community should it not.
Principally, the
Agency considered acoustical
strengthening.
This would require
reducing the number of ventilation openings,
installing duct
silencers at ventilation openings and gravity ventilators at the

5
roof openings.
The Agency agreed with
2½rnforge that these
three
efforts
would
hamper
the
“stack
effect”
this shop depends on.
As for the impact on the nearby community,
the Agency found that
only thirteen homes would receive levels as high as
70 Leg, while
an additional thirty—six would receive levels as high as
65 Leg;
101 a level
as high as 60 Leq, and 119 homes impacted at levels
as
55 Leq.
The Agency’s Recommendation also notes that since
1972,
no citizen complaints have been received about the Aniforge
facility.
In assessing the health and welfare effects,
the
Agency’s Recommendation cited the United States Environmental
Protection Agency’s document “Information on Levels of Environ-
mental Noise Requisite to Protect Public Health and Welfare with
an Adequate Margin of Safety”.
(Recommendation,
Ex.8)
This
study acknowledged that it is difficult to access the effects on
health caused by impulse noise because
it is necessary to take
into account other factors such as the background noise, and the
number and duration of the daily exposure.
The study found that
impulse noise exceeding background noise by 10 dB is potentially
sleep disturbing and startling.
However,
the study concluded
that no threshold level could be identified, or that there was
any clear evidence of permanent effect on public health and
welfare.
As its alternative compliance program,
Aniforge proposed
three operational changes.
It has agreed to reduce the number of
operating hammers from twelve to ten;
limit operations
to two
shifts which will mean the forging shop will operate from 7:00
a.m.
until 11:00 p.m.,
and occasionally from 6:00 a.m.
until
12:00 midnight;
lastly,
as the hammers are overhauled (approxi-
mately every three years),
the sound absorption pads described
above will be installed.
Ainforge estimates that removing two
hammers from operation and. curtailing the hours of operation to
sixteen per twenty-four period its potential
forging operation is
reduced by 39.1.
It could not, however, express this cutback
in
a dollar amount.
It should be noted that the Ainforge petition lists sound
abatement measures taken at the facility since
1972.
For
instance, mufflers,
silencers,
and snubbers were installed on
hammers, presses,
and on air compressors;
eleven hammers were
removed from service; part of the hammer shop was rebuilt with
noise insulating materials;
and the ground level doors were
repaired or replaced.
Some of these efforts directly reduced the
amount of impulsive noise, while other abated other manufacturing
noise.
The costs of these improvements ranged from $1,803,000
for rebuilding part of the hammer
shop, to $3,800 for the work
done on the ground
level
doors.
The economic impacts
to the individual shops,
to the State
and otherwise were initially considered in the R76—14 proceeding.
The Economic Impact Study submitted by the then Institute of
Natural Resources did investigate the cost of abatement for ten
individual forging shops.
Amforge was one so studied.
The

6
combined capital and operating costs
for reducing noise emissions
by
successive
5 dB increments in 1978 dollars was estimated to
range from $424,000 for a
5 dB(A) reduction to $714,000 for a 15
dB(A)
reduction.
(INR Document No.
78/03, pp.
39—40)
Although
1\inforge along with nine other
shops, was individually examined,
these dollar amounts were standardized for purposes of the
report.
DOCKET B:
MODERN DROP FORGE COMPANY
Modern’s facility occupies approximately four blocks
immediately northwest of the intersection of 139th Street and
Western Avenue in Blue Island,
Illinois.
The first forge shop
was constructed in 1918,
and
a second built
in the 1940’s.
Since
then numerous support buildings have been added.
Modern operates
twenty-one hammers and numerous furnaces.
The air drop, air
driven hammers range
in size from 2,000 pounds to 8,000 pounds,
while each furnace can heat up to 1.3 tons of steel per hour to a
temperature of nearly 2,000 degrees Fahrenheit.
The forgings
produced range
in size up to forty pounds and include among other
items connecting rods for engines, pinions, and gears for the
railroad industry, and shifting levers for transmissions.
Modern currently employs 263 persons
(R.
16).
Historically,
Modern operated two shifts from 6:00 a.m.
until midnight, with
occasional Saturday shifts from 6:30 a.m. until
7:30 p.m.
Currently,
the forging operation is from 6:30 a.m. to 10:15 p.m.
five days a week.
The chart below provides the approximate
number
of forgings manufactured, the total
tonnage of forgings,
and the number of blows creating impulsive noise
for the years
.1,979 through 1981
(Pet.
5).
At hearing, Modern estimated that
7,200 tons were forged in 1982 and approximately 8,000 tons would
be forged in 1983
(R.
17).
No. of Forgings
No. of
Tonnage of All
On Hammers
Blows
Forgings
-
1979
24,800,000
109,282,000
15,900
1980
18,800,000
92,475,000
13,350
1981
12,746,000
67,477,000
9,780
Modern is primarily surrounded by other industrial
facilities.
Directly north is a warehouse and trucking
operation, east a roofing company, and directly south in one
industrial park is another roofing company,
a potato processing
plant, incinerator manufacturer,
and pattern works.
Numerous
scrap yards and railroad switching yards are also in the vicinty.
A girls
school is directly east of Modern,
while trailer parks
are northeast, east and southeast of Modern.
Like Modern,
however,
these residential
areas are surrounded by industrial
52-256

7
complexes and switching yards
(Ex. A).
Nevertheless, these
residential
areas qualify for Class
A protection under Chapter
8.
More specifically, impulsive sounds impacting them must not he
more than 58.5 Leq during daytime hours, and 53.5
r4eq during
nighttime hours pursuant
to
Rule 206,
Table VII.
Sound measurements were taken by Modern using both the Leg
measure and dB(A)
(fast meter response).
Data taken on dB(A) was
converted to Leq by deducting
5 dB.
Excluding two residences
owned by Modern, the highest emission at the closest Class A Land
measured 67 Leq
(Pet.
9).
Using concentric circles,
Modern
illustrated the different noise parameters effecting the various
residential
locations.
The diagram indicates that the girls’
school, the northern trailer park, and part of one to the
southeast of Modern
fall within the 65 Leq or greater range.
The
two smaller trailer parks to the east
and
the remainder of
the southeastern park are within the 55 Leq.
to 65 Leq
(Ex. A).
Petitioner estimated that 1,639 residences
are potentially
exposed to sound levels greater than 53.5 Leq
(Pet.
9).
Modern’s
‘two forging shops are of similar design.
The lower
level
is composed of brick with large roll—open doors.
Above that
are wire glass panels on one building, and corregated
fiber glass
and steel panels on the other.
One roof is gypsum board and
asphalt with a corrugated transite peak, while the other
is a cor~
rugated transite roof.
Atop both buildings are large open roof
ventilators while
along with the buildings’
design provide for
natural ventilation of the furnaces’ heat, commonly referred to
as “stack effect”.
The impulsive sound
from the forging hammers
also exits through the roof ventilators;
thus,
the relationships
between adequate ventilation and sound emitted.
Modern considered two abatement strategies.
The first
entailed totally enclosing the shops and installing mechanical
ventilators.
Structural analysis of both buildings indicated
that the present trusses and related structures would have to be
extensively modified to support the deadweight associated with
additional exhaust units.
Seven additional units weighing 1,300
pounds apiece would be needed for the older, smaller shops which
currently has six trusses.
Ten units weighting approximately
7,740 pounds apiece,
in addition to the present eight, would be
needed
at the newer and larger of the two buildings
(Ex. F).
Modern claims that for the same structural reasons, sound
absorptive material cannot be installed.
A second means for abating sound would be to construct
barriers between the shops and receiving Class A areas.
Since
1976,
Modern has built five structures between itself and the
southern and eastern perimeters,
and is currently erecting a
sixth.
In locating these buildings, Modern had intended to
obstruct the impulsive noise caused by its operations.
In
building these new structures,
Modern used sound absorptive
brick,
at an increased cost of approximately three and a half times that
of normal building material.
One structure was also constructed
‘to
a height recommended to obstruct sound movement
(R.
20—21).
52-257

8
Lastly,
Modern enclosed the upper
side vents on its larger
building
(R.
22).
This was intended to direct noise skyward,
and
also to improve the “stack—effect”.
While it did improve the
natural ventilation, the workers objected
(R.
38).
Modern also considered constructing barriers.
To be
effective,
it was thought these barriers would have to be close
to
the
forging shops.
They would thus interfere with the
facility’s craneway and forklift routes
(R.
28,
29,
Ex.
D,
E).
Modern also introduced testimony from the R76—14 proceeding,
as
to the effect such barriers would have on its employees.
Since
the
harriers would have to be constructed close to the shops,
they would in effect
cut
of f light and air
(R.
30).
Two
employees
of forging shops, one from Modern, testified that would create
intolerable working conditions
(R.
76-14, February 23,
1981,
R.
270—274;
R.
429—431).
In taking
the sound measurements,
the buildings and
other barriers were found ineffective at distances greater than
200 feet beyond the barrier because weather conditions affected
the noise pattern.
Locations downwind registered higher noise
levels than those upwind from
the
source.
Even without wind,
weather conditions interfered with the barriers’ intended
effectiveness.
On
sunny days, the heated ground causes the noise
‘to be diffracted upwards very rapidly
(R.
43—96).
Thus, the
barriers,
regardless of height or material specifications,
failed
to stop impulsive noise from reaching Class A Land.
Evidence of
‘this diffraction pattern,
incidentally,
is the reason Modern used
concentric circles rather than irregular isopleths to illustrate
noise patterns.
Modern was only aware of one complaint about the impulsive
noise generated from its neighbors; which was made in 1977 in
response to 2:00 a.m.
operations.
Modern has since discontinued
the then experimental early morning third shift
(R.
24).
During
the R76—14 proceeding Modern also conducted a survey of the
affected residences and only one complaint was registered
(R.
76—14,
February 24,
1981,
R.
433—435,
441—444).
The Agency’s
Recommendation cited no known complaints.
Furthermore, the
Agency
estimated that only 5
to 10
of the 1,639 homes considered by
Modern would receive levels as high as 67 Leq.
Pursuant
‘to Rule 206(d)(2)(G) petitioners
for
a
site—specific rule are to include proposed operational
levels and
physical abatement measures,
if any, which are intended to reduce
‘the facility’s impulsive noise.
Modern does not propose to change
its operations
or,
in the future,
install or construct sound
abatement mechanisms.
However,
since
1976, Modern has undertaken
six construction projects which directly and indirectly were
intended to reduce impulsive noise.
Modern not only designed and
located building construction to act as barriers, but also used
sound absorptive material on those walls facing the forging shops.
Modern also closed the upper vents on
the
larger shop and the
southern end of the smaller shop
(R.
23).
Modern is also in the
process of installing
sound attenuators on its dust collectors.
52-258

9
This last measure will not reduce impulsive noise, but should
effectively reduce other noise emitted to nearby residences.
Cumulatively, Modern estimates that
the sound abatement measures
associated with these construction projects have cost approxi-
mately $24,000
(Pet.
7—8).
The R76-14 Economic Impact Study
estimated that
it would cost Modern $424,000 to reduce impulsive
noise by
5 dB(A) and up
to $1,231,000 to reduce it by 20 dB(A)
(INR Document No.
78/03,
p.
39—40).
A
20 dB(A) reduction was
tiien considered necessary for Modern to comply with the numerical
noise limitations.
Modern represents that future efforts to reduce impulsive
noise to compliance levels would require total enclosure of its
two shops,
thereby eliminating the buildings’
“stack effect”.
Replacing natural ventilation with mechanized ventilation is not
feasible given the buildings’
current structure.
Enclosing the
shops
is also unacceptable from a productivity viewpoint.
Large
materials must constantly he moved in and out of the buildings,
and the shops’
employees would not accept conditions which would
shut out natural
light and air.
Historically, Modern has not operated an early morning third
shift.
It cannot,
therefore,
propose to eliminate it.
Modern
does request that it he allowed to operate between 6:00 am.
until midnight, although it ordinarily operates no later than
10:15 p.m.
Therefore, those residences
located only within the
nighttime noise
limit parameter,
will be adversely affected for
no more than two hours per week day.
Impulsive sound is
considered disruptive to sleep according to the USEPA document
“Information on Levels of Environmental Noise Requisite to
Protect Public Health and Welfare With an Adequate Margin of
Safety”.
(Agency Recommendation,
Ex.8)
That same document,
however,
did not establish a threshold level
for health or
welfare impairment.
The Board notes that no complaints have been
filed
in the recent past concerning Modern’s forging operations.
Perhaps the industrial character of the area renders Modern’s
impulsive noise
less obtrusive.
DOCKET C:__WYMAN-GORDON COMPANY
Wyman—Gordon’s facility
is located on approximately 66 acres
immediately north and northwest of the intersection of 147th
Street
(State Highway
83)
and Wood Street
in Harvey,
Illinois.
Ten forging units, each consisting of two hammers, are housed in
four separate buildings,
identified as Nos.
6,
7,
67 and 75.
The
steam driven hammers range in size from 10,000 pounds to 30,000
pounds,
and produce forgings ranging
in size from twenty—five to
over. 1,000 pounds.
The forgings produced include among other
items crankshafts
for agricultural and off—road equipment, parts
for the aircraft, the aerospace and the under sea exploration
industries.
The table below provides the approximate number of
forgings manufactured on these hammers,
the number of blows
52-259

iU
c:reattng impulsive noise, the total
number of
forgings and the
total tonnage of forgings for the years
1979 through 1982.
(Pet.
6,
R.17).
At hearing, Wyman—Gordon projected that 11,000 tons
would be forged
in 1983.
No.
of Forgings
No.
of
Total No.
Tonnage of
All
On Hammers
Blows
Of For~q~
F~inas
1979
319,136
6,382,720
475,260
55,646
1980
220,684
4,413,680
344,863
42,732
163,485
3,169,700
285,657
38,629
1982
1,175,980
58,799
7,590
Wyman-Gordon began its
operations on 1919.
Although four
buildings previously contained hammer units,
the single unit in
Building
67 has been shut down.
Therefore,
three buildings
constructed before 1940 now house the remaining units and thirty
to forty
furnaces.
Individually, these furnaces are capable of
heating up to 16,000 pounds
of steel per hour to a
minimum
of
2,200 degrees Fahrenheit.
To exhaust
‘the tremendous heat
generated,
all three buildings were designed
to create a “stack
effect” for natural ventilation.
The end walls are partially
made of brick with some upper
level windows and corrugated
asbestos siding.
The principal walls have numerous grade
level
doors and side wall windows.
Roofs are of
federal cement tile
with a monitor containing operable sash windows.
The ground
level doors,
side windows,
and roof windows are all necessary
openings for ventilation.
It
is through these
same openings that
impulsive sound is emitted.
Currently, Wyman-Gordon employs
380
persons,
and at
Lhe time of petitioning
it employed G00 persons.
(R.15,
Pet.4).
At this time the forging hammers are operated
between 7:00 a.m.
and 3:00 p.m.
Historically, the hammers were
operated during two shifts,
from 7:00 a.m. until 11:00 p.m.
six
days per week.
Occasionally,
isolated units begin at 6:00 a.m.
or
end at midnight.
A third
shift has not traditionally been
utilized.
Wyman—Gordon’s facility
is surrounded by residential
property which qualifies
for Class
A protection under Chapter
8.
The plant and Wood Street
is bisected by two railroads.
An
average of eighteen trains operate daily,
which along with
a
manufacturing complex to the west contribute noise
‘to the area.
wyman—Gordon estimated that 1,263 residences are potentially
exposed to levels
in excess of 58.5 Leq.
and 794 additional
residences exposed
to levels exceeding 53.5.
These measurements
are respectively the daytime and nighttime maximum exposure
levels allowed under Rule 206, Table VII.
52-260

11
The highest noise
level, measured and therefore anticipated
at the closest Class A Land
is
74
Leg.
The
74 Leq. measurement
was taken in the vicinity of only three to four homes,
which were
just north of Building
75.
Wyman-Gordon qualified
this as the
worst case condition, only occurring on days when these
residences were downwind.
The total number of residences was
likewise qualified; only those in downwind quadrants receive
levels greater than allowed by Rule 206.
Therefore, the entire
number of potentially affected residences would not be subject to
excess levels at any one time.
(Pet.9,
10,
R.19).
Wyman—Gordon has over the years already taken steps to
reduce the noise,
impulsive and other,
emitted beyond its peri-
meter.
Between 1952 and 1978 it expended $462,937 to acquire
approximately twenty-one acres contiguous to its property.
This
land is vacant and acts as a buffer between the plant and
nearby
residences.
Secondly,
in 1979 Wyman—Gordon installed two roof
ventilators
at Building 75,
at a cost
of $84,000,
not including
internal engineering and labor costs.
Each vent is nine feet
wide by ninety feet long and directs heat and impulsive sound
upward.
Each ventilator contains two vertical panels, each
lined
with glass
fiber sound absorptive material.
Installation of the
ventil4tors
allowed the openings on Building 75’s north side to
be closed.
Northern residences,
when
downwind, benefit by a
sound reduction of approximately
4 decibels.
(Pet.8).
In 1982,
Wyman-Gordon shut down two hammer units,
each consisting of
two
hammers.
Both units were contained in buildings on the
facility’s southern boundary.
In
eliminating one of two units
in
Building
7,
and the only unit in Building
67,
the potential for
excess levels impacted residences to the south was reduced.
(R.18,
Pet.8).
Lastly,
between 1974 and 1979 Wyman—Gordon
installed mufflers to reduce non-impulsive noise from all its
steam vents
at a cost of $32,000.
Wyman—Gordon considered totally enclosing the three
remaining forging shops, Buildings
6,
7,
and
75.
However the
cost,
size and weight of the necessary exhaust fans,
silencers
and duct systems were prohibitive economically, but more
important, structurally.
(R.26).
For example, two silencers
would be required at Building
75 costing a total
of $12,000,
along with four ventilation fans at $84,000.
Duct work for
Building 75 was estimated at $181,700.
(Ex.H).
Regardless
of
the high cost, Wyman-Gordon testified that the ‘three buildings
would be unable to support the weight associated with mechanized
ventilation without substantial reinforcement of the present
structures.
(R.26).
Wyman-Gordon also considered constructing four barriers.
The one proposed at the facility’s north end would, however,
obstrucl
a craneway and the roadway providing access for Street
trucks to and from its principal steel yard.
A
new roadway was
estimated to cost
a total
of $114,365.
(Ex.F,
R.22).
52-261

12
Con~tructionof a second harrier at the southern end of the
facility, would interfere with the movement of steel
in and out
of’ one building.
To maintain production levels,
an additional
truck and driver would be needed at an estimated annual cost of
$125,398.
(Ex.6,
R.23).
Yet two more barriers at the southern
end would obstruct a crarieway and the shops’
natural ventilation
and light.
(Ex,E,
R.24).
Wyman—Gordon proposed both physical changes and operating
changes in order to reduce impulsive sound received at nearby
Class A Land.
Primarily, Wyman—Gordon will concentrate its
forging
operation
to
Building
75,
which is approximately
one—fifth of
a mile north
of
its
southern
forging
shops.
Buildings
6 and 7 will therefore not he used for more than 20
of
the total operation. Already Petitioner has eliminated two units
operating in Buildings
7 and 67, which are located at the
southern edge of its property.
It
is further willing by
January
1,
1984,
to remove another unit from operation.
That
will mean a 40
reduction of
the
ten units previously operated.
As noted above,
it was Building
75 which had its northern
facade closed
to reduce noise emitted to northern residences.
In an effort to further reduce noise
to the north, Wyman—Gordon
proposes
to consolidate two existing steel stockpiles into one
which
is to be located north of Building
75.
The consolidated
yard
is to act as a noise barrier during ideal
atmospheric
conditions.
(R.29,Pet 13).
Like other barriers,
its intended
purpose
is defeated whenever wind or heat diffracts noise over
it.
(R.41,
44).
At best,
the stockpile should reduce noise
levels by 1dB
or more.
(Pet.13).
Wyman—Gordon is aware of the ineffectiveness
of barriers
because four other buildings are already located just north of
Building
75.
These building shield all but one of the units in
Building
75.
In theory, these buildings should produce an
approximate
20 dB reduction.
However, measurements indicate that
noise
is reduced by just
3 dB (R.45).
Nevertheless, Petitioner
proposes to consolidate
its steel yard in
a location to shield
the one unit not already blocked to the north.
Lastly, Wyman-Gordon proposes to limit the amount produced
during its hours
of operation.
Forging operations will continue
as be’fore, primarily between 7:00 a.m. and 11:00 p.m. six days a
week, and occasionally begining at 6:00
a.rn.
and ending at
midnight,
with occasional Sunday shifts.
However,
it proposed
to
restrict operations during the latter to 2
of its annual total
hammer productions.
(R.27,30,54).
In addition to these efforts.
it
is noted that Wyman-Gordon has already invested money and
action towards consolidating production at Building
75.
Building
75 was itself renovated and partially enclosed, and Building 67
eliminated as
a forging
shop.
52-262

13
The past efforts and future consolidation Wyman—Gordon
estimates will cost nearly $2,000,000.
(R.30).
The Economic
Impact Study estimated that for the Wyman-Gordon facility to
reduce impulsive noise emissions by 25 dB(A), the amount
necessary to be in compliance with numerical limits, was
$1,715,000.
That was based on 1978 dollars, which also had been
standardized
in a study of ten forging shops.
(INR Document No.
78/03, pp.
3940).
The plan now proposed by Wyman—Gordon will
cost approximately the same amount,
but is anticipated to reduce
the noise level by
1 to 3 dB(A).
The difference in cost
is due
not only to inflation,
but because
it has now become apparent
that shops
like Wyman-Gordon cannot be totally enclosed and that
sound barriers do not perform in actuality as
formerly believed
in theory.
Inability to enclose and inefficiency of barriers
accounts for the difference in noise reductions anticipated.
CONCLUSION
In adopting the alternative of site—specific operational
levels in R76—14,
the Board concluded that given these figures
and
other
information
made
it
apparent
that
a
number
of
small
Illinois forging shops could not achieve the necessary noise
abatement for reasons technical and economic.
Therefore, instead
of
a standard noise
level the shop’s operational plan becomes the
rule within Chapter
8,
and the individual shop must comply with
it.
In no instance may such a plan allow an increase in existing
decibel
levels, measured in Leq.
In the matter of Docket
A, the Board accepts Amforge’s
assertion that the two buildings could not structurally bear the
weight mechanized ventilation would entail.
Therefore, the only
means
for totally enclosing the hammer and axle shops would be to
rebuild the existing buildings.
Secondly, the formerly
acceptable abatement measure of barrier construction has been
discredited as an effective method to reduce impulsive sound.
It
then
appears that impulse forging noise can only be reduced in
this case through operational changes.
Amforge has agreed to
eliminate its late night work shift as well
as two of the twelve
hammers.
In addition,
Amforge has agreed to reduce the noise
generated by the remaining hammers by installing absorption
material.
The operational changes are directed at reducing
impulsive sound, while installation of sound absorptive pads on
the hammers is intended to reduce the shop’s other noise
level.
This plan,
along with the other noise abatement measures taken
over the preceeding ten years should provide relief to the
nearby
Class A lands.
The plan
as set out in the accompanying Order is
incorporated into Chapter
8 at Rule 206(f)(1),
and Amforge is,
therefore,
required to~comply with it.
As for Docket
B,
the Board must conclude that short of
totally enclosing the shops, Modern has already installed noise
barriers to the furthest extent possible.
Although these have
52-263

14
proven inefficient
on windy or sunny days,
they will hopefully
provide
the
community
some
protection
from
impulsive
noise,
if
only during days of no wind or sunshine, and during nighttime
hours.
At this time,
Modern will not be required to make any
specific physical changes to reduce impulsive noise,
but
is
encouraged to continue replacing or locating new structures
conducive to reducing noise
levels.
Lastly, Modern will be
restricted to operating its forging hammers between the hours of
6:00 a.m. through midnight on weekdays,
and 6:30 a.m. through
7:30
p.m.
on Saturday, with no Sunday operations, pursuant to the
plan adopted at Rule 206(f)(2).
In the matter of Docket
C,
Wyman—Gordon
proposes to move
its
operations to Building 75 at the northern perimeter of its
facility.
As mentioned above,
the 74 Leq. reading was measured
at three to four residences just north of Wyman—Gordon’s
facility.
Enclosure of the Building 75’s north side,
the
existence of the four buildings just north of it,
and the
doubling the size of the steel stock pile should minimize these
incidents.
Impact on southern residences should be reduced by
Wyman—Gordon
limiting
operations
in
Buildings
6
and
7
to
no
more
than 20
of its annual production.
Finally,
since Wyman—Gordon
should routinely operate no more than one hour during nighttime
hours as defined by Chapter
8,
the probability of sleep being
disrupted should be reduced.
To insure these
noise reductions
and limitations, the plan proposed by Wyman-Gordon and found
acceptable to the Board is adopted at Rule 206(f)(3).
This Opinion supports the Board Order in this matter,
adopted this same day.
I,
Christan
L.
Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify that the above Opinion and Order
was adopted on the
__________
day of
1983 by a vote of
4—p
.
Christan
L. MofT~ii’erk
Illinois Pollution Control Board
52-264

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