INTERMET DECATUR FOUNDRY

825 N. Lowber Street

P.O. Box 1319

Decatur, Illinois 62525

Phone: (217) 428-7791

Fax:

(217) 425-6662

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March 30, 2004

Illinois Pollution Control Board

ATTN.: Dorothy M. Gunn, Clerk

Janies R. Thompson Center

100W. Randolph St., Suite 11-500

Chicago, IL 60601

Reference:

Certified #: 7000

1670

0004 7429

9800

Return Receipt

Requested

Docket R03-9, Proposed

New

and Updated Rules for Measurement and Numerical

Sound Emissions Standards Amendments to 35 ILL. ADM.

CODE

901 and 910;

and specifically, 351AC901 .113

Dear Ms. Gunn:

I spoke with Marie Tipsword recently about the reopening ofdiscussion in this matter. She stated

that she would notify me when the hearing is scheduled, but also stated that I could resubmit the

letter I sent to you last year and it would be entered as a record of public comment.

Upon review of the proposed changes to IAC 901 and 910, it became apparent that INTERMET

Decatur Foundry, aka Wagner Castings Company, of Decatur, IL, neglected to notify the Illinois

EPA and the Illinois Pollution Control Board, that forging operations at this plant ceased prior to

the year of 1984. All equipment associated with the forging operations has since been dismantled

and either sold or discarded. Furthermore, INTERMET Decatur Foundry has no intentions of re-

establishing forging operations at this facility. Therefore, it is our position that section 901.113 be

eliminated from the 35 IAC 901 entirely.

If the Illinois Pollution Control Board needs further information in order to eliminate 901.113,

please contact me at 217-425-6667 or via email at sgrimes@intermet.com.

Sincerely,

Sherri Grimes

Safety/EPA & Security Administrator

INTERMET Decatur Foundry

~NTERMET

Section 901.113

Wagner Casting Site-Specific Operational Level

Wagner Casting Company and future owners ofthe forging facility located at the southeast

corner ofSangamon and Jasper Streets in Decatur, Illinois, must comply with the following site- specific

operational level orare otherwise subject to Section 901.105(c) shall:

Operate Shall operate no more than nine forging hammers at any one time; and

Operate Shall operate its forging hammers only between the hours of5:00 a.m. Monday

through 9:00 p.m. Saturday.

(Source: Amended at 27111. Reg.

__________,

effective

__________)

Section 901.105(c) Limitations for Existing Forging Operation

No existing impact forging operation shall cause or allow the emissionofhighly-impulsive sound to

any receiving Class A orB land which exceeds the allowable sound levels specified in the following

table, when measured at any point within such receiving land, provided however, that no

measurement ofsound levels shall be made less than 25 feet from such existing impact forging

operation’s property-line unless such forging operations is granted a permanent site specific

allowable operational level pursuant to subparagraph (d).

Allowable Highly-Impulsive Sound Levels

£J~)

in Decibels Emitted

To Class A or B Land from Existing

Impact Forging Operation

Class B Land

Class A Land

Daytime

Nighttime

64.5

beq

58.5

Leq

53.5 Leq

Section 901.105(d) Site Specific Allowable Operational Level for Existing Impact Forging

Operation

1) An existing impact forging operation which does not comply with subparagraph (c) may seek a

permanent site specific allowable operational level from the Board. A permanent site specific level is

that level ofoperation allowed petitionerafter review and approvalby the Board and after

implementation ofabated measures, ifany, approved by the Board.

2) Any existing impact forging operation seeking a permanent site specific operational level must submit as

its petition the following:

A) The location ofthe petitioner, a description ofthe surrounding community, and a map locating the

petitionerwithin the community;

B) A description ofthe petitioner’s operations, the number and size ofthe petitioner’s forging hammers,

the current hours ofhammer operation, the approximate number offorgings manufactured during

each ofthe three prior calendar years and the approximate number ofhammer blows used to

manufacturethe forgings;

C) A description ofany existing sound abatement measure;

D) The sound levels in excess ofthose permitted by subparagraph (c) emitted by the petitioner into the

community, in

decibel increments measure in Leq shown on the map ofthe community;

E) The number ofresidences exposed to sound levels in excess ofthose permitted:by subparagraph (c);

F) A description ofother significant sources ofnoise (mobile and stationary) and their location shown

on the map ofthe community;

G) A description ofthe proposed operational level and proposed physical abatement measures,ifany, a

schedule for their implementation and theircosts;

H) The predicted improvement in community sound levels as a result ofimplementation ofthe

proposed abatement measures; and

I) A description ofthe economic and technical considerations whichjustify the permanent site specific

allowable operation level sought by the petitioner.

3) An existing impact forging operation seeking a permanent site specific operational level shall prepare

and file its petition with the Board and Agency as applicable no later than December 1, 1983.

4) The Agency shall prepare a written evaluationregarding eachpetition seeking a permanent site specific

operational level and shall file said evaluation withinninety (90) days following receipt ofthe petition

with both the Board and the petitioner.