ILLINOIS POLLUTION CONTROL BOARD

August

2,

1954

IN

TH~

~4ATTF~R

OF~

)

ROCFZFORD

DROP

FORGE

COMPANY

)

R83—30

)

for a Site—Specific Operational

)

Level Pursuant to Chapter 8,

)

Rule

206(d)

of

the

Rules and

)

Regulations

of the Illinois

)

Pollution Control Board

)

PROPOSED

ROLE.

FIRST

NOTICE

PROPOSED OPINION

AND

ORDER OF THE BOARD

(by B. Forcade):

This

matter comes before the Board on a petition filed on

November

17, 1983, by Rockford Drop Forge Company (~Rockford”)

for

a

site—specific

operational

level

for its

forging

shop as an

alternative

to

compliance

with

the

noise

limits

contained

in

35

Ill.

Adm.

Code

901.105

(old

Rule

206

of

Chapter

8),

A

public

hearing

was

scheduled

with

those

of

three

other

Illinois

forging

shops

in

order

to

conserve

the

time

and

resources

of

the

parties

involved~.

No

public

testimony

or

comments

were

received,

The

Department

of

Energy

and

Natu~:al Resources

(~DENR’~)

issued

a

statement

of

negative

declaration of economic impact on

April

19,

1984,

obviating

the

need

for

an

economic

impact

st.atement~

On

duly

18,

1984,

The

Economic

and

Technical

Advisory

Committee

concurred

with

the

DENR’s

finding~

The

regulatory

scheme

for

existing

forging

operations

require

that

the

Petitioner

either

(:1)

comply

with

the

noise

prohibitions contained in Table F

of

Rule

206(c)

no

later

than

fifteen

months following the effective date of the Rule,

or

(ii)

seek a permanent site—specific opeational

level as provided in

Rule 206(d).

These rules have been recodified as 35 Iii. Mm.

Code 901.905(c)

and

(d).

The noise prohibitions in §901.905(c)

vary for different classes of receivers and for daytime and

nighttime periods.

A petition under 5901.905(d) must demonstrate

that

it

is

technically

and

economically

infeasible

for

its

shop

to meet the numerical

limits of §901.905(c),

A petition must

also propose measures to reduce impulsive noise ~here possible

and

assess

the

consequential

health

and

welfare

impacts

on

the

surrounding

community.

Rockford

is

located

at

2031

Ninth

Street

in

Rockford,

Ellinois.

Rockford9s

facility

occupies

approximately

18

acres

and

has

been

in

operation

since

1911.

At

that

time,

the

adjacent

land

was

either

vacant

or

industrial

(Ft.

53)..

At

the

present

time,

the

facility

is

surrounded

by

warehousing

and

manufacturing

on

the

north

and

east,

manufacturing

on

the

west

and

a

parking

facility and alley to the south.

The

nearest

Class

A

residences

The Board acknowledges the contribution of David

G. Mueller

who was the administrative assistant for this rulemaking.

---

2

are approximately 500 feet south of Rockford~sfacility (R. 54),

There are 85 Class A residences that receive forging noise in

excess of the regulatory limit

(Pet, p~8),

The facility consists

of several buildings,

one of which houses

13 forging hammers

and

13 furnaces (R~57),

The forge hammers vary in size from 1,500

Ibs, to 4,000 lbs~ (Pet,

p,

4),

This building has 48 rolling

steel

doors on the north

and east

walls,

Ventilation is provided

by both gravity and. mechanical means through the roof monitor

(Ft..

58)..

Rockford currently employcs 100 people

(Pet,

p.

4),

The forging process consists of heating carbon or alloy

steel

in furnaces to approximately 2350 degrees Fahrenheit and

then forcing the heated pieces between two dies,

The upper die

is attached to a guided ram and the lower die is attached to the

forge..

The metal is

shaped

through pressure exerted by the ram

or forge hammer,

forcing the workpiece into the impression on the

dies,

The sound produced through this process is impulsive and

originates primarily from the impact between the upper and lower

die and the workpiece.

There is a constant flow of materials

between the furnace,

forge, and cooling area

(Ft..

46).

Rockford

manufactures forgings for

railroad,

farm and construction

equipment, hand tools,

trucks,

aircraft and ordinance

(Pet,

p..

4).

The nature of the

forge

operation creates an extremely hot

work environment,

The

furnaces

require a tremendous amount of

oxygen and emit a great deal

of

heat,

The cooling workpieces

also radiate heat into

the forge

shop,

Consequently, the shop

requires extensive

ventilation

which is provided by the rolling

steel doors and the roof

monitor,

This system creates a ~‘stack

effect~whereby air flows

through

the open sides of the building

and is drawn up and out through the roof

(Ft..

58)..

This natural

ventilation system is effective and widely utilized by the

forging industry.

The open sides of the building also

facilitates the free

movement of

material in and out of the forge

shop..

Noise escapes through these roof and side openings.

Rockford currently

operates

its forging hammers from 6:00

am..m to 4:00 p.m..

five

days per week..

Historically, Rockford has

operated two shifts,

from 6:00

a,m.. to 10:00 p..m. five days per

week, with occasional work on Saturdays from 6:00 a,m, until 4:00

p.m..

(Pet..

p..

4)..

The Petitioner requests a site—specific level

that would allow them to

operate

no more than 12 hammers

at

any

one time during the hours of 6:00

a,m.. to 10:00 p.m. Monday

through Saturday..

Production

has

fluctuated over the last few

years~ Production levels

have

declined since 1981 as is shown by

the table below..

Future production is expected to

be

double

the

1982 operating levels

(Pet,

p.

5).

Total

No. of forgings

No,

of

Tonnage of all

on

hammers

~9yj~..

~

1980

581,524

4,652,192

4,610,667

1981

1,234,056

9,872,448

10,527,516

1982

806,613

6,452,904

7,137,098

59~304

---

3

The regulations of the Board define two methods of measuring

sound..

The definition of dB(A), or A

weighted sound in

decih~s,

is found ir

35

Ill.. Mm, Code 900.101, as

is the

defin~tio~~.

cf Leg, or equivalent continuous sound pressure

level

in c3ecibeie.

Fssentially,

dB(A) measures the noise

level

at the

peaks

wli3e

Leq measures the average noise

level over time,

inc1udi~j~ea~

aid background noise,

Permissib~impulsive sound levels for existing forge shops

are found in 35

Ill..

Mm.. Code

901.105..

The impulsive sound

le~l~itted

to residences

(Class A land) cannot exceed 58.5

Leg, during the day or 53.5 Leq at night.

Actual measurement of

sound wer~taken around the Rockford facility by George F.

Kamperran,

an expert in the area of noise~controlengineering.

Based on these measurements, Kamperman predicted that the highest

level

at the nearest receiver would be approximately 64 Leq

(Ft..

110).

Approximately 85 Class A residences are exposed to forging

noise in excess of the regulatory standard..

Eighty—five Leq is

the maximum or ~worst cased situation..

Rockford has received no

citizen complaints..

The Illinois Environmental Protection Agency

(~Agency~)did receive a citizen complaint about the Rockford

facility in 1974..

This complaint did not concern forging noise,

but resulted from a trimming press that was operating on a third

shift after

10:00 p.m..

(R.

65—66)..

In

1981 Rockford modified

their roof exhaust system

by

installing consolidated steam vents.

This modification has

reduced

noise from the facility

(Ft..

64—65).

Rockford also removed the

hammers

nearest the closest residences

from the east and southeast

portion

of the shop

(Ft..

67)..

There

have been no citizen complaints since these modifications,

Rockford has investigated methods of compliance with the

Board~srcise regulations..

To achieve compliance,

it would be

necessary to replace all windows, doors and siding on the south,

east and north walls with sound deadening material, permanently

closing the upper portions of the facility with sound deadening

materia), constructing a double—door entrance and installing

accoustical louvers

(R.

61)..

Additional mechanical ventilation

would have to be installed on the roof

(Ft..

62)..

The roof

currently could not support any additional loading and would have

to be reinforced

(Ft..

60).

These modifications would cost between

$100,000 and $300,000

(Ft. 110),

Material flow at the forge would

be greatly altered..

Productivity would decrease due to the

enclosed work environment and the inhibited material flow

patterns that would result

(R..

62)..

Because the Rockford

facility is presently obsolete and is barely competitive with

more modern forge shops, one of the Petitioner’s probable options

would be to relocate their hammers at a newer facility in Iowa

rather than comply through modifications

(Ft..

71)..

The Agency, in their written comments on the proposal filed

January 23,

1984, did not challenge Rockford’ qualification for

site—soecific relief on the basis that it is an “existing

impact

forging operation”, nor did they question the fact that the

5~fl5

---

4

pet~ner ~as violating Rule 206CC).

The Agency stated that

while t~cI~no$ically feasible noise reduction measures existed

for fcr~u

ib

~

these measures were not technically feasible or

economic~Y’~

reascnable for Rockford..

The Agency also stated

that

grantiny

_he z~oposed site—specific opercitional level would

not

endanç~r

~rhe

b~irtngof area residentF.

~

3oar~proposes granting the

~it~speciffic operational

1ev~1

it

uestc’i by Rockford,

Rockford

13

an existing impact

forgin,

~ ratm~which is presently ~n violation of §901,105(c),

Whi~~e

c

~,Y

i.

e

i~

technically po~ib~

its extremely high cost

makes

it

ecou~uicallyunreasonable for Ro~kfordat this

time..

On

a pra’t~ ci ~evet

compliance meacures w~ d decrease production

by iiipeoing tht~flow of materials vithir

the forge shop, create

an unac~’ept&”~1ework environment for ~he er~ployeesand probably

result

the closing of the facility

The record indicates that

there have been no citizen complaint

about the noise from area

residerts sin a the implementation of nois~reducing

modificat~o~s..There is also no danger of hearing loss to area

residents

The site—specific operatio a

level will be limited

to

12 halnrer3 that way operate between 6

00 a

m..

and 10:00 p.m.

Monday through Saturday.

No ~peci±ic numerical noise

level

liiitations are being

imposed

a) though it is assumed that noise levels will

approxiriat~t~iosetestified to by Rockford and its witness,

Rockford shoi Id make efforts to lessen roise levels in the future

as equ pment

i

replaced and new technology for noise suppression

bec mes available..

In the event that noise leveis from the forge

shop becoxr~ex3easive, citizens have the rioht to initiate

proc~

I’~angethe rule which accompanies this opinion.

Th~ope a~ionalplan set out in this Order will be

incorpo~tedinto 35

111.. Mm,

Code

901

17

Rockford will be

requrr~ to

ip y with the plan upon fitrnq with the Secretary

of Stat

£ lilinois

---

5

ORDER

35

Ill..

Adm.. Code

901.117

will

read

as

follows:

Section 901.117

~

~ionalLevel

~

owners

of

the

forg,in~

~~litlocateL~t2031NinthStreet,Rockford,IUinois

~com1wit~h~ollowi~

~

level or are otherwise subj~ectto

Section

901. 105

(C);

a)

~1ve

for in

hammers

~~ne

time;

and

b)

Shall

operate

its

forging

hammers

only

between

the

hours

of

6:00 a,m..

and 10:00

p.m.

Monday

~

Saturday.

35

Ill..

Adm.

Code

901.117

is

directed

to

First

Notice..

IT

IS

SO

ORDERED.

I,

Dorothy

M.. Gunn,

Clerk of

the

Illinois

Pollution

Control

Board, hereby

certify

that the above Order was adopted on the

~

day of

~

1984 by a vote

of

_______________

Illinois Pollution Control Board

59-307