P

LLtJ2ION CONTROL

BOARD

Aj~,ust

2,

1984

R8 3—29

for

a

3~~~~3pec ~c O~

Leve1

~ureu~t~

~

~

Rule ~6(d)

of th~Pu ~:

~e~l

~ion

Pol~luJonCorttzi

~i

u’~~~r

Ttf~

B aRu

(by ~

Forcade):

This matter

cm~’°b~torethe Board on a

petition filed on

November 11~1984, by lorgings and Etarnpings,

Inc0 (~F&

Se’)

for

a site-specific operational

level for its

forging shop as an

alternative to cornplia~’ewith the noise

limits contained in 35

Ill. Adm~Code 90L105

(old Rule 206 of

Chapter 8)~

A

public

hearing was

held

on March

29, 1984,

in

Hampshire,

Illinois,

This

hearing

was

scheduled

with

those

~f

three other Illinois forging

shops

in

order

to

con~erve the

time

and resources

of

the parties

involved~.

No

p~ib~~

~c

~rony

or

comments

were received,

The Departrner~~f

nergv and

Natural Resources

(~DENR~)

issued a statement of noga~ve eclaration of

economic impact on

April

19

1994, oh i~inat~teneed for an

economic impact

staterneut

On

~

y

i, th~Economic

and Technical

Ad

sory Corn

tu~e

r

~d

th

t~~i

DENR’s

finding0

The

regulatory

ech ~c

for

e~c~

sC~ng forging

operations

requires

that

the

Peti’’crc

either

I~)

comply

with the noise

prob

~it~

nr~c~

aL~3

~

r

R~le 206(c)

no

later than

fifteen months ±o1lo~irglie effective date

of the Rule, or (ii)

seek a permanent ci e~s?°cfic operational

level as

provided in

Rule 206(d)~ These ru~~s lave been recodified

as 35 111. Adm0

Code 901 905(c)

ard

~

The noise prohibitions

in S9010905(e)

‘ary for iltfer’~c~ e~of receivers and for daytime

and

nighttime periods~

I cetition under 8901,905(d)

must demonstrate

that it is technica ly and econorn~cal1yinfeasible

for its shop

to meet tIe nurneric~1 imits of S90l,905(c)~ A

petition

must

also propose rneasurec to reduco impulsive noise

where

possible

and assess the ~

‘g~en’~ulhealth and welfare

impacts on

the

surrounding community

F &

S

is lceate~a

l~2523rd Avenue, in

Rockford,

Illinois0

F

& S~sfacility o~cupc~ipproximately one

acre

and was

built in

1920 when _he al)ac~t Ia !l was either vacant

or industrial

(R0

33-4)~ At the prer~n~

tiiim

the

facility is

surrounded

by

industrial aid corr ~ciil r~oprty on the

southeast

and

the

west,

residential pr3perty iinediateiy to the

north

and

industrial

The Board ackno~l~djestIe contribution

of

David G. Mueller

who was the administrative ~ssrstant for

this

rulemaking0

---

property to the nort~i.and nrtheast

(T~, 57)~

There are 75 Class

A

residences that rL~e1~eforging noise in

excess of the

regulatory 1imits~

The fac~lityconsists of

two buildings, one

of

which houses ci

forging hammers and

eight furnaces

(R. 58~9)

The forge

hammers vary in

s

ze from 1,000 pounds

to 3,000 pounds

(R~

58),

This bu~c1~zc~

~

steel doors that

roll up and down on

the north, west and e~

~l1s~

The root also

opens

(R0 59~60).

F

&

S

currently ernpic~

peo~ie

The forging p~.c~s~~r~:~t

of

icating carbon or alloy

steel in furnaces t

q

y 2350 degrees

Fahrenheit and

then forcing the

It~

~d ~ie~s cc:

ci two dies0

The upper die

is attached to a g~ a

ci

~h

‘ower die is attached to the

forges

The meta

i.

chap~t~cugf p essure exerted by the ram

or forge hammer, for~ingthe workpiece into

the impression

on the

dies~ The sound produc~dthrough this process is impulsive and

originates primarily fi

iii

the impact between the upper and lower

die and the workpiece~ There

~s a corstant flow

of

materials

between the furnace,

torg,~. end coo~ingarea

(R0 65)~

F

&

S

manufactures

forgings ;oz the automotive,

truck,

tractor

and

machine tool

markets,

The nature

of the forge operation

creates on extremely hot

work environments

The furnaces

~equire

a tremendous amount of

oxygen and

emits a great ct~alof neat

The

cooling workpieces

also radiate

heat into the forge shops

Consequently, the shop

required extensive

ventilation which is provided

by the steel

doors that roll

up ana down and the ability

of the roof to open0

This system

creates

a “stack effect

whereby

air flows through

the open

sides of th. bu~dingand

is drawn

up and out through

the roof (R~

5’~—d0

rh~urc ventilation

system is

effective and wioe~ut~.~~cd by the forging industry,

The open

sides of the buildrrg also facilitate the free

movement

of

material in and

out of the forqt. shops

Noise

escapes through

these roof and s~ue pcn g~

F

&

S

currently operates its forging

hammers from 6:00 a,m0

to 2:00 p~m0five days per week~

Historically, F &

S

has

operated from 6:0’ ~

intil 6~00p~rn~five

days per week, with

occasional work

on Saturdays from 6:00 a,m, until

12:00 noon,

The Petitioner,

in a post—hearing submittal,

requests a

site—specific

level that

gould allow them

to operate no more than

six forging

hammers at any one time during the

hours of 6:00 a,m,

and 6:00 p~m~

Monday tfrough Friday and 6:00

a,m0 and 2:00 p,m0

on Saturday0

Produ~t~on

has fluctcated over

the last few years0

Production

levels have declined slightly since

1981

as is shown

by the table

below~

The recent decline in

production

is

expected

to stabilize

during l983~

Total

Not,

of forgings

No,

of

Tonnage of all

~hammers

~

1980

3,7~0000

30,240,000

2,833

1981

4,435~00~

35,880,000

3,363

1982

2,987,744

23,902,000

2,241

---

3

The regulations

of the Board

de~~

~o

methods of measuring

sound,

The

definition

of

dB(A),

or A

-

‘teighted sound in

decibels,

is

found

in

35

Iii,

Adm

Cod~‘0O~l0l,

as is

the

definition of Leq, or equivalent

c~cntninussound pressure level

in decibels0

Essentially, dB(A)

neasur~sthe noise

level

at

the

peaks

while Leg measures the avert ge rorse level over time,

including

peaks

and

background

nei-c

Permissible impulsive sound

i~

1

a

existing forge shops

are found

in 35

I11~

Adm,

Code

9C1

t~-~impulsive sound

level emitted to residences

(Class ~

c~not exceed 58.5

Leg, during the day or 53,5

Leg at

ii

Actual measurement of

sound were taken around the

F

&

S

ra

b

George F.

Ramperman,

an expert in the

area

I

c~

ntrol engineering.

Based on these measurements,

Yamperrr

~ ~dicted that the highest

level at the nearest receiver

wou~dbL. a ~roximately 78 Leg

(R.

107—l07)~ Approximately 75

Class

r

ences are exposed to

forging noise in excess of the

re ul

y

ardard,

Seventy~eightLeq is the maximum

or

cr~t~aae~ situation.

F

&

S has received no citizen comp1ain~s

~ ~l inois Environmental

Protection

Agency did

receive

thre.~

wpl&nts in 1972 and 1973,

a

period

of high activity at

the forge.

In 1977, F

&

S installed

a

new

roof

with interior

baffles

to daiip~n the sound and began

operating with the sliding

doors partialiy closed0

These

modifications

resulted

in

approxirna’~lyan eight decibel reduction

in noise emitted from the

facility

A,

69).

$ince these modi-

fications, which cost

$30,000, ther

lava ceen no citizen

complaints

(R. 110,

113),

F

&

S

has investigated

metho~

f

a p iance with the

Board~snoise regulations,

To aci

upi cnce,

it would be

necessary to rebuild the entire

it

an essential y

closed structure.

Mechanical

venti -t~oi~,ouIdreplace the

present natural draft

system and

t~~tT

nc~ would have to be

redesigned

(R. 107).

Material

flo

~

e

altered,

Productivity would probably

decrec

dut~ o the enclosed work

environment and the inhibited

material fo

patterns that would

result

(R. 64),

Because of the

ext~nsv~rebailding that would

be

required

and the current

lack of soaca at the facility,

I

&

S

would probably relocate their

facil~tyelsewhere

(R.

70),

The Illinois Environ~ntal

Pro~ect

ri Agency (~Agency”)in

their written comments on the

propocal fale&January 20,

1984 did

not challenge F

& S~s

qua1iflcatio~ifor ~ite~specifie relief on

the

basis

that it is an ~existing

~LIp~t

torging

operation~,nor

did

they

question the fact that

the pe~itionerwas violating Rule

206(c),

The

Agency stated that

whi1~technologically feasible

noise reduction measures existed

for

f ~ge chops,

these

measures

were not technically feasible

or

~o

omically

reasonable

for

F

&

S,

The Agency also stated

that

grartir

the proposed

site~specificoperational

level

woul~

rot

endanger

the hearing of

area residents.

---

4

The

Board proposes granting

the site—specific operational

level requested

by F

&

S.

F &

S

is an existing impact forging

operation which is presently in

violation of §901,105(c),

While

compliance is technically possible,

its extremely high cost

makes

it

economically unreasonable for F

&

S

at this time,

On

a

practical

level, compliance measures

would decrease production

by

impeding the flow of materials

within the forge shop, create

an

unacceptable work environment for

the employees and result in

the

closing of the facility.

The record

indicates that there have

been

no citizen complaints about

the noise from area residents

since the installation of a new

noise—reducing roof,

There

is

also no danger of hearing loss

to area residents,

The

site—specific operational level

will be limited to six hammers

that may operate between 6:00 a,m,

and 6:00 p0m. Monday through

Friday and 6:00 a.m. and 2:00

p.m0 on Saturdays,

No specific numerical noise

level limitations are being

imposed, although it is assumed

that noise levels will

approximate those testified to by F

&

S and its witness,

F

&

S,

at hearing, stipulated that if

site—specific relief were granted,

it would continue to run its

facility consistant with the

operational changes initiated in

1977.

This includes the

re-

quirement that the north doors of

the facility be opened no

more than four feet, unless wheather

conditions makes this

impractible

(R. 119—120).

The site—specific relief granted

today is premised on this continued

practice.

F &

S

should make efforts to lessen noise

levels in the future as

equipment is replaced and new

technology for noise suppression

becomes available.

In the event

that noise levels from the

forge

shop

become excessive, citizens

have the right to initiate

proceedings

to change the rule

which accompanies this opinion.

The operational plan set out

in this Order will be

incorporated into 35 Iii.

Adm. Code

901.116.

F &

S will be

required to

comply with the plan

upon filing with the Secretary

of

State

59-300

---

ORDER

35

III.

Adrn, Code

901.116

will

read

as

follows:

Section

~L1l5

~nsand

St~mp~s

Inc.

~te-~cifi~Q2~rationa1

Level

~

owners

of

the

~

Rcdkford1

Illinois

shall

corn

1’

with

the

followin

gte-s

cc

tic

o~e~tiona

level or

is oterwise si~jec~t

to

Section

901. 105(c):

a)

Shall

operate

no

more than

six

fo~~~am~rs

at

any

one

time;

and

b)

Shall

~p.erate its

nh~rner.!on1between

the

hours

of 6:00

a,m,

and 6:00~~n~

throu

h

Friday

and

6:00

a,m.

and

2:00

p.m.on

~ra.

35

Ill.

Adm,

Code

901.116

is

directed

to

First

Notice,

IT

IS

SO

ORDERED

I,

Dorothy

M.

Gunn,

Clerk of

the

Illinois Pollution Control

Board,

hereby

certify

that

the

abov~ Proposed

Opinion and

Order

of

the

Board was adopted on the~~

day of

~

1984

by

a

vote of

~D

0

~

/~it~J

__

Dorothy

M’.

Gunn,

Clerk

Illinois

Pollution

Control

8aard