ILLINOIS POLLUTION CONTROL

BOARD

~ugust

2,

1984

IN

THE

MATTER

OF

THE

PETITION

OF:

CORNELL FORGE,

HAMPSHIRE

DIVISION

R83—26

for

a

Sita~Specific

Operational

Level,

Pursuant to Chapter

8, RUle

206(d)

of

the Rules and Regulations

)

of

the

Illinois

Pollution

Control

)

Board

)

PROPOSED

RULE,

FIRST

NOTICE

PROPOSED OPINION

AND

ORDER

OF

THE BOARD

(by B0 Forcade):

This matter comes before the

Board

on a petition filed on

November

15,

1983, by Cornell Forge,

Hampshire

Division

(“Cornell’~),

for

a site~specific

operational

level for its forging shop as an

alternative

to compliance with the noise limits contained in 35

Ill, Mm, Code 901~105(old Rule

206 of Chapter 8).

A

public

hearing was held

on March 29,

1984,

in Hampshire,

Illinois.

Two

members

of the public,

Robert Kudlicki, the village president and

Frederick

G0

Modde, the township supervisor, testified in support

of the petition,

No

other

public testimony or comments were received,

The Department of Energy and Natural Resources

(~‘DENR’~)

issued

a

statement of negative declaration of economic impact on

April

19,

1984, obviating the need for an economic impact statement,

On July

18,

1984, the Economic and Technical Advisory Committee

concurred with the DENR~sfinding0

The regulatory scheme for existing forging operations

requires that

th.~ Peti

ti

oner e~ith~r(I) ~oznp1yw~th 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

operational

level

as

provided in

Rule

206(d)0

These

rules

have

been recodified as 35 I1l~Adm,

Code 901.905(c)

and

(d).

The

noise prohibitions in S901.905(c)

vary

for different

classes

of

receivers and for daytime and

nighttime periods0

A petition under S901,905(d) must

demonstrate

that it is technically and

economically infeasible for its shop

to meet the numercial

limit.s of

S901,905(c).

A

petition must

also propose measures to reduce

impulsive noise where possible

and assess the consequential

health and welfare impacts on the

surrounding community~

Cornell

is located on Walker

Road in Hampshire, Illinois,

Cornell’s

operation occupies six acres and is surrounded on all

four

sides

by

land zoned for farming.

The

sole noise receiver is

Thei&i~dac~~i~dges

the contribution of David G0 Mueller

who

was

~9-291

---

2

a

farmhouse located approximately 1,000 feet northeast of the

Cornell facility

(R.

25).

The farmhouse is a Class A receiver.

The

Cornell

facility was built in 1953 and has been

in operation

since

that

time

UI.

25).

The

facility consists of three

~ne~story

buildings.,

Th~ forging

hammers

and

furnaces

are

located in a single one’~storybuilding

that runs north and south

of

the

property.

The building~slower

levels are composed

principally of a structural

frame with

sheet steel sides.

The

roof

:L~made entirely of sheet steel,

The

sheet

steel

sides

open

like

garage

doors

and

the

roof

also

can

be opened

(R.

36).

The

building

houses

seven

impact forge hammers

and

seven

furnaces,

There are two 1,500

lb.

hammers and

five

2,000 lb. hammers

(R,

28)~.

Cornell currently employs

28 people at

its

Hampshire

facility

(R. 4l)~

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

forge0

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

(R.

49).

Cornell

forges golf club irons and

various commercial and industrial

parts

(R.

33).

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 heat0

The cooling workpieces

also radiate heat into the forge shop.

Consequently, the shop

requires extensive ventilation which is provided by the garage-

type

side doors and the

ability

of

the roof to open.

This system

creates

a

~stack

effect’s

whereby

air flows through the open sides

of,

the

building

and

is

drawn up

and out through the roof (R.

67—

)~68)..

This natural

ventilation system is effective and widely

utilized

by

the

forging

industry.

The open sides of the building

also

facilitate

the

free

movement of

material in and out of the

forge

shop.

Noise

escapes

through

these roof and side openings

(R.

68j~.

Cornell currently operates

from 7:00 a,m, to 4:30 p.m.,

five

days per week

with

daily and

Saturday overtime,

Historically,

Cornell

has operated two shifts

from 7:00 a.m.

to 12:00 p.m.

The

Petitioner,

in a post~hearing

submittal,

requests

a

site—specific

level

that

would allow them to

operate no

more

than seven hammers

at

any

one

time for a maximum

period of 17 hours per day, Monday

through

Saturday.

Petitioner

proposes to operate in two shifts;

one from

7 a,m, to 3~30

p.m.

and the other on an alternating

basis,

either from 3:30 to 12:00 p.m. or from 10:30 p.m.

to

7:00

a.,m.,

Corne11~spresident testified

that

the

company

could

sig-

nificantly

reduce its electricity bill if it were allowed to

operate

a

nighttime

shift,

Cost savings would amount to 80

of

Corne1i~~

$60,000

to

$65,000 annual

demand charge for electricity

(R.

53).

---

Froduct~onha3 fluctuated over the last few years.

Production

1~velbhave declined slightly since 1981 as is shown by the table

below.

The volune of production in

1983

is expected to be the

c~raas

in

I982~

Tota. ~io of Forgings

No, of

Tonnage

of

all

3,133,0C0

13,158,000

1,005

3 426,000

14,388,000

1,123

3,352

OCO

14,079,000

1,011

Lh~regulations

f the Board define two

methods

of measuring

sound,

TI~edefinition of dB(A), or A

weighted

sound

in

decibels,

is found in 35

III. Mm,

Code 900.101, as is the definition of

Leq, or equivalent continuous sound pressure level in decibels,

Essentially, dB(M ~ea’s~ire’s

the noise level at the peak’s ‘~thile

Leg measures the average noise level

over

time,

including

peaks

and background noise,

Permissible impulsive sound levels for existing forge shops

are found

in

35

Ill. Adm,

Code 901.105.

The

impulsive

sound

level emitted to residences

(Class A’~1and) cannot exceed 58.5

Leg, during the day or 53.5 Leg at night,

Actual

measurements

of

sound were taken around the Cornell

facility

by

George

F. Kamperman,

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

62

Leq

(R.

72).

This

receiver, the farmhouse,

is the only

relevant

noise

receiver

in

terms of the regulations.

But for the

existance

of

this farm~~~

house, no petition for site—specific relief would be required.

Nc citizen comp1aint~fave been received about the noise from

Cornell~sfacility

(K. 46).

~oznell has ~rvestigated several methods of compliance with

the Board’s noise regulations.

Cornel1~sconsultant and expert

witness testified that the most economical and efficient method

of compliance would require closing all roof vents,

rebuilding

the north entrance of the building to make a sound lock type

vestibule, replacing the present fiberglass ‘wall panel.s with more

~ubstantia1 glass or cement asbestos board, and

sealing

the roof

vent system with thick cement asbestos

board.

A

mechanical

ventilation system would then have to be installed to exhaust the

heated air from the building

(K, 47~’48),

These

modifications

would zes’dt in an approximate 10dB reduction

(R.

97)

and

would

avhieve compliance with the regulations.

The capital cost for

these modifications are $225,000,

The building itself would

require structural strengthening to support the

new

vent

system

and roof silencers at a cost of $88,000.

Electric power for the

n~wvent system would cost $14,000. for

one

year

(R.

99—100),

Corneli~sexpert testified that other types of control methods

---

such as external grade-level sound barriers

would

be

acoustically

ineffective and would

ir.ipeda the flow of

materials

into

the

forge

shop

(K..

69-70).

The proposed changes also

affect the flow of

materials and would create an undesirable

~c1osed—in~ feeling for

the

erimloyees

R. 97—98

)

Corn~ilhas uct implemented any

control

measures

at

this

U~spresident testified that

denial of site—specific

relief would not result

in the immediate

closing of the Hampshire

facility~. Eventually, however, the facility

would

be phased out

of operation

(:7. 34

The

Il

1.inois Environnental

Protection

Agency

VAgency~) in

their writ.ten comments on the proposal filed

January

18,

1984,

did

not: challenge Cornell’s qualification

for

site—specific

relief on the basis that it is

an

~‘existing

impact

forging

oper—

ation~,nor did they question the

fact

that

the

Petitioner

was

violating Rule 206(c).

The Agency stated

that while

technolog-

ically feasible noise reduction measures

existed for forge

shops,

these measures were not technically

feasible or economically

reasonable for Cornell.

The Agency also

stated

that

granting

the

proposal

site—specific

operational

level

would

not

endanger the

hearing of area residents,

The Board proposes

granting

the

site—specific

operational

level requested by Cornell,

Cornell

is an existing

impact

forging

operation which is presently in

violation

of

901.105(c).

~1’ii1e

compliance is technically possible, its

extremely high

cost makes

it economically unreasonable for

Cornell

at this time,

On

a

practical level, compliance measures

would decrease production by

:Ls.peding the flow of materials within

the

forge shop,

create an

unacceptable work environment for the employees

and

result in the

eventual closing of the facility.

The

record indicates

that

there have been no citizen complaints

about the noise from

the

forginq operation and that there is no

danger of hearing

loss to

area residents.

Th~site—specific

operational

level

will

be

i1~jt~dto seven hammers that may operate a

total

of

17

hours

per

day, Monday through 3aturday.

~o

shifts

will be allowed;

one

from 7:00 a,m. to 3~30p.m. and the

other

from

either

3:30

to

l2~0Op.m. or from 10:30 to 7:00 a.m.

No specific numerical noise

level

limitations

are

being

imposed, although it is assumed

that

noise

levels will approximate

those testified to by Cornell

and

its

witness.

Cornell should

make efforts to lessen noise levels in

the future as equipment is

replaced and new t.echnology

for

noise suppression becomes available.

In the

event that noise levels

from

the

forge

shop

become

excessive,

~itizen~ have the right to

initiate

proceedings to change

th~

rule which accompanies this opinion.

~

operational plan set out in this

Order

will

he incor-

porated into 35 111. Mm,

Code 901,115,

Cornell

will

be

required

to

comply with the plan upon filing

with

the

Secretary

of

State

of

Illinois,

---

5

35 III

1~dm~C~c 901

115 w.~’ll read as follows:

~

~

C &~ati~nalLevel

Ccrne~orc~.

~..

~

ir~~i

~,

~

~

With

th’~. Ic

~-~pe

al

le ci_or are otherwi~

~

a

3an~~forinhammersa~n

u

t ne

an

b)

~ha

‘

~per

te

its

g~ammersonlonM~~da

ojSatnrda~~tqeenthehours of 7:00 a,m.to

330 ~

with ar

aud

2nal

shift that ma

run

from

~

to

00 anr.

33 IlL Adm.

Code 90

115

i~

directed to First Notice.

I,

Dorothy V

P ~n, Cerk of the Illinois

Pollution

Control

Board, hereby cer~i~yth~ the above Proposed

Opinion

and

Order of

the Board was a~op~sa

on the

~

day of

~

1984

by a vote of

~‘

—,

~thnnr~~

Illinois Pollution Control Board