ILLINOIS POLLUTION CONTROL BOARD
    September
    6,
    1984
    IN THE HATTER OF:
    )
    )
    THE PETITION OF WAGNER CASTING
    )
    COMPANY FOR A SITE—SPECIFIC
    )
    R83-35
    OPERATIONAL LEVEL PURSUANT TO
    )
    35 ILL.
    ?~DM,CODE 901.105
    )
    ADOPTED
    RULE.
    FINAL
    OPINION.
    FINAL OPINION OF THE BOARD
    (by 3. Marlin):
    On November 29,
    1983 Wagner Casting Company
    (Wagner)
    petitioned for
    a site—specific operational level for its forging
    shop as an alternative to compliance with the noise limits
    contained in 35 I1.
    Adm. Code 901.105
    (old Rule 206 of Chapter
    8).
    A public hearing was held in Peoria, Illinois on February
    15,
    1984.
    The Honorable Gary K. Anderson, Mayor of Decatur
    was the only member of the public who attended and he testified
    in support of the petition.
    Two
    public comments in support
    of the petition were also received.
    This hearing was originally
    scheduled with those of four other similar forging noise cases
    involving central Illinois shops in order to conserve the
    time and funds of all involved parties.
    Due to a scheduling
    error the other four had to be rescheduled.
    Wagner requested
    that its hearing proceed in Peoria since considerable delay
    would occur if the hearing was moved to Decatur.
    Rule 206(d) allows an existing forging shop to petition
    the Board for a site—specific operational plan which will
    limit noise emissions from the shop.
    Petitioner must demonstrate
    that it is technically and economically infeasible for its
    shop to meet the numerical limits.
    Petitioner must also propose
    measures to reduce impulsive noise where possible and assess
    the consequential health and welfare impacts on the surrounding
    community.
    Wagner is located at the southeast corner of Jasper and
    Sangamon Streets in Decatur, Illinois.
    Railroad switching
    yards are located to the west, south and southeast of the
    forge shop.
    Wagner’s foundry operations are to the east.
    Corporate offices and parking facilities are to the north
    and northeast.
    The Torrence Park urban renewal area is north
    of the parking lot.
    The Decatur Boys Club is northwest of
    the forge,
    located at the northwest corner of Jasper and Sangamon
    Streets.
    A recreational area i~westand northwest of the
    Boys Club.
    The nearest residences to the northeast and northwest
    of the forge are over 300 yards distant.
    Those to the south
    are screened by
    the
    railyards and numerous commercial buildings.
    80-59

    —2—
    The forge shop operated at the location since 1926 under
    a former owner.
    Wagner bought the forge shop in August, 1979
    and operated it until September, 1981 when operations were
    suspended for economic reasons.
    The equipment was mothballed
    in anticipation of reactivation.
    Wagner is continuing its
    foundry operations.
    It intends to sell the forge shop.
    The forging facilities are in one building which includes
    9 furnaces,
    5 coining presses, and
    9 Erie drop hammers in
    the following sizes:
    1,500 lb.(3);
    2,000
    lb.
    (4); and 4,000
    lb. (2).
    The forge building itself was built in 1926 and
    is
    con~tructcd
    of corrugated
    steel siding
    azid
    brick.
    The shop
    requires extensive ventilation for cooling where the furnaces
    reach 2600cF.
    There are approximately
    5 large door openings
    and
    2 smaller doors
    to the outside.
    There are
    3 large roof
    ventilators which draw hot air out of the building.
    Ten
    ventilators at wall level draw fresh air into the building.
    Noise escapes through these openings.
    Wagner requests that it be allowed to operate
    3
    shifts
    at the site and add a hammer in the future.
    Hours of operation from 1979 through 1981 were 5:00 a.m.
    to 1:30 p.m. and 1:30 p.m. to 9:00 p.m.
    Although the potential
    buyer of the forge testified that initially there would be
    1 to
    2 shifts, the petition is for allowing
    3 shifts.
    Page
    12 of the petition requests
    3 shifts with starting times of
    6:00 a.m.,
    2:00 p.m. and 10:00 p.m.
    The potential buyer testified
    he would prefer to start at 5:00 a.m.
    In a post—hearing letter
    filed March 13, Wagner reiterates that if the Board does not
    grant the
    3 shift relief, that it allow the first shift to
    begin at 5:00 a.m.
    Production decreased from 1979 through 1981, as will
    be shown in the table below.
    This resulted in less blows
    of the hammers which resulted in less noise
    (Pet. at 5~6,
    7).
    Total no. of forgings
    No. of
    Tonnage of all
    on hammers
    blows/yr.
    forgings
    1979
    3,986,934
    29,098,578
    4,390
    1980
    2,894,374
    20,717,350
    3,620
    1981
    1,089,596
    7,939,768
    2,180
    The regulations of the Board define
    2 methods of measuring
    sound.
    The definition of dB(A), or A—weighted sound
    level
    in decibels, is found in
    35
    Ill, Adm. Code 900.101, as is
    the definition of Leg,
    or equivalent continuous sound pressure
    level in decibels.
    Essentially, dB(A) measures the noise
    level at the peaks while Leq measures the average noise
    level over time, including peaks and background noise.
    60-60

    —3—
    Permissible impulsive sound levels for existing forge
    shops are found in
    35 Ill. Mm. Code 901.105.
    The impulsive
    sound level emitted to residences
    (Class A land) cannot exceed
    58.5 Leq during the day or 53.5 Leg at night.
    As to commercial
    establishments (Class B), the level cannot exceed 64.5 Leg.
    Actual measurements were taken in 1980 by ETA Engineering
    Inc.
    for the former owner of the forge shop
    (Exh E to the
    petition).
    These dB(A) readings were placed on a contour
    map of the area (Exh C to the petition).
    An expert for Wagner
    transformed the dB(A) readings to Leq readings and compiled
    another contour map (Exh D to the petition.)-~ Referring to
    Exhibit
    D1 the southeast corner of the Boys Club (Class
    B)
    will be subjected to 80 Leq.
    The building will face levels
    between 70 and 75 Leq.
    This is approximately 6-10 Leg over
    the 64.5 Leq limitation for Class B land.
    The many residences
    listed on Exhibit C have been eliminated through the city’s
    Torrence Park urban renewal project
    (R at 10).
    Wagner asserts
    that no residences are exposed to sound levels in excess of
    Rule 206(c).
    The
    3 residences at the intersection of Orchard
    and Lowber Streets are expected to be subject to the nighttime
    level of 53.5 and no more.
    During night time the background
    noise, which includes the railyards and busy highways, should
    be lower, reducing the Leg sound level(Pet. at 10).
    The ETA report
    (Exh.
    E to the petition) developed
    4 proposals
    for reducing noise emissions by 5,
    10,
    15 and 2OdB(A)
    (Exh
    E at 15).
    The recommendation for a 5dB(A) reduction includes
    closing all exterior doors and installing additional roof
    and sidewall fans.
    Wagner states that this would interfere
    with proper ventilation for the shop and affect the worker~s
    health
    CR at 64).
    The shop doors are open all of the time
    in the summer
    CR at 48).
    Other ETA suggestions for successive
    5dB(A) noise level reductions were to install silencers
    (2800 lb.
    a piece), use 3/8 inch thick asbestos board and
    1/8 inch thick steel panels, and install baffles
    (Exh B to
    Pet. at 15).
    If the ventilators were installed it is
    highly likely that the building would require reinforcement
    at additional cost in order to bear their weight
    (R at 80,
    81).
    To date,
    no abatement measures have been implemented
    by Wagner.
    The corporate office was constructed between the
    forge and residences to the north and northeast, which may
    or may not give incidental relief to those residences.
    Testimony
    has shown that barriers inside the plant would impede the
    flow of airr traffic,
    and movement of materials
    CR at 83).
    The ETA report addressed the cost to reduce noise emissions
    LThe conversion formula used was SLB
    =
    Leg
    +
    5dB(A),
    found on page
    8 of Wagner petition, which refers to Exh.
    E,
    p 5.
    60-61

    —4—
    by SdB(A)
    EExh.
    B at 11-141.
    To reduce the noise level by
    SdB(A),
    $234,000 would be spent
    (Pet. at
    14) while the forge
    facility is worth only 1/2 to 3/4 million dollars
    CR at 52).
    The Department of Energy and Natural Resources issued
    a negative declaration on March 7, 1984 obviating the need
    f-or an economic impact statement.
    The Illinois Environmental Protection Agency
    (Agency)
    has concerns, some of which are the following:
    (1)
    whether Wagner i~an “existing”
    or a
    ~
    forging
    facility;
    (2)
    whether nighttime operation noise levels will truly
    be within the applicable limits;
    (3)
    whether economic reasons are enough to reject the
    abatement measures.
    This forging facility is a property—line—noise--source
    according to 35 Ill. Mm.
    Code
    900.101.
    The forge also
    is
    an existing property-line—noise source as defined in
    35
    111.
    Mm.
    Code 900.101 for
    2 reasons.
    First, the facility was
    built prior to August
    10,
    1973.
    Second,
    its C land use
    classification did not change since it was only temporarily
    shut down.
    Therefore, Wagner is subject to noise limitations
    of 35
    Ill. Adm. Code 901.105(c) unless site—specific operational
    relief is obtained.
    The record contains evidence that nighttime
    operations will meet the sound limitations.
    The economic
    cost of
    a noise abatement program is clearly prohibitive~.
    The only apparent noise violation will occur at the Boys
    Club.
    The Club is built on land donated by Wagner at a time
    when the hammers were operating (R at 12).
    The Club wanted
    the land so as to be next to the outdoor recreational area.
    The Club opened in late 1983
    CR at 21).
    The Club~sbuilding
    is constructed of brick and the
    2 walls facing the forge shop
    are without windows.
    The City of Decatur has actively planned an urban renewal
    project in the area to act as a buffer between industry and
    residences.
    The City supports Wagner as does the Macon County
    Board
    (R at
    9;
    Exh.
    6).
    The operation of the forge shop is,
    therefore, consistent with the planned use of the area.
    Wagner~s
    expert testified that operation would not pose a threat to
    the public health
    CR at 133).
    There have never been any citizen
    complaints
    (R at 42); Agency Rec.
    at 1).
    The additional jobs
    C40—50 for
    2 shifts) will help the economy of the City of
    Decatur.
    The sound abatement m&asures appear to be economically
    unfeasible.
    60-62

    —5—
    The Board proposes granting Wagner’s site specific operational
    level for three shifts and the operation of
    9 hammers at one
    time.
    Section 23 and 25 of the Environmental Protection Act
    evince an intent to lower noise emissions rather than add
    to them.
    Ill.
    Rev.
    Stat.
    1983,
    ch.
    111½, pars.
    1023,
    1025.
    Rule 206(d) provides that petitioner propose measures to reduce
    impulsive noise.
    The Board is constrained to limit the number
    of hammers operating at one time to nine.
    Under this provision
    Wagner could operate up to
    9 hammers of any size at one time.
    During the first notice period Wagner and the Agency are asked
    to provide written comment on the following:
    whether the replacement of
    1 or more existing hammers
    with
    1 or more hammers of varying size would cause the
    petitioner to exceed the estimated noise levels stated
    in prior testimony.
    No specific numerical noise level limitations are being
    imposed, although it is assumed that noise levels will approximate
    those testified to by Wagner and its witnesses~ Wagner 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 following operational plan as set out in the attached
    Order will be incorporated into
    35 Ill.
    Adm. Code 9Ol.ll3~
    Wagner and future owners of the forging facility will be required
    to comply with the plan upon filing with the Secretary of
    State of Illinois.
    I,
    Dorothy M.
    Gunn,
    Clerk of the Illinois Pollution Control
    Board, h~rebycertify that.~the above Opinion was
    adopted
    on
    the
    ~~-
    day of
    ________
    _____
    1984, by a vote
    _____________
    I
    ~
    ,~/.
    ____
    ~
    Dorothy~Th~~ci.
    Illinois Pollution Control Board
    60-83

    Back to top