ILLINOIS
    POLLUTION CONTROL BOARD
    December
    20,
    1984
    IN
    THE MATTER OF:
    )
    ROCKFORD DROP FORGE COMPANY
    )
    R83~30
    PETITION FOR A SITE~-SPECIFIC
    )
    OPERATIONAL LEVEL PURSUANT
    TO
    CHAPTER 8,
    RULE 206(d) OF THE
    )
    RULES
    AND
    REGUlATIONS OF
    THE
    )
    ILLINOIS
    POLLUTION CONTROL
    BOARD
    ADOPTED RULE.
    FINAL OPINION
    AND
    ORDER.
    OPINION AND
    ORDER
    OF THE BOARD
    (by
    B.
    Forcade):
    On August
    2,
    1984,
    the
    Board
    proposed to adopt a new rule,
    35
    111.
    Adm. Code 901.117,
    which
    provides site~specificrelief
    from
    the
    Board~snoise regulations.
    First notice of
    this proposal
    was
    published
    at 8
    Ill,
    Reg.
    15274,
    on
    August 24,
    1984.
    The
    first notice comment period
    expired
    on
    October 8,
    1984,
    The
    Administrative Code Unit
    submitted
    a comment on September
    10,
    1984, regarding Illinois Register first notice format.
    No other
    comments were received.
    The
    Board
    made a non-substantive change
    in the wording of the proposed
    rule.
    By order
    of
    the
    Board dated October
    10,
    1984, the proposed
    rule
    was
    submitted to
    the Joint Committee on Administrative Rules
    (“JCAR~).
    JCAR
    second notice
    review commenced on October 22,
    1984.
    JCAR issued a Certification of No Objection to this rule-
    making
    on November
    8,
    1984,
    ending the second notice period.
    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 Board
    appreciates the contribution of
    David G. Mueller
    who
    assisted in
    drafting
    this Opinion.
    62~71

    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
    DENReS
    finding.
    The
    regulatory
    scheme
    for
    existing
    forging
    operations
    requires
    that the Petitioner either
    (i)
    comply
    with
    the
    noise
    prohibitions
    contained
    in
    Table
    F of Rile 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).
    These
    rules have been recodified
    as
    35
    Ill.
    Adm.
    Code 901,905(c)
    and
    (di.
    The noise prohibitions
    in §901,905(c) vary for different
    classes of receivers and for
    daytime
    and nighttime periods.
    A
    petition under §901,905(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 where possible and assess the consequential
    health and welfare impacts on
    the
    surrounding community.
    Rockford is located at
    2031
    Ninth Street in Rockford,
    Illinois.
    Rockford~sfacility occupies approximately 18 acres and has been
    in operation since
    1911.
    At that time,
    the adjacent land was
    either vacant or industrial
    (P.. 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 are ap-
    proximately 500 feet south of Rockford’s facility
    (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
    lbs.
    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
    (R,
    58).
    Rockford currently
    employs 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
    rain
    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.
    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
    S2~72

    3
    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 ustack
    effect” whereby air flows through the open sides
    of the b.iilding
    and is drawn up and out through the roof
    (R. 58).
    This natural
    ventil~tionsystem 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
    a.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
    blow/yr.
    forgings
    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
    The regulations of
    the
    Board define two methods of measuring
    s~ind.
    The definition of dB(A),
    or
    A
    weighted
    sound
    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
    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
    III.
    Adm.
    Code
    90L~105,
    The
    impulsive
    sound
    level
    emitted
    to
    residences
    (Class
    A
    land)
    cannot
    exceed
    58.5
    Leg,
    during
    the
    day
    or
    53.5
    Leg at
    night.
    Actual
    measurement
    of
    sound
    were
    taken
    around
    the
    Rockford
    facility
    by
    George
    F.
    Tamperman,
    an
    expert
    in
    the
    area
    of
    noise-control
    engineering.
    Based
    on
    these
    measurements,
    Kamperman
    predicted
    that
    the
    highest
    level
    at
    the
    nearest
    receiver
    would
    be approximately 64 Leq (R.
    110).
    Approximately
    85
    Class
    residences
    are
    exposed
    to
    forging
    noise
    in
    excess
    of
    the
    regulatory
    standard,
    Eighty—five
    Leg
    is
    the
    maximum
    or
    “worst
    case”
    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
    62~73

    4
    exhaust
    system by installing consolidated steam vents,
    This
    modification
    has
    reduced
    noise
    from the facility
    (R. 64-65),
    Rockford
    also
    removed
    the
    hammers
    nearest
    the
    closest
    residences
    from
    the
    east
    and
    southeast
    portion
    of
    the
    shop
    (R.
    67),
    There
    have
    been
    no
    citizen
    complaints
    since
    these
    modifications.
    Rockford
    has
    investigated
    methods
    of
    compliance
    with
    the
    Board~s noise
    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
    material,
    constructing
    a
    double-door
    entrance
    and
    installing
    accoustical
    louvers
    (R.
    61).
    Additional
    mechanical
    ventilation
    would
    have
    to
    be
    installed
    on
    the
    roof
    (R.
    62).
    The
    roof
    currently
    could
    not
    support
    any
    additional
    loading
    and
    would
    have
    to
    be
    reinforced
    (R,
    60).
    These
    modifications
    would
    cost
    between
    $100,000
    and
    $300,000
    (R,
    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
    (R.
    71).
    The
    Agency,
    in
    their
    written
    comments
    on
    the
    proposal
    filed
    January
    23,
    1984,
    did
    not
    challenge Rockford~squalification for
    site—specific relief on
    the
    basis
    that
    it is
    an “existing impact
    forging operation,” nor did they question the fact that the
    petitioner was violating Rule 206(c),
    The Agency stated that
    while technologically feasible noise
    reduction
    measures
    existed
    for
    forge
    shops,
    these
    measures
    were
    not
    technically
    feasible
    or
    economically reasonable
    for
    Rockford,
    The Agency also stated that
    granting
    the
    proposed
    site-specific
    operational
    level
    would
    not
    endanger
    the
    hearing
    of
    area
    residents,
    The Board proposes granting the site-specific operational
    level
    requested by Rockford,
    Rockford 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 Rockford 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
    probably
    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
    implementation
    of
    noise
    reducing modifications.
    There
    is
    also
    no
    danger
    of
    hearing
    loss
    to
    area
    residents,
    The
    site-specific
    operational
    level
    will
    be
    limited to 12 hammers
    that
    may
    operate
    between
    6:00
    a.m.
    and
    10:00
    p.m.
    Monday
    through
    Saturday.
    62~74

    No specific numerical noise level limitations
    are being
    imposed,
    although
    it
    is
    assumed
    that
    noise levels
    will
    approximate
    those
    testified
    to
    by
    Rockford
    and
    its witness,
    Rockford 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 he
    incorporated
    in
    35
    Ill, Adm.
    Code
    901.117,
    Rockford will
    be
    required
    to comply upon the filing
    of
    the
    rule
    with
    the
    Secretary
    of
    State
    of
    Illinois.
    ORDER
    The
    Board
    hereby
    adopts
    the
    following rule,
    to be
    codified
    as 35
    Ill.
    Adm.
    Code
    901.117,
    and
    instructs the Clerk to
    file
    the
    rule
    with
    the
    Secretary
    of
    State:
    TITLE
    35:
    ENVIRONMENTAL
    PROTECTION
    SUBTITLE
    H:
    NOISE
    CHAPTER
    I:
    POLLUTION
    CONTROL
    BOARD
    PART
    901
    SOUND EMISSION STANDARDS AND
    LIMITATIONS
    FOR PROPERTY
    LINE-NOISE-SOURCES
    ~ction90l.ll7
    ~roForeComan
    ~ionalLeve1
    ~ordDroForeComanandfutureownersoftheforin
    ~nois,
    iththefol1owinsi~ona1
    a)
    ~tenomorethantwelveforinhammers
    ~netime;and
    b)
    ~
    ~of6:0Oa.m.and1O:OO,n~,Monda
    Sa
    rd a
    IT
    IS
    SO
    ORDERED.
    I,
    Dorothy
    N.
    Gunn,
    Clerk
    of the Illinois Pollution Control
    Board,
    hereby~c~tify
    that
    tI~
    above
    Opinion
    and
    Order was adopted
    on the
    day
    of
    ~
    1984 by a
    vote
    of
    ~
    ~
    U~Fothy M.
    G
    nn,
    Clerk
    Illinois
    Pol ution
    Control
    Board
    62~75

    Back to top