ILLINOIS
POLLUTION
CONTROL
BOARD
December
20,
1984
IN
THE
MATTER OF:
FORGINGS AND STAMPINGS,
INC.
)
R83—29
PETITION
FOR A SITE—SPECIFIC
OPERATIONAL
LEVEL
PURSUANT
TO
)
CUAPTER
8,
RULE
206(d)
OF THE
RULE
AND
REGULATIONS
OF THE
LLL1NOIS
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,
3~
Ill.
Adm.
Code 901,116, which provides site—specIfic
relIef
from
the
Board~s
noise regulations.
First notice
ni this
proposal
was published
at
8
Iii.
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
ii
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
1~i1es
(“JCAR”).
JCAR
second
notice
review
commenced
on
October
22,
1984.
JCAR
issued
a
Certification
of
No
Oh~ection
to
this
rulemaking
on
November
8,
1984,
ending
the
second
notice
period.
This
matter
comes
before
the
Board
on
a
petition
tiled
on.
November
iT?,
1983,
by
Forgings
and
Stampings,
Inc.
(~F
&
pH)
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
p~h~:tc
hearin
was
held
on
March
29,
1984,
in
Hampshire,
Illinois,
This
hearing
was
scheduled
with
those
of
three
other
Illinois
forging
shops
in
order
to
conserve
the
time
and
resources
of
the
parties
involved.
No
p~iblic
testimony
or
comments
were
received,
The
Board
appreciates
the
contribution
of
David
G.
Mueller
who
assisted
in
drafting
this
Opinion~
The
Department
of
Energy
and Natural Resources
(HDENRH)
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~s
finding,
The
regulatory
~heme
for existing
forging
operations requires
that the
Petitioner
either
(i) 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
operational
level as provided in Rule 206(d).
These rules
have been
recodified as
35
Ill,
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
§901,905(d)
trust demonstrate
that
it is technically
and econo:~icallyinfeasible
for
its shop to meet the numerical
limits of §901,905(c),
A petition must also propose meas~resto
reduce impulsive
noise
where possible and assess the consequential
health and welfare impacts on the m~rroundingcommunity,
F
&
S is located
at 1025 23rd Avenue,
in Rockford,
Illinois,
F& S~sfacility
occupies
approximately one
acre
and
was hiilt
in
1920 when the
adjacent
land was either
vacant
or
industrial
(R.
53-54),
At the
present time,
the
facility
is surrounded by
industrial
and
commercial
property on
the
southeast
and
the
west,
residential
property
immediately
to
the
north
and
industrial
property to
the
north
and
northeast
(R.
57),
There
are
75
Class
A
residences
that
receive
forging
noise in
excess of
the regulatory
limits,
The
facility
consists
of two buildings,
one
of
which
houses
six
forging
hammers
and
eight furnaces (R~58—59),
The
forge
hammers
vary in
size
from 1,000 pounds
to
3,000
pounds
(P.
58).
This
hnilding
has
steel
doors that roll up and down on the
north,
west and east walls,
The roof also opens
(P. 59-60).
F
&
S
currently
employs
37 people~
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
(R.
65),
F
&
S
manufactures forgings
for
the automotive,
truck,
tractor and
machine tool markets,
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 steel
doors that roll up and down and the ability of the roof to open,
This system
creates
a ~stack effect”
whereby
air
flows through
the roof
CR.
59-60).
This natural ventilation
system
is effective
and widely
utilized
by
the forging industry.
The open sides of
the bnilding
also
facilitate
the free
movement of
material
in and
out of the
forge shop.
Noise escapes through
these
roof and side
openings.
F
&
S
currently
operates
its forging
hammers from
6:00
a.m,
to 2:00 p.m~
five days per
week.
Historically,
F
&
S
has
operated from
6:00
a.m.
until
6:00 p.m.
five
days
per week, with
occasional work
on
Saturdays from ~:00 a,m. until
12:00 noon,
The Petitioner,
in a
post-hearing ~submitta1,requests
a
site-specific
level
that
would all~wthem 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
through Friday and
6:00
a.m,
and 2:00 p.m.
on Saturday.
Production
has fluctuated over the last few years.
Production levels
have
declined slightly since 1981
as is shown
by the table below.
The recent decline
in
production
is expected
to stabilize during 1983,
Total No,
of
forgings
No.
of
Tonnage
of all
on hammers
—
blow
/
yr.
~
1980
3,780,000
30,240,000
2,833
1981
4,485,000
35,880,000
3,363
1982
2,987,744
23,902,000
2,241
The
regulations
of
the Board define
two methods
of measuring
sound,
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
ira
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
Ill, Adm,
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.
Actual
measurement of
sound were taken around the F
&
S facility by George
F,
Kamperman,
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
78
Leg
CR.
106-107).
Approximately
75 Class A
residences are
exposed to
forging noise
in excess of the
regulatory
standard,
Seventy-eight Leg is the
maxitaim or “worst
case”
situation,
F
&
S
has received
no citizen
complaints.
The Illinois Environmental
Protection
Agency did
receive three
complaints
in
1972 and 1973,
a period of high
activity
at the
forge.
In 1977,
F
& S installed a new roof with
interior
baffles
to
dampen
the sound and began operating with
the
sliding
doors
partially
closed.
These modifications resulted
in
approximately
an
eight
decibel
reduction
in noise
emitted
from
the facility CR.
69),
Since
these modifications, which cost
$30,000,
there have been no citizen complaints (P.110,
113).
F
&
S has investigated
methods of compliance with
the Board’s
noise
regulations.
To
achieve compliance,
it would
be necessary
to
rebuild
the entire forge
shop into an essentially closed
structure.
Mechanical
ventilation
would
replace
the present
natural draft
system and
entrances
would have to be redesigned
(P.
107).
Material
flow
would be
altered,
Productivity would
probably decrease
due
to
the enclosed work environment and the
inhibited material
flow
patterns that would result
(P.
64).
Because
of the extensive rebuilding that would be required and
the current lack
of space
at the
facility,
F
&
S would probably
relocate their
facility
elsewhere
(P.
70).
The Illinois Environmental Protection Agency (uAgencyH)
in
their written comments on the proposal
filed January 20,
1984,
did
not challenge F
& S~stualification 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 206Cc),
The
Agency
stated that while technologically feasible
noise
reduction
measures existed
for forge
shops, these measures
were not
technically
feasible or economically reasonable
for
F
&
S.
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
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 p,m~Monday through Friday and 6:00
a.m,
and 2:00 p.m.
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
consistent
with
the
operational
changes
initiated
in
1977,
This includes
the
requirement that
the
north
doors of
the
facility be opened
no
more
than
four feet,
unless
weather
conditions
makes this impractible
(P.
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
he
incorporated
into 35
Ill,
A.dm.
Code 901.116.
F
&
S 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 he
codified
as
35
Ill.
Adm. Code 901.116,
and
instructs
the Clerk
to
file
this
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
Section 901,116
~
~onalLevel
Forging~~4Stampings,
mc,
and
future
owners of
the
forging~jacility
located
at
1025
23rd
Avenue,
Rockford,
Illinois,
shall comp~ywiththe fol1ow~
site-specific
operational
level:
a)
~22erate no more than
six~q~jin9
hammers
at any one time;
and
b)
Operate its forgin
ers
only between
the hours of
6:00
a.m.
and
6:00 p.m. Monday
through Friday
and
6:~
am,m
and 2:00 p.m.
IT IS
SO
ORDERED.
I,
Dorothy
M.
Gunn,
Clerk of the Illinois Pollution Control
Board,
hereby
certify
that
th
above Opinion and Order was adopted
on
the
~?ôtZ
day of
~
1984 by a vote of
Dorothy M.
nn,
Clerk
Illinois Pollution Control Board