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

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