‘~iw1:~oISPULLUflON CONTROL BOARD

August

2,

1984

IN THE MAtmTIR 0~

NIJAS

C CThY~ ~oVISJON Or

5CC1~

:to~

‘~

)

9.83—34

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)

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OROPOSEC

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‘ROPOSED

O~INTON AND

ORDLR

01

THE

BOARD

(by

L

Eoruade)~

This

matteL

comes

before

the

Board

on

a

pentios

fii

d

or.

November 23,

9P3,

by Atlas Forgings Division of 8~o3Fcrge

(~‘Atlas~)for a site—specific operational

level for its forgIng

shop as an alternative to compliance with the noise Irmits

contained in

35 Ill~Adm~Code 90L105

(old Rule 206 of Chapter

8).

A public hearing was held on March 29, 1984,

in Hampshirt,

Illinois,

TL’s hearing was scheduled with those of three oScar

Illinois tirging shops

in order to conserve the time and

resources of the parties involved.

No public testimony or

comments were received.

The Dwpa~t’r~nt

of Cnergy and Natural Resources V’DENR’,

issued

a

atthep

ant

of

cegative

declaration

of

economic

Inpact

oc

!~ril

19,

Sl4~

onIrL:ng

the

need

for

an

economic

~pact

statement.

Or

July

18,

1984,

the

Economic

and

Technical

Advisot’y

ronimattee

concurred

with

the

DENR~sfinding,

The

reguloth:y

achr~me for

existing

forg~ng operthi~.

is

require

that

the

Petitiorer

either

(i)

comply

with

the

noise

crocibiti ns

co~~

ained

In

Table

F

of

Rule

206(c)

no

later

than

r

Steen mont’s thlloeing the effective date of the Rule, or

(ii)

~ p ~aansz’t 5th~—t’eoific operational

level as provided in

i”la 206(d),

P~eserulee have been recodified as 35 t.l~Ad~j

u’n& 90l,a034c; and

(d).

The noise prohibitions in 591.905(c;

~nry

Sot

different

classes

of

receivers

and

for

daytime

and

righttime

persodcr.

C

petition

under

5901,905(d)

must

demonstr&

~

~hrt

It

ic

troSn~cally

and

economically

infeasible

for

its

shop

to meet the numer~callimits of 590L905(c),

A petition must

~lco

propose

measures

to

reduce

impulsive

noise

where

possible

end

assess

tho

conesgurtial

health

and

welfare

impacts

on

the

surroundIng

co.mrenity0

Atlas

is

iocstea

at

1501

south

55th

Court,

Cicero,

Illinois,

The

Atlas

operatirn

oacupies

1.37

acres

and

is

surrounded

on

the

Tt’

Board

acknowledges

the

contribution

of

DavId

0,

Mueller

rho

was

the

adrinistrative

assistant

for

this

rulemaking~

rfl

‘jjO

a

---

2

north,

south

a

~S

~:st

by

heavy

Industry.

To

the

wesT~ beyond

the

Petit4oner~c

caning

at~fl5,

are

residences

(9..

57—58),

The

facility

was

init

in

1914

when

the

surrounding

land

was

industria

or

~e’ant

(9.,

56),

There

are

100

Class

A

residences

that

recci

t

~.

~ir~

noise

in

excess

of

the

regulatory

limits

(Pet,

p

8)~

fne

car:lity

consists

of

several

buildings,

one

of

whIch

hcurci

ttrec

.iarging

hammers

and

four

furnaces

(9.,

58—60).

Theta

is

one

tclOt

round

hammer,

one

6,000

pound

hammer

and

one

4,000

pond

thmr~r (9,

59),

This

building

has

rolling

doors

and

windows

th~t

n

“ua’ly

open

durinq

operation

and

a

steel

rof

wins

r.umtr’r~

Ic

r~tors

¶R,

64).

Atlas

currertly

employes

40

;eorie

~i~t

r.

fn~’forgirg

p

ice

consrsts

of

resting

c

rbon

r

-

v

steel

in

turn rc.en

cc

approximately

2350

oegrees

Fahrenrseit

and

then

for&ng

the

heated

places

between

two

dies,

Atas

utilizes

open

dies

chat

nave

no

~attern

(9.,

60).

The

upper

dt’

i~

attachers

o

a

g ‘itt’

rev

and

the

lower

die

is

ittac

red

to

the

forge,

The

metal

is

rhapad

through

pressura

exerted

ty

the

ram

or

forge

hammer,

The

sound

produced

through

this

procoss

is

impulsive

and

originates

primarily

from

the

impact

battens

the

upper

and

lower

die

and

the

workpiece.

Ihera

is

a

constant

flow

of

materials

between

the

furnace,

forge,

and

cooling

area

(9.,

48),

Atlas

produces

forgings

for

the

gear,

machine

tool

and

energy

industries

(Pet,

p.

4).

The

nature

of

the

forge

operation

creates

an

extremely

hot

work

envi

onmant,

The

furnaces

require

a

tremendous

amount

of

oxygen

and

emit

a

great

deal

of

heat,

The

cooling

workplaces

also

radiate

heat

:nto

the

forge

shop.

Consequently,

the

shop

requires

~xter

vntilation

which

is

provt&d

by

the

c’nurcs

level

doors

and

wi.

dows

and

roof

ventilators

(9.,

64),

This

system

creates

a

thtack

effect~

whereby

air

flows

through

the

open

sides

of

the

beilding

and

is

drawn

up

and

out

through

the

roof

(~,

~4

Pt’s

nat

~ral

ventilation

syster

Is

efifec’ in

a

widsly

ntil~.nd

by

the

forging

industry.

The

open

sicc~nof

~

building

ils~’ facilnate

the

free

movement

of

material

in

and

out

of

the

forge

ohop

Noise

escapes

through

thesa

roof

and

side

ipenings.

AtTn

currently

operates

its

forging

hammers

from

i;Q5

a.m,

to

4:30

p.m.

four

‘o

six

days

per

week

(9..

66).

Often

they

only

operata

two

of

their

three

hammers.

In

a

post’hearing

submittal,

Atlas

req’rest~~an

orerational

level

that

would

allow

thtm

to

ooerate

between

6:00

i,m,

and

6:00

p.m.

Monday

through

Saturcay.

ibis

level

would

allow

some

flexibility

in

their

operation

~n

case

the

need

arose

to

work

past

4:30

p.m.

(9..

67).

Production

has

fluctuatth

o”er

the

last

few

years.

Production

levels

have

declineS

rinse

1981

as

shown

by

the

table

below.

The

decline

in

production

is

expected

to

continue

in

1983.

The

figures

below

reflect

approximations

because

of

the

nature

of

the

open

die

forging

process

(9.,

77),

sour

a.

---

3

t’tai

No,

of

fcrgings

No,

ot

Ton~age

of

all

in

hammers

~~grt

198~

27,791

973,000

3,710

1961

35,384

1,238,000

4,665

1992

24,904

892,000

3,052

it, requl,~tions rf the Board def’ne two methods of measuring

sound,

The

0t’inicaon

of

dB(A),

or

A

—

weighted

sound

in

decibels,

is

found

in

35

Ill,

Adm,

Code

900.101,

as

is

the

definition

it

cal

~c cquivalent

cot tinuous

sc

-

,

orecs~re

level

in

decibels,

threx.t~-)ly,

dB(A)

measures

th-

~crn

i-ru’

at

the

peaks

anile

Le.s

I~c

ruins

the

avenge

noise

I

ci

over

cI

including

o~

ar c

tactground

noise

Permiss4hle

impulsive

sound

levels

for

exL4ing

ft

ige

crops

are

found

in

if

Ill,

1dm,

Code

901,105.

The

impulsive

cc’srd

level

omitt~0

t.u

naidences

(Class

A

land)

cann

t

exceed

58~

Leg,

during

the

day

or

53,5

Leg

at

night.

ActeJ

men

5mns’nt

of

sound

were

taken

around

the

Atlas

facility

by

Leorge

F,

Kamperman,

an

expert

in

the

area

of

noise~contro

engir.nsrrrg.

Based

on

these

measurements,

Kamperman

predicted

that

to’.:

highest

level

at

the

nearest

receiver

would

be

approxtnately

70

Leg

(9.,

116).

Approximately

100

Class

A

residences

are

exposed

to

forging

noise

in

excecs

of

the

regulatory

standard,

Savrnty

Leg

is

the

maximum

or

~worst

case”

situation,

Atlas

has

received

no

citizen

complaints,

In

the

early

1970Us,

Atlas

received

complaints

from

rook

County

regarding

noise

from

their

steam

exhaust,

AtlAS

rubscguently

put

a

silencer

on

their

steam

vent

(9., 70).

The 1~i:aoisEnvironmental Protection Agency ~Agency”)

received

a

ci’~isen ronplaint

in

1976

about

the

forging

noise

from

Atlas.

Atlas

;~‘.

rot

implemented

any

noise

reducing

macsum

at

the

Cicero

faoulrny,

They

have,

however,

built

a

new

plant

in

Wisconsin

that

utilizes

noiseless

presses

(9.,

69),

Atlas

has

inrestigated

various

methods

of

comp1tar.~:e with

t~ie Boar&s

noasc..

regulations.

To

achieve

compliance,

It

wcud

bo

necessary

to

close

up

the

forge

shop,

by

replacing

all

windows

with

double

glazinj,

replacing

all

non—masonry

surfaces

ann

wa’i

surfaces

surrounding

windows

and

doors

with

more

massive

materials

and

eliminating

the

large

west

access-door

opening

entirely.

A

necnanlcal

ventilation

system

would

have

to

be

installed

which

would

include

fans

and

silencers,

The

roof

ri

aid

have

to

be

structurally

reinforced

to

support

this

additione~’

burden

(9.,

71—72)

these

modifications

would

cost

approximcteiy

$320,000

in

1979

dollars,

This

figure

does

not

reflect

the

installation

costs,

operating

costs

or

the

cost

of

reinforc.ng

the

roof

(9.,

117),

Material

flow

would

be

altered,

Product...vrty

would

probably

decrease

due

to

the

enclosed

work

environment

and

the

inhibited

material

flow

patterns

that

would

result

(9.,

73),

Petitioner~s

president

testified

that

if

site—specific

relief

was

not

grantod,

they

would

relocate

their

three

hammers

to

their

Wisconsin

fac~1ity

(R~ 74),

---

Tho

Agency,

In

their

written

comments

en

the

propose

filed

January

26,

l.~Pt

did

not

challenge

the

Petitioner~s

qualificatic:

for oit~~specif1crelief on the basis that

it is an

~exi~tlng us~ent Lorqing operation,” nor did they question the

fact

thus; tIe Petltllner was violating Rule

206(C).

The Agency

stated that while technrt’gically feasible noise reduction

measures ewisted toe forge shops,

these measures were not

tecloically feasih~cor economically reasonable for Atlas,

The

Agency

also

stated

that

granting

the

proposed

site~specif

mc

operational

level

wr’uld

not

cadet ger

the

hearing

of

area

residents~

The

Board

proncues

granting

th~’ site—specific

operatiout)

level

requested

by

Atlas,

Atlas

is

an

existing

impact

forging

operation

which

is

presently

in

violation

of

5901,105(c),

While

compliance

is

tecnnically

possible,

its

extremely

high

cost

makes

it

economically

unreasonable

for

Atlas

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.

There

is

no

danger

of

hearing

loss

un

area residents,

The site~specificoperational

level wiLl be

limited to three hammers that may operate between 6:00 a,m, and

6:00 p.m. Monday through Saturday.

No specific numerical noise level

limitations are being

imposed, although it

is assumed that noise levels will

approximate those testified to by Atlas and its witness.

Atlas

should make efforts to lessen noise levels in the future as

equipment is replaced and new technology for noise suppression

becomes availabxr,

In the even 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 oparationar plan set out in chic Order will ha

incorporated Into 35 Iii, Ada,

Code 901.118~ Atlas will he

required to comply with the plan upon filing with

the

Secretary

of Stats of Illinois

---

ORDER

35 I1I~

Adm~

Code 90L118 will read

as

follows:

Section 90L118

Atlas For ins

Division

of

Scot

For

Se~~icQ~rationa

1

Level

Atlas For

Divisio

0

f~ç

For

a

nd

utu

re

o~ner

Cicero,il1~oisshallcornlwithth~ollowinsit!~

~oerationalleve1orareotherwisesubect

to

Section

90L105(c):

a)

~~1oerat~~o

more than th~e fo~~

~~

r~

for

in

hammers

~etime;and

b)

~

~jO~~m.and6:~Qp

.m.Mond~

~hSaturda

35 IlL

Adm.

Code 901.118 is directed to First

Notice.

IT

IS SO ORDERED.

I,

Dorothy

M~

Gunn,

Clerk of the

Illinois

Pollution

Control

Board, hereby certify that the

aboy~ Proposed

Opinion

and

Order

was adopted on the

~

day of

~

1984 by a vote of

~

Illinois Pollution Control