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BEFORE THE ILLINOIS POLLUTION CONTROL

BOARD

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NOISE RULE UPDATE:

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R03-8

AMENDMENTS TO 35

 ILL. ADM. CODE

)

 (Rulemaking

 Noise)

900 AND 903

)

NOTICE

PLEASE TAKE NOTICE that

 I have today filed with the Office

of the Clerk of the Pollution Control Board the Comments on the

Illinois Pollution Control Board’s Notice of Proposed Amendments

by George Kamperman,

 a copy of which is hereby served upon you.

Respectfully submitted,

JOEL J. STERNSTEIN

Assistant Attorney General

Environmental Bureau

188

 W. Randolph Street, 20th Floor

Chicago,

IL

60601

(312)

 814-6986

SERVICE LIST

Dorothy Gunn

Clerk

Pollution Control Board

100 W. Randolph,

 Suite 11-500

Chicago.,

 IL 60601

Kyle Rominger

Division of Legal Counsel

Illinois

EPA

1021

N.

 Grand Avenue E.

Springfield,

 IL 62794-9276

Thomas Thunder

Acoustic Associates,

 Inc.

305 E. Northwest Highway

Palatine,

 IL 60067

Paul Schomer

Schomer & Associates,

 Inc.

2117 Robert Drive

Champaign,

61821

Robert T.

 Lawley

Dept.

 of Natural Resources

One Natural Resources Way

Springfield,

 IL 62702

Matthew J.

 Dunn

Division

Chief

EE/ALD

Office of the Attorney General

188 W. Randolph,

20th

 Floor

Chicago,

 IL 60601

Greg Zak

Noise Solutions by Greg Zak

36 Birch Drive

Chatham,

 IL 62629

cry:

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?003

Illinois Pollution Control Board

J. R. Thompson Center

SiI~TE

L~

ILLINO!S

100

WestRandolph

Pollution

Control Board

Chicago, IL 60601

Subject: Noise Rule Update: Amendments to

35111. Adm.

Code 900 and 903; R2003-00~

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Gentlemen:

The Illinois Noise Rule was constructed by the flhinois Noise Task Force consisting of

about a dozen faculty members at the University ofIllinois.

During the formulation of

the Illinois noise standard I was retained as their consultant on noise measurement and

noise control.

I participated in numerous meetings

in 1972 at Champaign and then fifteen

all day hearings on the proposed Noise Rule conducted by the Pollution Control Board at

different locations throughout Illinois.

The Illinois Noise Rule has become the noise

standard reference in the USA.

The present “Noise Rule Update” presents an opportunity to make the noise measurement

procedures more meaningful and

efficient for determining compliance with 35 Ill.

Adm.

Code 901.

The one-hour LEQ measurement requirement (Section 900.103

Measurement

Procedures) was never envisioned by the drafters ofthe original Illinois noise standard.

did testify,

at the public hearings thirty years ago, that the sound level averaging time of a

standard sound level meter is undesirably short (one-eight second on fast meter response

and one second on slow meter response) thus, making it difficult to determine the average

noise level.

And although longer time-weighted-average (LEQ) sound measurements

were possible with laboratory instruments, there were no portable LBQ meters available

thirty years ago.

Today there are numerous manufacturers ofvery portable LEQ meters

containing octave and one-third octave band frequency analyzers.

These portable

integrating averaging sound level meters (LEQ) can average the sound level over a period

oftime from a fraction ofa second to

more than a month.

There is no unique duration of

sound measurement recommendedfor all sound

sources.

A LEQ measurement duration

ofone minute is usuallymore than adequate for documenting the average sound emission

from a steady source such as a transformer or constant speed roofexhaust fan.

complex sound sources mayrequire a longerLEQ measurement period to obtain the

average sound level.

It is my professional opinion the existing one-hour LEQ measurement requirement does

not protect residents as intended by the drafters ofthe Illinois noise standard.

The one-

hour LEQ measurement requirement is also excessively burdensome on determining

compliance due to problems with intrusive noises

and the limited number ofdifferent

sound measurement locations that can be performed in a finite period, oftime.

Although a

measurement duration related to

the sound source variability is best for obtaining

the

average sound level, it maynot be the best for a noise limit standard.

Forthe Illinois

Noise Rule Irecommend the PCB select a single LEQ measurement period ofnot less

than one minute and not more than tenminutes.

The measured results will be the same

with either time period for a constant sound source.

A one-minute versus a ten-minute

LEQ measurement maybenefit the receiver at the expense ofthe emitterif the sound

source

is not constant.

Thus, the sound emitter will always argue for the longest possible

time duration for a LBQ measurement.

The following American National

Standards Institute standards are recommended for the

measurement procedures in 35

111. Adm.

Code 901.

ANSI S 12.9 Part

1&3 address the

sound measurement procedures.

ANSI Si .4 for standard sound level meters is already

part of Code 901.

ANSI S 1.43 should also be referencedto cover the special additional

requirements for L1EQ meters.

Si .40 is included to

ensure the sound measuring system is

calibrated in the field with an appropriate acoustic calibrator.

ANSI Si2.9-1988/Part

(R1998) “AmericanNational Standard Quantities and

Procedures forDescription and Measurement of Environmental Sound. Part

1”

This standard provides basic quantities for description ofsound in community

environments and general procedures for measurement ofthese quantities. Based on these

quantities and procedures, compliance limits of sound may be specified by cognizant

authorities and conformance with the limits

controlled forpurposes ofenvironmental

assessment, regulation, and land use planning.

ANSI S12.9-1993/Part

(R1998) “American National Standard Quantities

and

Procedures for Description and Measurement ofEnvironmental Sound. Part 3: Short-term

measurements with an observer present”

This standard is the third in a series ofparts concerning description and measurement of

outdoor environmental sound. The standard describes recommendedprocedures for

measurementofshort-term, time-average environmental sound outdoors

at one

or more

locations

in a community for environmental assessment or planning for compatible land

uses and for other purposes such as demonstrating compliance with a regulation. These

measurements are distinguished by the requirement to have

an observer present. Sound

maybe produced by one

or more separate, distributed sources ofsound such as a

highway, factory, or airport. Methods are given to

correct the measured levels for the

influence ofbackground sound.

ANSI S1.4-1983 (R2001) “AmericanNational Standard Specification for Sound Level

Meters”

This standard is a revision ofthe American National

Standard Specification for Sound

Level Meters,

S1.4-1971. It conforms as closely as possible to the IEC

Standard for

SoUnd Level Meters, Publication 651, First Edition issued in 1979. This revision

represents a significant improvement over ANSI S1.4-1971, particularly in its

specifications relating to measurement oftransient sound

signals. It also permits the use

ofdigital techniques

and displays. The principal changes from ANSI Si .4-1971 are:

inclusion ofan optional impulse exponential-time

averaging characteristic, inclusiOn of

an optional peak characteristics, more rigorous definition ofthe dynamic characteristics

for the Fast and Slow exponential-time-averaging, increase in the crest factor requirement

to ten for type

instruments,

specification ofa type

0 laboratory instrument with

generally smaller tolerance limits than those previously specified for type 1, and deletion

ofthe type 3

survey instrument

ANSI S 1.43-1997 (R2002) “American National Standard Specifications for Integrating

Averaging Sound Level Meters”

This Standard describes instruments forthe measurement offrequency-weighted and

time-average sound pressure levels. Optionally, sound exposure levels maybe measured.

This standard is

consistent with the relevant requirements ofANSI S1.4-1983(R 1997)

American National Standard Specification for Sound Level Meters, but specifies

additional characteristics that are necessaryto measure the time-average sound pressure

level ofsteady, intermittent, fluctuating, and impulsive sounds.

ANSI,S1.40-1984 (R200i) “American National Standard Specification for Acoustical

Calibrators”

This

standard specified performance requirements for coupler-type

acoustical calibrators.

For each microphone type that may be used with the calibrator, requirements include the

sound pressure level in the coupler, the frequency ofthe sound, and the determination of

the influence of atmosphericpressure, temperature, humidity,

and magnetic fields on the

pressure level and frequency ofthe sound produced by the calibrator. Specifications’are to

be met within stated tolerances at each frequency and soundpressure level ofoperation.

Sincerely,

George W.

Kamperman, P.E., Bd. Cert. INCE

KAMPERMAN ASSOCIATES INC.

312 Washington Avenue

Wisconsin Dells, WI

53965

Phone;

608-254-5656

Email: george(2i~kamperman.com

Cc: Howard Chinn

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CERTIFICATE

 OF SERVICE

2003

I, JOEL J.

 STERNSTEIN,

 an Assistant Attorney Ge~M~9F~LLH\iOIS

Polk~t~~~

C~ntr~J

Board

certify that

 on’ the 28th day of February,

 2002,

 I caused to be

served by First Class Mail the foregoing to the parties named on

the attached service

 list,

 with the exception of Matthew J. Dunn,

by depositing same in postage prepaid envelopes with the United

States Postal Service located at 100 West Randolph Street,

Chicago,

 Illinois 60601.

 Matthew J. Dunn was served personally.

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JOEL J. STERNSTEIN