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HomeMy WebLinkAboutCC - Odor Plan Appendix E Odor Control Plan Timber Creek Recycling, LLC ow 1% TIMBER CREEK R E C Y C L I N G Odor Control Plan Draft Timber Creek Recycling, LLC TABLE OF CONTENTS 1.0 INTRODUCTION ....................................................................................................................1 2.0 ODOR PREVENTION.............................................................................................................1 2.1 Feedstock Acceptance ........................................................................................................2 2.2 Feedstock Handling, Mixing, and Windrowing.....................................................................2 2.3 Monitoring of Composting Material......................................................................................2 3.0 IDENTIFYING THE PRESENCE OF ODOR ..........................................................................3 3.1 Odors Identified Through Self-Inspection ............................................................................4 3.2 Odors identified by the Community......................................................................................4 3.3 Agency Response................................................................................................................4 3.4 Identifying the Source of the Odor.......................................................................................5 4.0 ODOR MITIGATION...............................................................................................................6 5.0 DOCUMENTATION................................................................................................................7 LIST OF ATTACHMENTS Attachment A Forms November 2019 i Odor Control Plan Draft Timber Creek Recycling, LLC 1.0 INTRODUCTION The Timber Creek Recycling (TCR) Odor Control Plan (OCP) is designed to control and reduce odors from composting operation to the extent necessary to prevent nuisance conditions from occurring. Composting is the natural decomposition of organic matter by biological and chemical processes. TCR will be using aerobic composting that occurs in the presence of oxygen. Operations and site activities that can contribute to odor at the facility include: • Incoming raw material that will be composted; • Composition of the feedstock used to create the compost rows; • How well the feedstock is mixed; • Decomposition of unprocessed material; • Formation of anaerobic pile of materials where decompositions starts to occur in the absence of oxygen; and • Processing anaerobic piles. TCR plans to manage odors at the site by implementing best management practices (BMP) to reduce situation where nuisance odors develop. The OCP will address how to handle raw material and compost to reduce odors, how to identify the source of odors, documentation requirements for addressing odor issues, and how to mitigate odors. Section 2.0 discusses odor prevention, Section 3.0 will discuss odor identification, Section 4.0 will discuss odor mitigation, and Section 4.0 will discuss documentation. 2.0 ODOR PREVENTION Operation of TCR composting operation will include best management practices to reduce odor generation activities that could affect adjoining properties. Transmission of odor depends on the weather, as well as the time of day of operation. The on-site weather station, as well as weather forecast for the area will be used to evaluate the best time to conduct odor generating activities, such as turning windrows and moving fresh pile. In general, these activities will be conducted when the wind speed is below 15 miles per hour (mph), when the air is saturated with water (i.e. the difference between the ambient and dew point temperature is less than a 10-degrees), and when the surface temperatures are warmer than atmospheric conditions to promote vertical mixing (i.e. mid-morning to mid- afternoon). In addition, these activities will be avoided in the late afternoon, and before weekends and holidays when neighbors are more likely to be outside. Odors can also be reduced through management of feedstocks and monitoring of compost operations. The objective of the feedstock process and product monitoring is to operate the facility in a manner that result in a compost product of value with minimal impact to adjoining properties. The compost process takes place in several steps and each step will have specific procedures defined in the operations manual that will meet quality objectives and generate a beneficial final product. These common processes include: ■ Mixing feedstocks properly; ■ Balance the carbon to nitrogen ratio; ■ Managing particle size through grinding sizes; ■ Correct moisture content; November 2019 1 Odor Control Plan Draft Timber Creek Recycling, LLC ■ Promote biological activity; ■ Maintain porosity of material to insure sufficient oxygen; and ■ Manage pH levels. 2.1 Feedstock Acceptance The feedstock acceptance policies detailed in the operations plan evaluates what feedstocks are acceptable for use to produce a quality product, and how feedstocks will be accepted or rejected. Once a feedstock has been determined to be acceptable and beneficial for site operations, it will then be managed to reduce odors. Management techniques required will be dependent on the particular feedstock, and each incoming feedstock may have different management procedures. Management techniques that will be employed include: ■ The time of day when a feedstock can be accepted; ■ Limiting acceptance of feedstock during windy conditions; ■ Defining the time between acceptance and processing; ■ Aerating the pile if processing will be delayed; and ■ Covering the feedstock with a layer of woodchips, mulch and/or compost until it can be processed. 2.2 Feedstock Handling, Mixing, and Windrowing This composition of the compost is critical to both successful composting and odor management. In general, the incoming feedstocks will be processed by grinding the material to the desired particle size and then mixing different feedstocks to achieve the optimal composition of nutrients, texture and moisture to promote aerobic decomposition. The feedstocks used for composting will vary seasonally, so the process will focus on maintaining the optimal conditions for the various feedstock mixtures before being placed in windrows. These include: ■ Nutrient content or Carbon / Nitrogen ratio between 20:1 to 35:1; ■ Maintain a moisture content of 40% to 60% in windrows; ■ Maintain the porosity (i.e. air space) to ensure the piles have a minimum 10% oxygen content to promote aerobic degradation; ■ Maintaining the surface to mass ratio of the windrows (i.e. dimensions); ■ pH; and ■ Visual/Qualitative. The visual appearance of the material during the mixing and composting processes presents additional insight as to the stage of the product. Trained and experienced onsite personnel will utilize the visual tests as part of the normal procedures. The characteristics of the product include color, moisture, particle size, bulk density, odor and porosity. 2.3 Monitoring of Composting Material Process monitoring entails the regular collection and evaluation of data pertinent to the composting process. The following parameters will be monitored on a regular basis: ■ Decomposition; • Bulk density and porosity; November 2019 2 Odor Control Plan Draft Timber Creek Recycling, LLC ■ Moisture content; ■ Temperature; ■ Oxygen content; and ■ Qualitative parameters: odor, color and texture. Assessing the compost visually, by smell and feel can provide valuable insight to the process. Samples for evaluation should be taken from the pile interior (deeper than 36 inches) with a front-end loader. The following properties of the sample should be evaluated: ■ Moisture content - composting material should feel moist but not excessively wet. When squeezed in a fist, free water should not drip from the material. ■ Aeration - a sour or pungent odor is an indication that the pile is anaerobic and that the pile should be turned. The dynamic of a compost pile changes as the compost matures and based on the stage of the composting the frequency and duration of aeration should be evaluated. ■ Porosity - the compost should have a granular, chunky appearance. A fine texture is an indication that the material may not be sufficiently bulked. If there is a doubt a more quantitative evaluation can be done with a five-gallon bucket to evaluate the bulk density and porosity. ■ Temperature - Pile temperatures should be consistently measured on Monday, Wednesday, and Friday every 100 feet in each windrow at three different depths. Optimal temperatures are between 120 OF to 160 OF. These temperatures will be recorded and saved as part of the operation records onsite. A discussion on the testing for compost maturity and nutrient parameters are discussed in the Sampling and Analysis Plan, which is Appendix D of the Operations Plan. 3.0 IDENTIFYING THE PRESENCE OF ODOR Transmission of odor depends on atmospheric conditions. The facility will operate a weather station that records date, time, temperature, wind direction and speed, precipitation, relative humidity, and barometric pressure. This information, along with weather forecast will be used to guide operations and reduce conducting odor generating activities when weather conditions are not favorable. Common odor complaints from composting facilities are: ■ Ammonia - can be from too much nitrogen; ■ Fishy smell — can indicate anaerobic conditions; and ■ Rotten egg smell - can indicate anaerobic conditions. Knowing the type of odor present can help identify and address the problem. The presence of odors can be identified in one of the two following ways: ■ Odors identified by TCR personnel, through self-inspection or on-the-job observations. ■ Odors identified by individuals other than TCR personnel. These odors are often identified through our "odor notification group." There are three methods by which odors are identified: 1. Identification by self-inspection; 2. Reports to TCR by the community at large; November 2019 3 Odor Control Plan Draft Timber Creek Recycling, LLC 3. Reports to DEQ or the Central District Health Department (CDH). How TCR responds and address odors is defined by the method that the complaint originated, which is discussed in the sections below. The method for odor identification is discussed in more detail in Section 3.4. 3.1 Odors Identified Through Self-Inspection The purpose of the TCR OCP is to identify and mitigate odors from the facility before the odors can have an impact on the local community, (i.e. to eliminate odor complaints). This is accomplished through the use of self-inspections. Self-inspection will be performed on a weekly basis and before any holiday breaks by the Operations Manager, site inspector and/or their designees. The inspection is conducted by one of the individuals touring the facility specifically to identify odors. An odor inspection form is provided in provided in Attachment A. Copies of the form will be maintained in a 3-ring binder in the office located on site for 2-years. Any odors identified through self-inspection that are present at the property boundary (i.e., if the individual performing the self-inspection is standing on the property boundary and an odor from the facility can be detected) will be mitigated as quickly as possible based on methods discussed in Section 3.0. Other odors identified on the property will be addressed as appropriate to prevent odor transmission 3.2 Odors identified by the Community Although all efforts will be made to reduce and mitigate odors using BMPs for operation of the composting facility, there is the potential for operation to result in an odor complaint from adjoining property owners and other members of the community. All odors brought to the attention of TCR through a phone call, letter, or email will be documented on the odor complaint form included in Attachment A and investigated by the operations manager or designated individual. The odor complaint form requires that the following information be collected: ■ the location/address of the complaint; ■ date and time; ■ contact information for the person who filed the complaint; ■ source of odor, if it can be identified, and ■ steps taken to mitigate the odor. In addition, all complaints from the public, will be reported by TCR to the Idaho Central District Health Department, DEQ, managing members of Timber Creek LLC, operations supervisor, operations manager, office manager, and the site inspector to maintain transparency. 3.3 Agency Response The process that DEQ uses to address an odor complaint concerning TCR will be at the discretion of DEQ who may respond with the following actions: ■ The complaint will be referred to the Boise Regional Office who may elect to refer the matter to the Central District Health Department and may also choose to notify the Ada County Commissioners. ■ DEQ personnel will contact TCR. ■ DEQ will encourage a meeting with TCR, the complainant (if they have identified themselves) and DEQ personnel. November 2019 4 Odor Control Plan Draft Timber Creek Recycling, LLC ■ If the complainant does not desire to meet or if they are not satisfied with the outcome of the meeting, then the Boise Regional Office of DEQ will conduct an investigation. This can include a file search for previous complaints concerning TCR, determining the validity of the complaint using DEQ's internal Odor Determination Process, and a review of this odor control plan. o If the Boise Regional Office of DEQ determines that TCR is in compliance with this plan, DEQ may request that TCR voluntarily update this odor management to specifically address the source of the complaint. o If the Boise Regional Office of DEQ determines that TCR is not in compliance with this plan, they may forward an enforcement concurrence package to the DEQ state office. If DEQ receives an additional complaint related to the same odor source, they may respond with additional actions that could include: ■ They will conduct a file search for previous complaints. ■ They will determine the validity of the additional complaint using their internal Odor Determination Process. ■ They will investigate to determine if TCR is in compliance with this plan. This can include an information order to TCR for the purpose of determine if the facility is in violation of any Rules of Control of Air Pollution in Idaho o If TCR is in compliance with this plan, the DEQ will require that this plan be amended to specifically address the identified odor. o If TCR is not in compliance, the Boise Regional Office of DEQ they may forward an enforcement concurrence package to the DEQ state office. Enforcement actions by the DEQ state office may meetings with TCR, issuing a Notice to Comply or Notice of Violation, entering into a consent order, or filing a civil suit. TCR will work with DEQ, CDH, and the public to address all odor complaints. An odor determination process has been developed by DEQ, and this process will be used as appropriate while the complaints are being investigated and addressed. This process includes the following: ■ The odor determination will be made jointly by two members of the DEQ compliance staff who are trained in odor detection. ■ These two DEQ compliance staff members will determine if the detected odor is specific to the alleged odor source by conducting odor detection at a location upwind, or at any other relevant location, of the alleged odor source. ■ The two DEQ compliance staff members will use their odor detection training to determine if, at the downwind source property boundary or beyond, odor levels meet or exceed the level at which regulations applicable to the odor source provide DEQ with authority to regulate odors. ■ The two DEQ compliance staff members will prepare an odor determination report that will include their determinations, the means through which the determinations are made, and all other relevant information. 3.4 Identifying the Source of the Odor Once the presence of odor is identified through either self-inspection or through an odor complaint, the source of the odor needs to be determined. Typically, the source of the odor is readily identifiable. However, if the source of the odor is not obvious and cannot be traced November 2019 5 Odor Control Plan Draft Timber Creek Recycling, LLC immediately to a feature or activity at the facility, the following steps provide a methodology for identifying the source of the odor: • Using data from the weather station, determine the wind direction at the time the odor was identified. ■ Using an aerial photograph, Google Earth, or a plan of the facility, draw a vector in the same direction as the wind, and intersecting the location where the odor was identified. ■ If the vector crosses the facility and the facility is in an upwind position compared to the location where the odor was identified, then determine the facility features and activities that lie along the vector. ■ Compare this process at varying times of the day, under varying operational conditions, and with varying wind directions until the source of the odor is identified. All information collected during the source identification will be documented on the odor complaint form. 4.0 ODOR MITIGATION Identifying the source of odor will assist in determining the best means of mitigating the odor. One or more of the following methods will be selected to mitigate the odor: ■ Cover the area or pile that is generating odors with 4-6" layer of compost; ■ Add additional bulking material; ■ Increase the carbon content; ■ Add wood grindings to the pile causing odors; ■ Turn piles to increase aerobic conditions and ensure the oxygen content is at least 10% oxygen or greater; or ■ Use odor masking or neutralizing agents at the facility It should be noted that the last option - use of masking or neutralizing agents- should be considered as a last resort. Experience has shown that the use of odor masking or neutralizing agents has proven to be extremely difficult in a composting facility environment. Once the immediate problem has been addressed, TCR will review the cause(s) of the odor problem operationally and review the feedstock used for the area that caused the problem. If the odor originates from a specific feedstock material, one or more of the following methods will be selected to mitigate the odor: ■ Stop taking the objectionable material; ■ Require that the material generator treat the objectionable material to eliminate odors prior to delivery to the facility; ■ Immediately cover objectionable materials upon delivery to the facility; or ■ Restrict the times when an objectionable material can be delivered to the facility. If odors are detected through self-inspection and no complaints have been made by the local community, mitigation of the odor will be addressed to prevent transmission to the local community. TCR plans to operate a well maintained and efficient composting operations and to be a good neighbor. Self-inspection and mitigation are mandatory for all TCR facilities to prevent transmission of odors to the local community. If a mitigation method is found to be unsuccessful in controlling odor, alternate methods will be used until the problem is corrected. November 2019 6 Odor Control Plan Draft Timber Creek Recycling, LLC 5.0 DOCUMENTATION A copy of this odor control plan will be maintained in the facility offices. The plan will be reviewed on an annual basis to incorporate lessons learned and improve odor mitigation at the facility. All revisions and modifications will be recorded, including the date and the nature of revision/modification. Data from the weather station will be used to assist in implementing BMPs for site operations to minimize transmission of odors, identify the source of the odors, and establish seasonal weather patterns. Information from the weather station will be retained for the life of the facility. TCR will maintain a file with a copy of all site inspections, odor complaint forms, and documentation of odor mitigation efforts. These documents will be stored on site in the office. Site inspection and odor complaint form will be maintained for 2 years. November 2019 7 ATTACHMENT A FORMS Timber Creek Recycling, LLC Fugitive Dust and Odor Complaint Form Complaint Form Date: Time: Type of Complaint ❑ Dust Complaint ❑ Odor Complaint Name of Complainant: Time Complaint Received: Location of Complaint(address and/or area where dust or odor is a problem): Contact information for complainant(phone, email,address): Description of Complaint: Name of Person Receiving Complaint: Name of Person Assigned to Address Complaint: Weather Conditions from onsite weather station at time of complaint: Wind Speed: Temperature: Wind Direction: Humidity: Precipitation last 24 hours: ❑ Yes, amount: ❑ No Managing members of TCR notified? ❑ Yes ❑ No By whom: Notified via? ❑ Email ❑ Phone ❑ Mail Kevin Ryan, Idaho DEQ notified? ❑ Yes ❑ No By whom: Notified via? ❑ Email ❑ Phone ❑ Mail Lori Badigian, Central District Health notified? ❑ Yes ❑ No By whom: Notified via? ❑ Email ❑ Phone ❑ Mail Timber Creek Recycling, LLC Fugitive Dust and Odor Complaint Form For Dust Complaints: 1.What activities were being conducted at the time of the complaint? a) Grinding ❑ Yes ❑ No b) Trommel ❑ Yes ❑ No c) Turning Windrows ❑ Yes ❑ No d) Movement of heavy equipment and/or large trucks ❑ Yes ❑ No 2. Is the problem still visible? ❑ Yes ❑ No If yes, describe location and activity: If no, describe the procedure used to identify the source of the dust: 3. Describe the corrective action taken and whether it addressed the problem. List all actions taken, even if they did not resolve the problem. 4. Has the issue been resolved?❑ Yes ❑ No If not,what is the next step? 5. Has this problem occurred previously? ❑ Yes ❑ No If yes, describe location and activity that created problem previously. What actions are required to prevent the problem from reoccurring? Timber Creek Recycling, LLC Fugitive Dust and Odor Complaint Form For Odor Complaints: 1.What activities were being conducted at the time of the complaint? a) Grinding ❑ Yes ❑ No b) Trommel ❑ Yes ❑ No c) Turning Windrows ❑ Yes ❑ No d) Movement of heavy equipment and/or large trucks ❑ Yes ❑ No 2. Can the odor still be detected? ❑ Yes ❑ No 3. Is there currently an odor: a) South Perimeter? ❑ Yes ❑ No b) East Perimeter? ❑ Yes ❑ No c) Green Wood Grinding and Storage Area? ❑ Yes ❑ No d) Commercial Wood Waste Grinding and Storage Area? ❑ Yes ❑ No e) Feedstock Acceptance Pad? ❑ Yes ❑ No If yes, can the feedstock generating the odor be identified?What was the original source? f) Compost Grinding Area? ❑ Yes ❑ No If yes, can the feedstock generating the odor be identified?What was the original source? g) Compost Windrows? ❑ Yes ❑ No If yes, describe the location and type of odor: 4. Describe the corrective action taken and whether it addressed the problem. List all actions taken, even if they did not resolve the problem. 5. Has the issue been resolved? ❑ Yes ❑ No If not,what is the next step? 6. Has this problem occurred previously? ❑ Yes ❑ No If yes, describe location and activity that created problem previously. What actions are required to prevent the problem from reoccurring? Timber Creek Recycling, LLC Odor Inspection Form Inspection Form Date: Time: Name of Person Conducting Inspection: Weather Conditions from onsite weather station at time of complaint: Wind Speed: Temperature: Wind Direction: Humidity: Precipitation last 24 hours: ❑ Yes, amount: ❑ No 1.What activities were being conducted at the time of the inspection? a) Grinding ❑ Yes ❑ No b) Trommel ❑ Yes ❑ No c) Turning Windrows ❑ Yes ❑ No d) Movement of heavy equipment and/or large trucks ❑ Yes ❑ No 3. Is there currently an odor: a) South Perimeter? ❑ Yes ❑ No b) East Perimeter? ❑ Yes ❑ No c) Green Wood Grinding and Storage Area? ❑ Yes ❑ No d) Commercial Wood Waste Grinding and Storage Area? ❑ Yes ❑ No e) Feedstock Acceptance Pad? ❑ Yes ❑ No If yes, can the feedstock generating the odor be identified?What was the original source? f) Compost Grinding Area? ❑ Yes ❑ No If yes, can the feedstock generating the odor be identified?What was the original source? g) Compost Windrows? ❑ Yes ❑ No If yes, describe the location and type of odor: 4. If any areas have an odor, describe the corrective action taken and whether it addressed the problem. List all actions taken, even if they did not resolve the problem.