Sunnyland Neighborhood Association Odor Presentation

1. Sunnyland Neighborhood Association Odor Presentation January 15, 2008

2. NWCAAPrograms & Services • Public information & education • Asbestos • Indoor Air • Air Monitoring • New Source Review • Air Operating Permit Program • Small Business Assistance • Global Climate Change • Outdoor Burning & Agricultural Burning • Woodstoves • Complaint Response & Enforcement

3. Overview of Topics:

4. NWCAA Odor Regulations Section 535 – Odor Control Measures 535.3 - Any person who shall cause or allow the generation of any odor from any source which may unreasonably interfere with any other property owner’s use and enjoyment of his or her property must use recognized best practices and control equipment to reduce these odors to a reasonable minimum. • Complaint driven • NWCAA investigates • Impact must be “unreasonable” • Impact must occur at person’s place of residence or work • Source of odor confirmed • Best practices/control • Enforcement action if nuisance odors are confirmed by field staff • Odor presence does not always = violation • Person must be willing to testify if necessary

5. NWCAA Odor Regulations Section 535 – Odor Control Measures (cont.) 535.4 - Odor emissions detrimental to persons or property. No person shall cause or permit the emission of any odorous air contaminant from any source if it is detrimental to the health, safety, or welfare of any person, or causes damage to property or business. • Emissions “detrimental” • Specifically references “welfare”

6. Registering a Complaint • Citizen files complaint with the NWCAA (by phone for odors) at the time of impact or ASAP • Information should include: • Complainant’s name, address, and phone number • Time and date • Location of impact • Description of impact • Characteristic and duration of odor • Any other pertinent information (i.e. wind direction) • Complainant willing to testify to unreasonable impact if necessary (enforcement action appealed) Note: Complaints referencing odors not at their residence or place of work will be considered FYI only

7. Complaint Response Process • Impacted person files complaint with NWCAA • Inspector investigates in appropriate manner • NWCAA contacts complainant for additional information if necessary • Potential odor source(s) contacted by inspection staff • Site investigation of potential odor source(s) conducted by NWCAA when appropriate • Formal enforcement action may be initiated by NWCAA if nuisance odors are confirmed by field staff

8. Enforcement Process Goal is compliance • “Violation” formally documented • Requires source to respond with corrective action • Allows for the imposition of penalties as incentive for compliance • Portion of penalty may be suspended if facility commits to mitigation steps

9. Odor Complaint History

10. Influences on Odor Levels & Complaints • Meteorology • Mixing of emissions • Odor “pockets” • Topography – Ohio/Iowa St. area • Multiple odor sources • Public awareness

12. Topography Map – Zoom In

13. NWCAA – Odor Area Survey Purpose: • Identify potential odor sources Identified three types of source categories • Spray coaters (12+) • Coffee roaster (2) • Wood treater (1) • Work with facilities with larger odor potential: • Evaluate overall emissions • Reduce odors • Work with remaining sources: • Evaluate overall emissions • Reduce odors

14. Potential Odor Sources - List

15. Potential Odor Sources Identified

16. NWCAA’S Actions 2003 • Windsor Plywood issued Notice of Violation (NOV) for odor 2006 • Canvassed industrial odor sources in the Iowa/Ohio areas to identify potential odor sources • Enhanced complaint investigation to include after-hour response • Issued NOV warning to Brooks for odor nuisance 2007 • Further enhanced complaint investigation to include additional after-hour response On-going: • Work with facilities to address odor mitigation efforts

17. Examples of Facility Modifications Windsor Plywood • Changed out high-emission spray guns to low-emission spray guns • Increased spray booth exhaust stack height • Operational changes

18. Examples of Facility Modifications Brooks Manufacturing 2006 • Enclosed east side of treated material storage area • Piloted “odor neutralizer” project • Installed meteorological station 2007 • Installed water spray on exhaust stack to reduce emissions • Installed 1st set of odor control devices (activated carbon) on process exhaust stack

19. Examples of Facility Modifications Brooks Manufacturing - 2007 (cont.) • Installed 2nd set of odor control devices (activated carbon) on process exhaust stack • Installed odor control device waste water system (activated carbon) • Covered open-top tanks • Installed balancing system on “work” tanks to reduce emissions • Increasing frequency of carbon change-out to once/month (formerly quarterly)

20. Examples of Facility Modifications Brooks Manufacturing - 2008 • Install odor control devices (activated carbon) on tank vents, including delivery tank • To fully enclose treated material storage and install automatic hangar doors • Increase exhaust stack height and diameter • Install and ID fan on control device

21. On-going NWCAA Actions • Continue to work with facilities to address nuisance odor mitigation efforts • Continue to respond to complaints, including after-hours when needed • Explore hiring third-party consultant to conduct odor survey • Work with City of Bellingham Planning Department

22. Brooks facility Citizen Follow-up • File a complaint with NWCAA • Information should include: • Complainant’s name, address, and phone number • Time and date • Location of impact • Description of impact • Characteristic and duration of odor • Any other pertinent information (i.e. wind direction) • Complainant willing to testify if necessary • Identify person(s) to tour Brooks facility

23. Contact Information 800.622.4627 (Whatcom & Island county) 360.428.1617 (Skagit County) info@nwcleanair.org www.nwcleanair.org