,..,..

,MATERIAL
MATTERS,Inc.

Memo
To: Tom Petrucci, Township Manager
Plainfield Township, azareth PA 18064

From: Robin C. Brandt, Ph.D., P.E.

Trudy Johnston
CC: File
Date: January 17,2019
Re: Slate Belt Heat Recovery Center - Material Matters, Inc. Review Comments Pertaining the
Synagro Nuisance Mitigation Control Plan Submission Dated January 09, 2019

This Technical Memo (TM) contains comments resulting from Material Matters (MM) review of the
above referenced submission by Synagro on January 09,2019. For this review we focused on the original
pdf submission as the base for initial DRAFT Mark-Up comments (See accompanying pdf DRAFT Mark-
Up file). In this TM, comments are linked to the aforementioned pdf file by citing the pdf page number
and topic. This narrative is intended to summarize, clarify, and in many cases supplement review
comments initially inserted as DRAFT pdfMark-Ups. This approach will be helpful to insure that
remaining nuisance concerns are addressed.

Over-all Comment:
This updated NMCP submission addresses comments provided in the previous MCP submission by
Synagro, which has been incorporated in this latest version. However, several comments remain, as
provided herein.

Pages 7 and 8 - 4.0 Nuisance Prevention Design Operating Features:

1. NH3 shall be included in the AERMOD dispersion study, both for pre-construction and at
commlsslomng.
2. AERMOD output Isopleth plots shall depict the following parameter concentrations for both pre-
construction and at commissioning:
a. 0.001 ppm HzS,
b. 0.08 ppm H3, and
c. 20U/m 3
3. All significant emission sources must be included in the AERMOD modeling study, including: the
Odor Control System stack, and; all area and fugitive emissions from the dewatered biosolids
receiving and storage area (including trucks in que), and the Class A product loadout and storage
area.)
4. It may be appropriate to address details regarding the AERMOD dispersion modeling as an SOP
in the SOP section of this MCP document.

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Page 11-7.0 Documentation - Reference to Professional Odor Support (POS)
Professional Odor Support as proposed in the current MCP document is unsatisfactory. See
narrative provided below for detailed discussion (See comments for pages 19 thru 22 - Item 7).
Accordingly, narrative on page 11 shall be revised as appropriate when an updated POS document is
developed.

Page 16 - Community Response Plan - Community Complaint and Response Form

A map showing location of complaint shall be prepared and attached to the Complaint Response
Form. Show location to best of ability based on complainant description. This map shall be the base
map described in the current NMCP in the ATTACHMENT immediately following APPENDIX H of
the PPC Plan herein. Minimum scale 1" = 1000' and show location of all potential sources as
described in the narrative accompanying that piece. Location of other complaints is not necessary on
this particular map as it focuses on immediate complaints, at that time.

Item 4. Nuisance Monitoring and Documentation - Name the "outlined procedure" and where the
procedure is located within the NMCP.

Item 6. Walk through observations - The walk through items listed should be expanded to include all
potential sources of odors, with observations documented.

Pages 19 thru 22 - Community Response Plan - Odor Monitoring and Documentation Performance
Standard:
1. Minimum routine monitoring frequency shall be daily and include times of day associated with
peak nuisance odor events, as revealed in three-year historical odor complaints (gathered by
SBHRC).
2. H2S monitoring equipment: All references to 0.1 ppm H2S shall be replaced with 0.01 ppm in this
section.
3. NH3 monitoring shall be included in this section.
4. NH3 monitoring equipment: Minimum required detection level shall be 0.1 ppm H3
5. 0-6. IfH2S and/or NH3 concentration exceeds established thresholds ..... or odor is observed and
confirmed by SBHRC personnel during investigation:
a. Document field instrument reading(s), and
b. Record that the presence of an off-site odor has been confirmed by investigating SBHRC
personnel.
6. 0-7. Insert "Proceed to preliminary identification of potential odor source" ..... then include
remaining narrative in current step 0-7.... Ending with reference to Professional Odor Support
(POS)
7. General comment. Provide specific (unambiguous) language describing circumstances triggering
POS evaluation specified in existing step 0-10. (Revise and/or add steps bridging existing 0-6
thru 0-9 to provide unmistakable clarity.)
8. Professional Odor Support (POS)
Off-site Dynamic Dilution Olfactometry (i.e. Dynamic Triangular Forced-Choice Olfactometry,
DTFCO) ofTedlar bag samples is OT an appropriate method for assessing low concentration
odor samples that have been significantly diluted with odorless ambient air, distant from the odor
source. There are several reasons for this, including:
a. Preconditioned Tedlar™ bags still have a residual background odor that is routinely
greater than 10 OU/m 3. Off-site fugitive odors will presumably contain low concentration /
dilute odorants. If detection by a neighbor or passer-by is "questionable", it is essential to

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 have an objective follow-up method for determining whether an odor is present (or not).
When a high concentration odor is observed, a consensus of all involved should be
relatively easy to achieve. Even though measured H2S and/ NH3 concentrations may be
very low, presence of other odorants (e.g. other reduced sulfur compounds, nitrogen
compounds, volatile fatty acids, phenols, etc.) may be present in sufficient amounts to
create highly objectionable odor conditions. Upon acknowledging a nuisance odor
incident, it is understood that the SBHRC will promptly advance the mitigation process
directly to source identification and appropriate conective actions. Use ofDTFCO, along
with sampling for specific odorants (in addition to H2S and NH3) to further
assess/characterize the identified emission odor source (at the source) would be a useful
strategy to evaluate additional, or improved odor treatment technologies, but not for
assessment/characterization of dilute downwind sample locations.
b. Storage of odorous air in sample bags, even for a short period of time, introduces
unpredictable alterations in odor composition due to selective odorant interactions with bag
material and chemical decomposition/interactions. (Note: IfDTFCO were used to evaluate
air samples in addition to odor intensity, and persistence, it is doubtful that I-L Tedlar
sample bags would provide sufficient volume for testing due to the very dilute nature
expected in off-site emissions.)
c. Direct, real-time observation of odors in the field cannot be accurately simulated in a
laboratory using stored air samples from the field. The human nose is much more sensitive
than cunent laboratory technology can achieve, and the human nose is the sensor that
neighbors will ultimately use to detect and judge if a nuisance odor episode has (or is)
occumng.
d. The challenges associated with the above issues are fundamental reasons favoring field
olfactometry techniques for assessment / documentation of off-site nuisance odor incidents
elsewhere. It is understood that use of field olfactometry introduces many logistical
challenges, but with thorough planning, a strategy for use of a human odor panel in the
field can be accomplished. For example, the PSU Odor Assessment Laboratory (PSOAL)
has performed many surveys using a Multiple Assessor Repeat Observation (MARa) field
olfactometry technique (Nasal Ranger™ field olfactometer units), developed at Penn
State 1. This method uses four (4) assessors plus one (l) test administrator who supervises
testing and collects all field observations. All assessors are pre-qualified at the PSOAL
before going to the field and trained in the MARa method. One could assume that non-
locals with no ties to Synagro could be objective odor panelists. Notably, this multiple
assessor approach could be performed without the use of Nasal Ranger units, if
appropriate. However, use of Nasal Ranger™ instruments would enable quantification of
odor concentrations in the form of dilution-to-threshold (D/T) values.
e. Field olfactometry can facilitate real-time delineation of odor plume spread and aid in
identifying the odor source. Even if one assumes DTFCO measurements are an effective
means to quantifying very dilute odors in ambient air, pulling many air sample in Tedlar™
bags for off-site DTFCO assessment, with results provided 72 hours later, would seem to
be an inefficient (and expensive) way of documenting an off-site odor episode. Odor plume
delineation via off-site DTFCO would be a very significant undertaking making this
approach impractical.

1 Brandt, R.C., MAA. Adviento-Borbe, HA Elliott, E.F. Wheeler. 2011. Protocols for Reliable Field Olfactometry
Odor Evaluations. J. Appl. Engr. Agr. Vol. 27(3): 457-466

SBHRC_NMCP_MM-Comments (OI-17-2019)Final.docx Page 3 of5

 f. The Plainfield Township zoning ordinance (Chapter 27, subsection 27.410 4(B» states that
"No odorous material may be emitted into the atmosphere in quantities sufficient to be
detected without the use ofinstruments." It is unclear if off-site DTFCO analysis of
Tedlar™ bag air samples would represent a conflict with this stipulation. At the face of it,
use of a human odor panel for on-site, real-time assessment of odors would seem to be
more consistent with the intent of the ordinance.
9. It may be appropriate to address details regarding Professional Odor Support in the SOP section
of this NMCP document:
a. Inclusion of this SOP in the SOP section of the NMCP would facilitate future reference.
b. This SOP shall fully describe the circumstances triggering pas and methodology to be
used for odor verification / quantification via olfactometry methodes) by the pas provider.
c. Refer to this SOP throughout document as appropriate.

Pages 19 thru 22 - Community Response Plan - Noise Monitoring and Documentation Performance
Standard:
Under Action Items in the event of confirmed noise concern - What is "second staff'?

Page 28 - Dust Monitoring and Documentation Performance Standards

Under List of Documentation, include site dust observations as part of the daily rounds.

Page 31- Attachment - Nuisance Mitigation and Control- Focus Areas - Dewatered Biosolids
Receiving and Storage Area:
Under Operational Mitigation - Insert "appropriate negative pressure value range that must be
measured routinely and maintained".

Also insert "daily observation and documentation of odors adjacent to tlucks waiting to offload
during peak daily offloading times".

Under Actions to Take if receiving and storage area operating improperly - What is "In-Route
drive agreement"?

Page 34 - Attachment - Nuisance Mitigation and Control- Focus Areas - Process Wastewater
Storage and Loadout:
Under Operational Mitigation - Insert - Monitor performance and service carbon filter to maintain
effectiveness. Minimum filter cartridge change-out frequency is 4-months. More frequent change-
out is based on daily inspection findings.

Page 36 - Attachment - Standard Operating Procedures:

1. As noted earlier in this comment summary, it may be appropriate to address details regarding
Professional Odor SUPPOlt in the SOP section of this NMCP document, via two additional SOPs:
a. SOP for conduct of AERMOD dispersion modeling, and
b. SOP for circumstances triggering Professional Odor Support and methodology to be used
for odor verification / quantification via olfactometry methodes) by the pas provider.
2. Inclusion of these pieces in the SOP section would facilitate future reference, as opposed to
indistinct placement elsewhere in the NMCP text. Working through an SOP mindset process will
help to insure that thorough step-by-step procedures are thoroughly defined for immediate
implementation if / when pas is needed.
3. Refer to these SOPs throughout document as appropriate.

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 4. There are many references to information throughout the SOP narrative herein that are not
currently available for inclusion in the MCP at this time (e.g. equipment #, Instrument IDs,
operating parameters, PADEP approved PPC Plan, etc.). SBHRC management shall promptly
update the NMCP document with this information as it becomes available prior to substantial
completion of the facility.

Page 38 - Housekeeping
8.0 Procedures, Specific Tasks. Add the Dewatered Biosolids Receiving Station and surrounding
area as a housekeeping area with appropriate inspection schedule.

Page 49 - Dewatered Biosolids Receiving

8.0 Procedures 8.1.1 - Add "and inbound truck tarping and gate locking system is operational.
Confirm / document tarping and gate systems were in working order during transportation".

Page 52 to 53 - Thermal Drying Process Monitoring Procedures

3.0 Risks and Hazards - Add risk for fire and explosion.
8.0 Procedures - When updates completed to "thermal dryer system specific content", include fire
and explosion condition monitoring and reponses.

Page 57 - Class A Product Loadout

3.0 Risks and Hazards - Include risk for product heating and fires.

7.0 Operating Parameters & Limits - Include details about temperature monitoring system, system
testing, and fire suppression system, if any.

Page 63 - Process Wastewater Storage and Liquid Loadout

7.4 Process Wastewater Storage - What is "Collected Precipitation Release"?

Pages 98 to 156 - Contingency Plan for Emergency Procedures

Detailed comments on the Contingency Plan were provided to the Township by Material Matters
dated December 28, 20 18. Additional comments are not provided herein.

Pages 158 and 159 - Attachment - Potential Source Inventory Map and Complaint Log List:
It is understood that the Synagro is requesting information for these exhibits from Pen Argyl Borough
and Plainfield Township. Similar information may also be available from the PADEP.

Page 166 to 169 - Attachment - Sample Odor Panel Report:

Collection of Tedlar™ bag samples directly from an odor source for laboratory assessment is a
common well-established practice. While informative, the Sample Odor Report information provided
in this attachment is not appropriate for investigation of dilute off-site odors that may (or may not)
originate from the SBHRC. This section of the NMCP should be supplemented, or replaced, with an
appropriate Field Olfactometry technique that can be implemented on the ground (in real time) at the
SBHRC property line and vicinity. As noted earlier, Professional Odor Support may best be presented
as an SOP in an updated version of this MCP (See page 36 comments above).

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