From Emission Summary table# 4
All the following report is from the Application to the Ministry Of Environment EMMISSION SUMMARY AND DISPERSION modeling report dated February 2010 Ref.no.046254 (3)
Emission Rate 1 Odour unit at MINISTRY OF THE ENVIRONMENT point of impingement limit (Is the Point that the MOE chooses as the most likely point where a resident will be most affected by odours.)
This odour level is the worst fear for local residents, but is given a Not applicable MOE POI limit. This not expected to be the case. (My opinion only)
Total reduced sulphur is expected to be very high and is widely dependent on the incoming organic material.
Old incoming material, e.g. manure, would have high total reduced sulphur (very odorous) and in return have high impact on what is discharged by the bio-filter.
Material that is not suitable for processing is sorted and dumped into a bin.
This may be odorous and is expected to be odorous. This must be taken off the property as soon as possible, at least within 3 days.
The surface water management will use recycled water or fresh municipal water to balance the water losses.
There is no doubt that water is required for this process. The question is, where does this water come from? Municipal or offsite, and how much is anticipated? This was proposed originally as a dry process. Is this no longer possible?
The EMISSION SUMMARY AND DISPERSION MODELLING REPORT was prepared in accordance with MOE REGULATION 419/05. The emission rates are all estimates. Odour was modeled in Aermod. (A METHOD OF EVALUATING ODOUR) The report demonstrates that the facility can operate in compliance with Reg. 419/05.
On figure 3A of the Emissions Summary it is very important that all solids recovery trucks are covered and sealed to prevent odours from escaping.
Source Summary Table
Stack diameter is .54M and 20M high and 13.4M above the building.
This height should be at least two times the proposed height. Neighbouring properties are in line with the proposed height. It is expected that odours will be significant from this operation and not only from the bio-filter stack. Stack Flow rate of 5.56 M3/second should be increased.
Emissions from bio-filter (total reduced sulphur) shown as not applicable. Odours are shown as not applicable.
There are odours from a bio-filter and they should be noted as a major contributor.
CRA Memorandum page 3
The bio-filter stack was identified as the only significant source or odour emission at the proposed facility.
Truck traffic of uncovered trucks, opening and closing of doors, and open tanks at the property, will all add to the total odour emissions.
Other concerns and comments
1. A peer review must be done of the project, especially for odour potential.
RWDI is a great environmental group and would be fair to be used as a peer review.
RWDI is from Guelph, Ont. (R W D I is a consulting group in Guelph). What is the pre-treatment for the odour control bio-filter?
This plant should be moved away from Elmira town limits and onto a farm. This would save a lot of resident opposition to the proposal.
The property overall is small. As we can foresee, many trucks could be on the property at the same time. Is there room?
The bio-filter is a living organism and can not take heat. How is the air stream to the bio-filter cooled?
The air exchange in the plant or process is expected to be one.This means that the air in the plant is replaced with new air once per hour. This is almost 0, and odours will certainly escape from the area. It is more realistic to require 5-10 air changes per hour to keep the building in a negative air pressure.
Trucks are expected to be tarped. This will not seal the trucks and odours will be emitted.
2. Whathappenswhentrucksarearrivingandtheplanthasbrokendown? (a)Willtrucksturnaround?(b)Dowehavesparespartsattheplanttokeeptheprocessoperating?WhathappenswhentherearesubstantialodoursatPointofimpingment?Whatcanbedone?Whomdowecall?
Who or what decides what material goes for processing in the plant – for example, the cost of material received, or advantage of material used for gas production?
The truck drivers that haul material into the plant must be licensed waste haulers. The products that are trucked are Organic wastes and Hazardous wastes
A public committee of concerned residents must receive a monthly report on environmental issues.