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Odor and H2S Modeling and
It's Implications, Permit
Problems
Prepared by: Edwin P. Valis, Jr
Cornerstone Environmental Group, LLC
NJ SWANA Conference, April 13, 2015
ODOR - Sources
• Working Face
• Landfill Gas
• Municipal Solid Waste (MSW) decomposition
• Construction and Demolition (C&D)
• Normal waste stream
• C&D Fines
• Storm Events
MSE Ltd & Viridis © 2002. Managing Odors at Landfill Sites, Main Report; P.
McKendry, J H Looney, A McKenzie
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Historical Odor Control Issues
• Historical Issues
• Typical Reasons for Odors
• Odiferous Waste Hauled to the Site
• Queue Times
• Working Face/Cover
• Insufficient landfill gas system controls
• Vacuum
• Well dewatering
• Well spacing
• Horizontal Collectors
• Environmental Influences
• USEPA AP-42 Section 2.4
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USEPA AP-42, Section 2.4 – Sulfur
Compounds
Total Sulfur Compound Concentration – 46.88 ppmv
This is NOT the 100’s or 1000’s of ppmv being seen at many landfills!!!!!
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Current Landfill Gas Sulfur
• Typically at least 500 ppmv, Hot Spots 1000-10,000
ppmv Total Reduced Sulfur (TRS)
• WHY?
• C&D has value
• Super Storm Sandy Waste – HOT SPOT
• How to tell if you have high sulfur?
• ODOR
• Monitor
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Landfill Gas Sampling – On-Site
Landtec GEM External Module
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Colorimetric Gas Detector Tubes
Landfill Gas Sampling - Lab
Tedlar Bags
SUMMA Canister
Sampling needs to be conducted within 24 hours for Tedlar Bags and with 48
hours for silica-lined SUMMA Canister. Analysis using ASTM D5504 or
USEPA Method 16
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New NJDEP Odor Policy Considerations
(including NJDEP Guidance Documents)
ODOR FACT SHEET
How is odor regulated?
The Air Pollution Control Act prohibits the emission into the outdoor atmosphere of air
contaminants in quantities that result in air pollution. Air pollution is defined as “the presence in the
outdoor atmosphere of one or more air contaminants in such quantities and duration as are, or tend to
be, injurious to human health or welfare, animal or plant life or property, or would unreasonably
interfere with the enjoyment of life or property.” Odor is an air contaminant and therefore may be
considered air pollution if it is present in a way that unreasonably interferes with the enjoyment of
life or property.
What triggers an odor investigation?
The Department or a local health department will initiate an investigation in response to complaints
from one or more citizens regarding objectionable odors.
Do all odor complaints result in violations?
No. In order to verify a complaint and issue an enforcement action, an investigation must be
performed and the investigator must verify the odor on the complainant’s property and concur that
the odor “unreasonably interfered with the enjoyment of life or property.” In making this
determination, the department considers the character, severity, frequency and duration of the odor
and the number of persons affected thereby. (Note – the use of a monitoring device is not
necessary to verify an odor complaint.)
How do we investigate an odor complaint?
1. After receiving a complaint, the inspector will first go to the complainant’s location and
attempt to verify the presence of the air contaminant at that location. The inspector will then
ask the complainant(s) to complete a “Statement of Complaint form.” By completing the
form, the complainant is attesting that the odor “unreasonably interfered with the enjoyment
of life or property.” Although this form is the primary basis for the violation, the
investigator must independently verify that the odor “unreasonably interfered with the
enjoyment of life or property” by performing his/her own investigation.
2. The inspector then proceeds upwind of the complainant in an attempt to identify the source
of the odor. Once the inspector believes that he/she has identified the source, the
investigator will proceed upwind of the facility and around the entire perimeter of the facility
to ensure that no other sources are contributing to the odor in question. At that point, the
inspector will enter the facility and attempt to identify the specific process or area of the
facility from which the odor is emanating.
3. Before the inspector leaves, he/she will tell the facility representative whether or not a
violation was verified. If a violation was verified, the inspector will issue the appropriate
Enforcement Action to the facility.
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New NJDEP Odor Policy Considerations
(including NJDEP Guidance Documents)
What is the penalty for an odor violation?
First offense of a violative odor release may be assessed penalties ranging from $150 up to $1,400.
Subsequent or continuing violations may be subject to penalties of up to $15,000 per violation.
Are all odors treated similarly?
No. Odors have different severity, duration and characteristics. All of these factors are taken into
account when investigating an odor complaint and determining whether the odor constitutes
“unreasonable interference with the enjoyment of life or property.” The inspectors use a scale to rate
the odors:
0-not detectable Odor not detectable; no odor perceived by the sense of smell
1-very light Odor present, which activates the sense of smell but the characteristics, may
not be distinguishable.
2-light Odor present, which activates the sense of smell and is distinguishable and
definite but not necessarily objectionable in short durations, but may be
objectionable in longer durations.
3-moderate Odor present in the outdoor air, which easily activates the sense of smell, is
very distinct and clearly distinguishable and may tend to be objectionable
and/or irritating.
4-strong Odor present, which would be objectionable and cause a person to attempt to
avoid it completely, and may cause physiological effects during prolonged
exposure.
5-very strong Odor present, which is so strong, it is overpowering and intolerable for any
length of time and causes physiological effects.
Are the above procedures and information published anywhere?
Yes. As required by the Air Pollution Control Act, the guidelines for investigating air pollution were
published in the New Jersey Register on January 2, 1996.
Who can I call if I have a question about odors?
You may call the regional field office that corresponds to your geographical area:
Northern Regional Office (Bergen, Essex, Hudson, Hunterdon, Morris, Passaic, Somerset,
Sussex, Union and Warren)
973 656-4444
Central Regional Office (Burlington, Mercer, Middlesex, Monmouth and Ocean)
609 292-3187
Southern Regional Office (Atlantic, Camden, Cape May, Cumberland, Gloucester, Salem)
856 614-3601
CALL IN COMPLAINTS OF ODORS TO THE DEPs 24 HOUR TOLL-FREE
ENVIRONMENTAL HOTLINE at 1-877 WARN DEP ( 1-877-927-6337)
dpdocs\odor.fct revised 5/30/14
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Example Permit Condition for Odor
Monitoring
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Example H2S Monitoring Permit
Condition
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Hydrogen Sulfide Handheld Ambient
Monitor
QRAE II from Rae
Systems – NOT
SENSITIVE ENOUGH
FOR NJDEP MANDATED
H2S LEVELS (i.e. 30
ppb)
Jerome J605 hydrogen sulfide analyzer made by
Arizona Instruments
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Air Quality Dispersion Modeling
• Issues and Challenges
• H2S Health Risk Modeling
• 42 ug/m3 (30 ppb) NJDEP short-term reference
concentration
• Odor Modeling
• Dilution to Threshold (D/T)
• Odor Threshold
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Odor Thresholds
SOURCE: New Jersey Department of Environmental Protection, Division of Air Quality, Bureau of Technical ServicesTechnical Manual 1002 - Guideline on Air Quality Impact
Modeling Analysis, November 2009
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Odor “Masking”/Neutralization
• “Masking”
• Does not address underlying issues of gas control
• May be a viable working face technique
• Some contain volatile organic compounds which may be
an Air Permitting issue
• Neutralization
• A viable “control” technique?
• Air Quality vs. Solid Waste Guidance
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Legal Issues
• Fenimore Case - Strategic Environmental Partners,
LLC v NJDEP
• Self Reporting/Self Incrimination
• UARG v. EPA US Supreme Court Case
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How to Avoid Future Odor Issues????
• Keep C&D Away from Municipal Solid Waste (MSW)
• Dedicated C&D Cells
• Engineered C&D cells within MSW Cells
• Faster Final Cover Placement
• Interim Horizontal Gas Collection to Engineered Control
• NJDEP Permit Negotiations
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Questions????
Edwin P. Valis, Jr. - Senior Project
Manager
Cornerstone Environmental Group
(845) 695-0221
edwin.valis@CornerstoneEG.com