Sunnyland Neighborhood Association Odor Presentation
January 15, 2008
NWCAA Programs & 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
Overview of Topics:
NWCAA Odor RegulationsSection 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
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”
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
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
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
Odor Complaint History
Influences on Odor Levels & Complaints
• Meteorology
Mixing of emissions
Odor “pockets”
• Topography – Ohio/Iowa St. area
• Multiple odor sources
• Public awareness
Topography Map – Zoom In
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
Potential Odor Sources - ListFacility Name Address
Process Equipment
Facility Name Address
Process Equipment
Boulevard Customs 2227 Queen St.
Spray booth - Auto body painting
Moka Joe's Coffee 2118 James St. RoasterGrand Central Collision, Inc. 1811 Iowa
Spray Booth - Auto body painting
Three Sun's Roasting Company 2209 Queen St. Roaster 20/20 Customs 2145 Queen St.
Spray Booth - Auto body painting
Haskell Corporation 1001 Meador Ave
Spray booth for finishing, lacquer
Olsen Auto Body & Collision 1919 Humbolt St.
Spray Booth - Auto body painting
Price and Visser 2207 Valencia St.Paint Booth - Doors, cabinets
Custom Design & Awning (CDI) 423 Kentucky Spray Booth
Al's I-5 RV Inc 2039 Moore St.
Minor painting with spray cans - touch-up Final Finish 611 Kentucky
Spray Booth - Auto (touch-up bumpers)
Diehl's Collision Center 1820 James St.
Spray Booth - Spray coating cars
Bellingham High School 2020 Cornwall
Three-sided Spray Booth
Windsor Plywood 2119 Queen St.Spray Booth - Lacquer
Brooks Manufacturing Company 2120 Pacific St.
Lumber treating facility specializing
Tero Company 2127 Lincoln St.Spray Booth - Lacquer
Pearson Construction 2034 Franklin St.
Staining, Some minor painting at night
Steve Hall Woodworking 2139 Humbolt
Spray Booth - Lacquer Chuck's Shop 1830 Grant St.
Another owner suggested painting at
Towne Painting Co. 2116 Queen St.
Spray Booth - Lacquer Northwest Honda 2010 Iowa
Mobile Repair Unit On-Site
Greg Aanes 2109 Queen St.Spray Booth - Lacquer
- Veteran's Autobody
Mobile Repair of bumpers w/spray guns
Bellingham Collision Repair 2034 Moore St.
Spray Booth - spray coating cars
Pro-tent & Pro-deal 1400 Kentucky
Possible touch-up painting
Potential Odor Sources Identified
NWCAA’S Actions2003
•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
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
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
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)
Examples of Facility Modifications
• 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
Brooks Manufacturing - 2008
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
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
Contact Information
800.622.4627 (Whatcom & Island county)
360.428.1617 (Skagit County)
www.nwcleanair.org