orgaworld canada ltd. london facility...(omp) for the london facility. this odour management plan...

ODOUR MANAGEMENT PLAN

ORGAWORLD CANADA LTD.

LONDON FACILITY

LONDON, ON

ODOUR MANAGEMENT PLAN

RWDI # 1801815

March 28, 2018

ODOUR MANAGEMENT PLAN (OMP)

ORGAWORLD CANADA LTD. LONDON FACILITY

March 28, 2018

rwdi.com

TABLE OF CONTENTS

INTRODUCTION ..................................................... 1

1.1 Facility Description ................................................... 1

1.2 Objectives ............................................................. 3

1.3 OMP Structure .......................................................... 3

ROLES AND RESPONSIBILITIES & TRAINING ............................ 3

2.1 Management Responsibilities and Review ................................. 3

2.2 Training and Competence ................................................ 4

DESCRIPTION OF SITE OPERATIONS AND PROCESS ....................... 4

3.1 Overview ............................................................... 4

3.2 Description of Site Activities ......................................... 4

3.3 London Facility Process Description .................................... 5

3.4 London Odour Abatement System .......................................... 6

3.5 Potential Impacts ...................................................... 9

ODOUR GENERATION AND CONTROL MEASURES ............................ 9

4.1 Odour Control During Normal Operations ................................. 9

4.2 Controls on incoming waste ............................................ 10

4.3 Controls of Out-going Waste ........................................... 11

MEASUREMENT OF ODOUR ............................................ 11

ROUTINE MAINTENANCE AND INSPECTION .............................. 11

6.1 General ............................................................... 11



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6.2 Building Containment .................................................. 12

6.3 Maintenance of other plant and equipment. ............................. 12

6.4 Monitoring ............................................................ 12

6.5 Regular Olfactory Monitoring .......................................... 13

6.6 Monitoring Impacts .................................................... 14

6.7 Record Keeping and Reporting .......................................... 14

6.8 Actions in the Event of Abnormal Emissions ............................ 14

6.9 Contingencies ......................................................... 15

COMPLAINT HANDLING AND COMMUNICATIONS ........................... 15

7.1 Contact details for complaints. ....................................... 15

7.2 London Complaints Investigation Procedure. ............................ 16

7.3 Further Investigation of Complaints ................................... 17

LIST OF APPENDICES



March 28, 2018

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VERSION HISTORY

Index Date Pages Author

1 March 26, 2018 All Brad Bergeron (RWDI)

2 March 28, 2018 All David Veinot (Orgaworld)



March 28, 2018

Page 1

INTRODUCTION

RWDI AIR Inc. (RWDI) was retained by Orgaworld Canada Ltd. (Orgaworld) to complete an Odour Management Plan

(OMP) for the London facility. This Odour Management Plan documents the methods by which the Orgaworld

London Facility will manage, monitor, reduce and prevent potentially odorous emissions, from operations at the

Orgaworld London Facility. In preparation of this OMP, RWDI obtained copies of the following reports:

Emission Summary and Dispersion Modelling Report, Orgaworld Canada Ltd. London dated July 2011

prepared by GHD.

Source Testing Report, Orgaworld Canada Ltd. London, dated September 21, 2012 prepared by Conestoga-

Rovers & Associates (now referred to as GHD).

Final - Interim Report No. 1 - Results of a Voluntary Odour Sampling Program, Orgaworld Canada Ltd.

London, dated December 7, 2017, prepared by Pinchin Limited.

1.1 Facility Description

The facility is owned and operated by Orgaworld Canada Ltd. and operates under the same name. The facility is

located at 4675 Wellington Road in London, Ontario N6E 3W7. The facility operates under Amended Certificate of

Approval (ECA) 2450-8KVG84 dated October 24, 2011 (Appendix A). Within the ECA, there are numerous conditions

provided to control odours at the site, the following is a bulleted list of the conditions:

Condition 2: The Company shall ensure that the maximum 10-minute average odour concentration of odour at

the most impacted Sensitive Receptor, computed in accordance with Schedule B, resulting from

the operation of the Facility, shall not be greater than 1.0 odour units.

Condition 3: The Company shall monitor and record the physical parameters of the ammonia scrubber, the

Bioscrubber and the Biofilters, through a combination of sensors, meters, physical probes or

equivalent means, at frequencies either as recommended by the Equipment suppliers or as

determined by operational needs. (refer to Section 5 for Monitoring Requirements)

Condition 5: The Company shall ensure that the Facility is properly operating and maintained at all times. The

Company shall:

(1) Review and update, as necessary, within three months after the date of this Certificate, its

current Manual which outlines the procedures of the Facility that relate to odour and noise, as

well as the operating procedures and a maintenance program for the Equipment with in

accordance with good engineering practices, to ensure that the Manual includes the following:

a) Routine and emergency operating and maintenance procedures recommended by the

Equipment suppliers including operating procedures for the Facility that relate to odour

and noise during Equipment malfunction, power outages, by-passes and other emergency

or abnormal operating conditions and procedures for notifying the Ministry of such

events.;



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b) Procedures to monitor and record the temperature and relative humidity of the air exiting

the composting tunnels;

c) Procedures to monitor and record the quantity of ventilation air that bypassed the

composting and the quantity of air that are collected by the composting tunnels to the

flow splitting box;

d) Procedures to monitor and record the quantity of air flowing through the two (2)

ammonia scrubbers;

e) Procedures to monitor and record the concentrations of ammonia in the air entering and

leaving the ammonia scrubbers;

f) Procedures to monitor and quantify the sulphuric acid solution in the storage tank of the

ammonia scrubbers;

g) Procedures to monitor and record the results of the monitoring and the frequencies of

monitoring of the parameters of the ammonia scrubbers, Bioscrubbers, and Biofilter in

Condition 3 above;

h) Procedures to monitor and record the results of monitoring the quality of water in the

water sumps of the Bioscrubber, and the criteria of replacement of water in the water

sump of the Bioscrubber; of the booster fan in the period of November 1 to March 31 of

the next year, to drawn ambient air into the Facility Stack;

i) A Fugitive Control Plan, identifying odour sources from the operation of the Facility, and

outlining the physical and procedural controls such as policies and standards required in

order to prevent or mitigate fugitive odour emissions from the operation of the Facility;

Condition 6: The Company shall keep all doors in the enclosed building of the Facility fully closed at all times

except when used for necessary personnel or vehicle entrance and exit.

Condition 7: The Company shall ensure that the enclosed building and the Compost Curing Building of the

Facility are operated under negative pressure at all times, when there are unprocessed or partially

processed materials inside the building or Compost Curing Building.

Condition 8 to 15: Source Testing

Condition 16: Record Retention

Schedule “B” Procedure to calculate and record the 10-minute average concentration of odour at the Points of

Impingement and at the most impacted Sensitive Receptor

The London composting facility is able to receive and process up to1,000 tonnes per day and 150,000 tonnes per

year of organic materials including source separated organics (SSO) and leaf & yard waste employing the aerobic

tunnel composting process followed by screening and curing to finished compost/NASM. Much of this waste is

collected in plastic bags.



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The separated organic waste is processed in the London tunnel composting plant. Once the plastic bags arrive at

our site they are opened using a shredder/bag ripper. The organic waste is then mixed with an inoculum. This mix is

then composted in special composting tunnels over the course of approximately 14 days. .

The plant is kept under negative air pressure to limit the emission of odours and particles. We also pass air through

dual ammonia scrubbers, an air cooling heat exchanger system, a bio-scrubber and bio-filters so that odour

components are removed before the air is released into the atmosphere via a special stack with ambient air

dilution.

1.2 Objectives

The Orgaworld London Facility OMP has been designed with the following objective clearly in mind:

The facility must meet the odour performance standard of not exceeding 1.0 ou/m3 based on a 10-minute

average, more than 0.5% of the time measured using AERMOD Dispersion Modelling at the Critical

Receptor Points

This OMP considers sources, releases and impacts of odour emissions arising from the activities at the site and

identifies effective measures for odour management.

1.3 OMP Structure

This Odour OMP is structured as follows:

Section 1: Introduction;

Section 2: Summary of site operations;

Section 3: Identification of odour generation sources, releases points and controls during normal

operations;

Section 4: Routine maintenance.

Section 5: Routine monitoring methods and process set points to minimize odour generation, emission

points, dispersion and impacts;

Section 6: Identified contingency measures; and

Section 7: Complaint handling and communication.

ROLES AND RESPONSIBILITIES & TRAINING

2.1 Management Responsibilities and Review

It is the responsibility of the Site’s Operations Manager to ensure that the requirements of this document are

adhered to. If the Operations Manager is unavailable or non-contactable, the contingency management staff to be

contacted are as follows:



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Process Engineer

Maintenance Supervisor

This OMP is intended to be a live document which serves as a reference during daily operations, as such it will be

reviewed and updated should the following occur:

Significant changes are made to the plant or operational practices;

Substantiated complaints are received, which on subsequent investigation result in the identification of

further control measures or remedial action.

2.2 Training and Competence

The Orgaworld London operation follows a well-defined and documented management system. The

management system covers training, awareness, and competence for all staff. All new employees receive

induction and awareness training and job specific training as required.

All staff at the Orgaworld London facility will be made fully aware of the need to be constantly vigilant regarding

site odour control and the importance of reporting of issues to site management. The Operations Manager and

Process Engineer are responsible for:

Training the staff on the aspects of this odour management plan as it relates to their job;

Ensuring staff are trained in the key process areas with regards to their significance for odour

generation;

Ensuring all training events are documented.

DESCRIPTION OF SITE OPERATIONS AND PROCESS

3.1 Overview

The London facility consists of an aerobic in-vessel composting waste treatment process. Designed and operated to

treat source separated organics and leaf & yard waste from various municipalities . The facility has the capacity to

process a maximum of 150,000 tonnes of municipal/commercial solid waste per annum.

The facility will operate on a continuous basis using a computerized SCADA system for process control. Various

process parameters will have an alarm condition that will automatically notify site staff of any condition that

requires a process alteration.

3.2 Description of Site Activities

The Orgaworld London facility comprises the following operational areas:



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Main enclosed process building (including receiving area with shredder, composting tunnels, main drive

aisle, compost storage, screening hall, bioscrubber, ammonia scrubber, and the biofilters)

Compost shed

Site office building

Weighbridge

3.3 London Facility Process Description

The overall process for the Facility is described below:

The incoming SSO waste is unloaded in the Receiving Hall.

The fresh SSO waste is first put through a shredder to break down the SSO material into smaller sizes and

to blend the different sources together.

The SSO waste is mixed with a small proportion of previously composted waste. Through mixing, the waste

is given proper structural characteristics and provided with a high rate of initial biological activity.

The material is transported into the tunnels by front end loaders.

After tunnel filling, the doors are closed and the tunnels are sealed.

Air is blown into the material through the floor and is either recirculated inside the tunnel or is exhausted

to the biofilters.

Leachate is collected from a tunnel drainage system and then re-used to moisten the material through

sprinklers located on the ceilings of the tunnels.

The material advances through various process stages including heating, hygienization, stabilization, and

cooling.

A computer-controlled system monitors the process using sensors located throughout each tunnel and

ensures the water content, air temperature, oxygen content, air pressure, and air flow are in the preset

ranges for all stages of the process. These parameters are continually monitored and adjusted to maximize

biological activity.

In addition to the biofilter compartment, a bioscrubber provides additional treatment of the biofilter

exhaust. A 60 metre (m) high emission stack further ensures that odours are controlled with the provision

for the use of a booster fan allowing for an additional 20.83 cubic metres per second to be added for

dilution air.

An ammonia scrubber is included before the biofilters in order to respond to any increases in ammonia

level (dependent on incoming waste stream, composting cycle, etc.) to extend the longevity of the biofilter

media.

The air constantly flows through the system, ensuring that all indoor areas are under negative pressure

throughout.

After the composting process, tunnels are unloaded and the composted materials are screened in an

indoor mechanical screening process. The screening process results in three streams:

o Oversized material, typically contamination, is sent for landfill disposal



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o Oversized material to be composted again and used as structural material (inoculants)

o Compost ready for storage and final maturation outside in the compost shed

Appendix B illustrates the location of the sources of emissions at the site.

3.4 London Odour Abatement System

The basis of the odour abatement system is containment, extraction and treatment of odorous air. The London

Odour Abatement strategy is as follows:

1. Odour-laden air streams are collected and sent through the odour abatement system. The abatement

system consists of an ammonia scrubbers, bioscrubber and biofilters.

2. Use of a “cascade” system of air management to minimize the total air volumes by using air from the

receiving hall and tunnel hall as fresh input air for the composting tunnels.

Note that outside air enters the facility by passive wall mounted louvers. When the overhead doors open, these

louvers automatically close so negative pressure is maintained. The operational philosophy is that indoor air in the

facility is reused in other processes, but all exhaust air eventually leaves the facility after treatment by the odour

abatement system.

Odour Abatement Equipment

The processing building is equipped with a ventilation system that maintains negative pressure within the building

drawing air from the receiving and traffic halls, screening area and pump room and air from the Compost Building.

Collected air is either drawn into the composting tunnels before being sent to the exhaust system or directly to the

exhaust system that directs all collected air to the odour abatement system consisting of the following:

Collected air is first sent to two (2) roof mounted ammonia scrubbers, using sulphuric acid as

scrubbing medium to pre-treat the collected air and remove ammonia;

After the ammonia scrubber, the pre-treated air is sent to one (1) enclosed cross-flow bioscrubber;

After the bioscrubber, the air is sent to the biofilters consisting of five (5) enclosed up-flow biofilters;

After the biofilter, the air is sent to the discharge stack consisting of one (1) 60m tall stack at a

maximum flow rate of 50 cubic metres per second, the system is also equipped with three (3) booster

fans that draw in ambient air prior to discharge at a combined maximum flow rate of 20.83 cubic

metres per second. The exhaust system and booster fans have a combined maximum flow rate of

70.83 cubic metres per second.

The odorous air originating from the receiving hall, compost storage/screening area and composting tunnels is

mixed and sent through the system. The air leaving the mixbox will now be a relatively consistent odour and heat

level, and will have a maximum flow-rate of approximately 210,000 m3/hr. From the mixbox, the process air goes to

the ammonia scrubbers.



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The ammonia scrubber forces the exhaust air through a EDPM media, where it is sprayed with an aqueous mixture

of water/sulphuric acid. The resulting chemical reaction creates ammonium sulphate. This reaction continues until

ammonium sulphate of suitable concentration is created (monitored by a conductivity probe), then this solution is

dumped, the scrubber filled with fresh water/acid, and the process repeated. After the ammonia scrubber, the

levels will be <10 ppm. The ammonium sulphate solution discharged from the scrubber can be marketed as a CFIA-

registered fertilizer.

After the ammonia scrubbers, the air has the potential of being quite hot (>55oC due to compost tunnel

pasteurization), and must be cooled to remove the danger of the hot air negatively impacting biofilter performance.

Therefore, cooling towers, mounted on the roof, are used to produce a cold water stream that is used in

combination with stainless steel heat exchangers. The water from the cooling section of the bioscrubber is passed

through the heat exchangers and is cooled. The process air passing through this cooled water stream is then cooled

to below 40oC.

From the ammonia scrubbers, the air travels through to one of two cooling sections in the bioscrubber, which are

horizontal scrubbers where water is sprayed counter-current flow to the air. From the cooling sections, the air

travels through one of two humidifying sections of the bioscrubber. The goal of the humidifier is to prevent the

biofilters from drying out, and to remove odorous compounds from the airstream. The water in the humidifiers is

reused until a conductivity set point is reached. At this point the water is dumped and the humidifiers refilled with

fresh water.

The next stage of the odour abatement system is the five (5) biofilters. Biofilters T2a and T2b are 35m long X 4.5m

wide X 6 m high and T3, T4 and T5 are 35 m long x 9 m wide X 6 m high and are filled with 2.5 metres of biofilter

material. Contact time between the exhaust air and the biofilter media is 50 seconds.

The incoming humidified air is passed into the biofilter tunnels equipped with perforated PVC pipes buried within

the floor. These pipes act as a spigot floor, which gives both effective air distribution and allows the efficient

drainage of any excess water. The odorous compounds in the air are initially absorbed in the water layer on the

surface of the biofilter material. The population of bacteria and fungi that live on the media break down odorous

compounds as the air passes through the media and converts them into harmless compounds such as carbon

dioxide and water.

The exhaust air is then blown by fans and forced out the top of a 60m stack that helps provide optimum dispersion

to meet the odour guideline of 1.0 OU.



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Diagram 1:

Pathways

The pathway by which odours may impact upon receptor locations is a result of atmospheric dispersion. In general,

high wind speeds lead to emitted odour being rapidly dispersed and diluted due to turbulence, while low wind

speeds inhibit the dilution of odours, particularly when combined with cold conditions.

All efforts have been made to minimize potential impact on the surrounding area by having all treated exhaust air

from the facility exit via a 60m high stack. The combination of stack discharge velocity, height of the discharge stack,

and low odour content of the exhaust air are all steps taken to minimize impacts on the surrounding area.

Receptors

Potentially sensitive receptor locations for odour are typically defined as locations where people spend time and

have expectations of a high level of amenity. Therefore, residential properties are generally regarded as the most

potentially sensitive locations along with some recreational (such as parks) and commercial areas (such as

restaurants) where the duration of exposure may be several hours. Other recreational, commercial and industrial

areas are considered as being of medium to low sensitivity given the limited duration of exposure and lower

expectations.



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For London, there are numerous sensitive receptors less than 1,000 metres from the facility, with receptors as

close as 250 metres from the site. Appendix C provides a figure noting the location of the sensitive receptors

around the London facility.

3.5 Potential Impacts

The likelihood and frequency of exposure to odour arising from the facility is determined by the magnitude of

release, the prevailing meteorological conditions, and the distance and direction of receptors in relation to the

facility. A detailed odour impact assessment of emissions from the odour abatement system has been undertaken

using atmospheric dispersion modelling techniques as detailed in the various consultant’s reports as noted in

Section 1.0.

The predicted odour exposure resulting from the odour abatement system showed that compliance with the

criterion of 1.0 OU/m3 (based on 10min avg. more than 0.5% of the time based on AERMOD Dispersion modelling)

would be achieved at all identified sensitive receptors with exhaust air from the facility travelling out of a 60m high

stack, with a discharge velocity of 30 m/s to 42.2m/s with booster fan and an emission rate of 20,000 to 30,000

OU/s.

With respect to odour concentrations, the following table outlines the odour concentrations from predicted for the

London site from 2012 and 2017 (most available source testing data).

Table 3.5: Summary of Historical Odour Data

Year

Maximum Odour

Concentration (OU) at

Sensitive Receptors

Total Hours Exceeding 1 OU

at Sensitive Receptors

Frequency of Occurrence

of Exceedances (%)

2012 0.6 0 0.00

2017 0.7 0 0.00

ODOUR GENERATION AND CONTROL MEASURES

A summary table of Odour Generation and Control Measures is found in Appendix D.

4.1 Odour Control During Normal Operations

The application of good housekeeping and process control is of fundamental importance in eliminating and

minimizing the formation and subsequent release of odours to atmosphere. The overall aim in the operation of the

London facility is to apply Best Available Techniques (BAT) at each stage of the waste treatment process. Several

control techniques have been included within the design of the facility, to ensure the most effective implementation

of BAT for this type of process. The measures employed include:

Containment of the complete aerobic composting processes in enclosed buildings.



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Maintenance of negative air pressure inside the waste receiving/processing facility.

Active extraction of air from the main waste process areas.

Extracted air treated before being emitted to atmosphere. Odorous air travels through an ammonia

scrubber, cooler, humidifier, biofilter and is discharge out of a 60m high stack

4.2 Controls on incoming waste

The potential for odour generation is inherently linked to the nature of the feedstock (type of waste, age, storage

prior to arrival on site) and how it is handled and processed once received at the site. If incoming waste is

excessively odorous on arrival at site it will increase the potential for generation of odour during handling and

processing which can challenge the efficiency of on-site odour control and abatement measures. Customer contract

conditions which restrict the composition of the SSO feedstocks are essential to ensure that incoming waste does

not compromise the ability to manage odour effectively. All loads of incoming waste are inspected by trained

personnel to determine that the waste does not contain an undue amount of contaminants, any hazardous waste,

or possess a quality that may cause undue and potentially troubling levels of odour.

Equally, inadequate or ineffective controls on storage duration and the quantity of feedstock stored on-site can

compromise the ability of the control measure to manage odour effectively.

The Operations Manager or responsible alternate has the power to reject any incoming material that may

jeopardize their ability to prevent the emission of unacceptable odours beyond the site boundary or contains an

unacceptable amount of non-organic contamination. Any rejected material will be quarantined in the receiving hall

and either returned to sender or transferred to an appropriately licensed disposal facility off-site, and notification

made to the MOECC in accordance with the Waste ECA.

London Receiving Area Door Management

Waste delivered to the site is first weighed on the weigh scale, then the delivery vehicle backs up to the overhead

door as directed by plant personnel. The overhead door will not be opened until the delivery vehicle is properly

lined up and ready to proceed. This will minimize the amount of time the overhead door is open.

The holding time of feedstock material prior to treatment is a significant factor in the site’s potential for odour

generation. The reception area has a capacity to store up to 3 days’ worth of deliveries although the facility has a

“trigger alarm” which requires senior management to be notified, and a remediation plan created, if the amount of

unprocessed material in the off-loading bay exceeds 200 tonnes. In most circumstances, all the incoming feedstock

that arrives in a day, is processed the same day.

Contractual arrangements, and Waste ECA requirements, dictate when material can be delivered to the site.

Negative Pressure in the Facility

All efforts will be made to process the incoming waste, and place it into composting tunnels, the same day the

waste is received. This will help remedy the problem of having an inventory of fresh, shredded, unprocessed waste



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sitting in storage in the waste receiving area. There are times when this may not be possible such as seasonal

inflows of large amounts of waste, late deliveries on Friday not being processed, mechanical breakdown, etc.

Therefore, the entire facility will be kept under negative pressure, to keep the potentially odorous air inside the

facility from escaping, and possibly becoming a fugitive emission. The level of negative pressure will be monitored

by pressure sensors located throughout the facility, and the readings of the sensors are shown on the SCADA

system, which allow operational personnel to know the negative pressure situation at any time.

Leachate

A pipe-work system underneath the reception bay, storage areas and the perforated floor of the aerated compost

tunnel system, is used to collect any leachate produced within these areas. The contained system is designed to

collect the leachate in a purpose-built sealed tank. The leachate can either be pumped back into the composting

tunnels or can be disposed of to a licensed disposal facility.

4.3 Controls of Out-going Waste

Out-going material from the facility, such as residual waste or finished compost/NASM, will be minimized by

ensuring that all trucks and/or trailers are loaded inside the facility. Trailers that are transporting residual waste or

compost/NASM will have tarp covers put on the trailers before they leave the facility interior.

MEASUREMENT OF ODOUR

London facility has completed source testing in 2012 to 2017 for odour from the facility. London retains outside

contractors to complete the odour testing. The results from odour testing is incorporated into air dispersion

modelling (AERMOD). The results are compared to the 1.0 OU requirements as outlined in the ECA conditions. The

report is document and copied to the MOECC.

ROUTINE MAINTENANCE AND INSPECTION

This section of the Odour OMP describes how the London facility will address the following issues to help maintain

the effectiveness of odour controls:

Plant performance;

Planned inspection and maintenance.

6.1 General

Planned maintenance and inspection is crucial to maintaining the effectiveness of odour control measures. The

London facility has implemented a planned inspection and preventative maintenance regime which is employed on

all plant-and equipment, this includes:



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A documented maintenance schedule

A record of all maintenance undertaken.

A list of critical spare parts is held on site based on the manufacturer’s recommendations.

6.2 Building Containment

To achieve overall odour containment, it is essential that the integrity of the fabric of the main process building is

continuously maintained, other than during periods of essential maintenance. The effective operation of fast acting

doors is checked daily. Any essential maintenance will be undertaken following a risk assessment of the proposed

works which will include measures to be adopted to minimize odour release during these works.

6.3 Maintenance of other plant and equipment.

A routine maintenance plan and inspection schedule for the following equipment has been developed for the

London facility and forms part of the maintenance plan for the facility:

Extraction fans;

Gas monitors and analytical devices;

Leachate collection system and tank;

Temperature sensors;

Fast-acting doors;

Separation and sorting equipment and conveyors within the refinement section

6.4 Monitoring

Routine Monitoring

The aim of routine monitoring is to inform management as to the effectiveness of the control measure.

Table 6.6.1: Routine Monitoring

Source of Odour

Generation Control measure

Monitoring

Frequency Method Limit

Waste reception,

storage and

handling.

Inspection of loads on arrival

and identification of highly

odorous wastes.

Each load Visual and olfactory

inspections.

Based on operator

experience.

Maximum quantities of waste

retained in accordance with

design.

Daily

Visual checks that all

waste is placed

within appropriate

areas.

Prescribed in the Waste

ECA

Closure of fast acting doors

except during vehicle and

personnel entry

Daily Visual inspection of

door operation. n/a



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Cleaning of spillages. As required

As per proper

housekeeping

procedures.

n/a

Composting

Tunnels & Storage

Process control to ensure

waste effectively processed

prior to discharge.

Daily

Continuous

Monitoring of

temperature,

oxygen, humidity

and pasteurization

temperature hours.

Maintenance of

processing plant.

Variables set to optimize

composting process.

Ensure regulatory limit of

excess of 55oC for at least

3 days.

Maintain downstream

processing capacity to

match waste input.

Maximum design capacity not

exceeded. Daily

Regulatory daily limit to

be set.

6.5 Regular Olfactory Monitoring

All site personnel are responsible for reporting any operational issue which has the potential to result in odour

impact beyond the site boundary immediately to the Operations Manager.

Odour inspections or “sniff-tests” are made around the site perimeter daily when operations are being conducted

and waste materials are being received on site. The findings of these inspections are recorded in the site diary. In

addition, occasional off-site inspections are undertaken at sensitive receptors as determined in response to odours

being detected on site, off site or in response to odour complaints. When necessary, the inspection frequency will

be increased particularly in the event of odours from site activities being detected at the site boundary.

Observations including time, date, weather conditions, odour type, location, and intensity are recorded. Abnormal

site operating conditions at the time of the survey are also recorded. Any potential off-site odour sources noticeable

at the time are also recorded.

The London facility monitor local weather conditions on a continuous basis using an on-site weather station.

Electronic Nose (e-nose)

The Orgaworld London facility has installed an Odotech e-nose to provide additional early detection of changes in

odour levels. The e-nose takes real time odour tests in an air stream. The e-nose was installed in the ductwork of

the air exhaust system downstream of the air treatment equipment but prior to the exhaust stack. This location

was selected for placement of the e-nose because air flow in this location best represents the quality of airflow

discharged to the environment through the stack, while providing protection from the outside environment. The e-

nose unit takes a reading every 4 minutes, 24 hours per day.

The e-nose is calibrated by collection of an odour bag sample from the exhaust airstream which is provided to a

designated odour panel to assess the extent of odours present. The instrument is then calibrated based on Site

conditions and the results of the odour bag sample allowing for the detection of concentrations of odour in air

which is provided in odour units. Incorporation of the e-nose monitoring equipment provides Orgaworld with real-

time updates on odour concentrations in the air stream. The instrument also uses dispersion modeling software



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(AERMOD) to calculate concentrations expected at a downstream receptor based on recorded odour unit

concentrations.

These tools provide Orgaworld with capabilities for early detection of odours to allow adjustments to be made to

the process control system to help prevent odour releases in real time.

6.6 Monitoring Impacts

Monitoring of impacts will be achieved by recording and monitoring complaints and reviewing the corresponding e-

nose monitoring data. Complaints may be reported directly to the site or via the Ontario Ministry of the

Environment and Climate Change.

Odour complaints will be fully investigated and recorded in accordance with procedures set out in this OMP as per

the conditions outlined in the Environmental Compliance Approval.

6.7 Record Keeping and Reporting

Daily records are maintained in the site’s production log and include the following details:

Air flow rates through the odour abatement system

Back pressure of the biofilters which may lead to replacement or refreshing of biofilter media

Temperature and humidity data

Weather station data

All monitoring data will be reviewed by site staff to ensure optimal odour abatement performance.

6.8 Actions in the Event of Abnormal Emissions

If monitoring indicates that abnormal emissions from the London facility are taking place (such as source

monitoring, alarms triggered in the control room or through monitoring of odour in the stack emissions), the Site

Management team will take the following actions:

If required, notify the MOECC of the situation, potential impacts and corrective measures planned

Undertake site walkthrough to identify any upset conditions that may have occurred with on-site plant or

machinery (for example fan failure, door failure) or spillages which may have occurred which could be a

source of odour.

Take immediate steps to eliminate the cause of the abnormal situation in accordance with the measures

outlined in Appendix E of this OMP;

Contact the relevant maintenance contractor if necessary - to obtain telephone support/advice or to

request attendance on site;

Record their response and any remedial action taken in site log and enter in the report sent to the MOECC



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6.9 Contingencies

Contingency plans have been developed to react to situations where monitoring indicates that a potential odour

source is not completely under control or that adverse impact has occurred.

This includes accidents (or incidents) which would result in the loss of control of odorous substances and have the

potential to cause an unacceptable short-term impact on the local community, but are not considered an

emergency.

These situations have been identified as:

Deviation from normal practices during routine operations;

Receipt of an odour complaint; and

Temporary maintenance works.

This section of the OMP presents a summary of the foreseeable situations that could compromise the operator’s

ability to prevent and/or minimize odorous releases from the process and the actions to be taken to minimize the

impact.

The action plan is intended to be used by operational staff on a day-to-day basis.

A tabular risk assessment (Table 6.1, Appendix E) approach has been employed in the evaluation of odour control

techniques during maintenance and abnormal events, which:

Identifies the location and conditions under which abnormal operational conditions or failures could arise;

Summarizes the potential impact or consequences of the identified abnormal / failure situation and

assesses the degree of those impacts; and

Describes how the conditions could be prevented and/or mitigated and controlled. Most abnormal

situations can be controlled in some way by effective management.

Where planned or emergency maintenance of plant or equipment is necessary and there is a likelihood of odour

being released to atmosphere in quantities sufficient to result in detection offsite, a risk assessment of the activity

will be carried out, as part of which issues of odour generation, release, and control will be considered.

COMPLAINT HANDLING AND COMMUNICATIONS

The London facility has a comprehensive system of monitoring and site inspection to check odour control measures

are functioning effectively. If an odour complaint is received, this will be logged, investigated and dealt with as a

priority as defined by the Waste ECA.

7.1 Contact details for complaints.



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Members of the public can contact the facility directly with any odour complaints by the following means:

By telephone – the site contact number is displayed on the notice board at the site entrance.

By email

Members of the public may wish to make a complaint directly to the MOECC. The preferred method of contact for

the MOECC would be via telephone.

Methods of contacting London Facility will be displayed at the site’s entrance, shown on the company website and

communicated through meetings, press releases or other form of communication regarding the operation of the

facility.

Once a complaint has been received and the details collected, the complaint must be investigated following the

Orgaworld standard procedure outlined below.

7.2 London Complaint Investigation Procedure.

Odour complaints received at the London Orgaworld facility will be investigated, recorded, and communicated as

per the requirements outlined in the Site’s ECA (Air). See Appendix A.

Whomever goes to investigate the complaint will compile the following information:

Time of complaint

Time and date of odour event

Location of odour event

Name, address and telephone number of complainant

Weather conditions at the time of the odour event

Operational conditions at the time of the odour event

Immediate actions taken, if any

It is critical to try and get to the location of the odour event as soon as the complaint is registered to determine if

the odour has indeed been generated by the facility and not some other odour source. If odour that could possibly

be attributed to the site is detected, it should be quantified (i.e. rated from 1(barely detectable) to 10(very strong))

and qualified (i.e. constant, intermittent, garbage, ammonia, etc.). This will aid in trying to locate the possible source

back at the plant.

The Operations Manager (or investigative team) will check the site for any potential sources of odour, such as

spillages or other upset conditions which may have occurred and are being rectified. Any other potential odour

sources identified in the local area will be noted. Following the site inspection, the investigation will examine the

SCADA system to determine if there was a physical cause that can be identified such as:

Fan failure

Over-pressurization of ductwork



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Page 17

Inoperative sensor, etc..

Should a complaint be received by the site long after the odour was noted, either the Operations Manager, or

designate, will investigate using records in SCADA and the historical records kept by the ‘e-nose’ odour monitoring

tracking program and weather station combination.

The findings of the investigation and whether any corrective action is to be taken will be reported to the MOECC by

the Operations Manager. All aspects of the investigation will be documented and reported as prescribed.

7.3 Further Investigation of Complaints

If the investigation concludes that the London facility could be the likely source of the odour, then further

investigation will be undertaken by the Operations Manager. Such investigations will seek to determine:

Confirmation that the London facility was the source of the odour;

The scale of the impact;

Likelihood of a recurrent event.

The Operations Manager (or investigative team) will obtain further detailed information from site records about

process conditions, observations, or operations being conducted at the time of the complaint. This will allow odour

trends to be identified and potential links with process operations or maintenance works. The Operations Manager

will discuss the findings with the company’s Senior Management Team and any effective remedial action identified

will be implemented.

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AERMOD View - Lakes Environmental Software D:\39395_CompostSite_London\2011_June\FlexibilityModels\scen05g.isc

SCALE:

0 0.05 km

1:2,203

PROJECT TITLE:

FIGURE 1SOURCE LOCATIONS, BUILDING CONFIGURATIONS AND ROOF HEIGHTS

COMMENTS: COMPANY NAME:

ORGAWORLD CANADA LTD., LONDON, ONTARIO

MODELER:

CRA

DATE:

7/4/2011

PROJECT NO.:

039395

SOURCES:

1

RECEPTORS:

2061

H=6.5m

H=6.5m

H=9.5m

H=10.5m

H=3.5m

H=4.0m

Property Boundary

CompostStack

H=4.5m

482550 482600 482650 482700 482750 482800 482850

UTM East [m]

4750

550

4750

600

4750

650

4750

700

4750

750

4750

800

UT

M N

orth

[m]

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Table 4.0: Summary of Odour Generation Sources, Variability and Control MeasuresSource Release Point Activity and Materials Involved Type of Emissions Likely Odorous Characteristics Means of Control Release Type Release Characteristics

Site Access

road and weigh

bridge

Incoming loads of residual

household wastesFugitive

Fresh waste odours. High

potential

Measures to control at source specified in

contract conditions with

suppliers/contractors

Fugitive emissions along

access road and weigh

bridge

Intermittent release,

near ground level

Opening and closing of overhead

doorsFugitive

Fresh waste odours. High

potential

Measures to minimize door opening times

specified in Operating Plan. Negative

pressure maintained in receiving building.

Holding waste in reception area FugitiveFresh waste odours. High

potential

Containment within building and abatement

by odour abatement system

Shredding of waste FugitiveFresh waste odours. High

potential

Containment within building and treatment

by odour abatement system.

Main

Processing Hall

Filling, aerating, transferring,

emptying composting tunnels

Compost process

odours, ammonia

levels

Aerobic waste decomposition

odour. Intensity reducing with

moisture reduction

Containment within the building, extraction

of air via process fans, treatment by odour

abatement system including ammonia

scrubber.

Leachate

Storage

Leachate drainage channels under

the composting floor to sealed

storage tank below floor levels in

processing building

FugitiveFresh waste odours. High

potential

Volumes of leachate evaporated on compost

tunnels when air is treated by odour

treatment system

Screening of

Composted

Material

Screening HallMechanical handling, sorting,

screening of composted wasteFugitive

Residual waste odour, small

odour potential



abatement system.

Treated air exited via the

stack


stack

Product StorageCompost

Storage HallStorage of output material Fugitive


odour potential



abatement system.


stack


stack

Product

Shipment

Compost

Storage Hall

Opening and closing of vehicle

access doorsFugitive


odour potential

Measures to minimize door opening times

specified in Operating Plan. Negative

pressure maintained in receiving building.

Fugitive emissions

Fugitive. Very minimal

due to negative pressure

in receiving hall and

treatment via odour

treatment system

Waste Delivery

and Reception

Waste

Reception area

of building

Fugitive emissions




treatment via odour

treatment system


stack

Composting

Phase




treatment via odour

treatment system

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Orgaworld Canada Ltd. London Facility: BMPP

1

Location of emissions

Circumstances of abnormal

event

Consequences of abnormal event

Measures to be in place to prevent or reduce the possibility of the abnormal event arising

Actions to be taken and responsible persons

Access road and reception areas.

Delivery of a large volume of waste over a short period.

Fugitive release of fresh waste odours From delivery vehicles queuing at site entrance.

Liaise with waste suppliers to agree delivery schedules paying attention to avoiding delivery of many trucks all at one time. Examine the use of air deodorizers for the area where waste trucks will be in line to enter the facility Recording of amount of incoming waste at the weighbridge.

Site Manager responsible for negotiating with all parties delivering waste to the site. Weighbridge to record incoming feedstock quantities. Weighbridge operator to alert control room operatives of incoming loads. Control Room operatives to visually monitor reception pit levels and advise Site Manager if capacity is becoming reduced. Consider reducing or delaying inputs to the site until the backlog is cleared.

Spillage of waste and leachate from delivery vehicle.

Uncontrolled release Of fresh waste odours from open area source.

Spillages cleaned using site plant and/or manual tools in accordance with site operating procedure. Notification of waste delivery contractor that delivery trucks may have leaks and need repair. Facility to note and document truck numbers and advise City of Surrey

Weighbridge and control room operatives to alert site operative to spillage. Site operative to undertake clean up as per procedure. Site Manager to inform customer of defective waste delivery vehicles

Accident Involving Delivery vehicle causing major spillage of waste and leachate.

Uncontrolled release of odours from open area – potential to lead to odour pollution at nearby receptors.

Response in accordance with Site Emergency Plan. Attention paid to preventing material entering stormwater sewer system.

Site Manager to initiate Site Emergency Plan response – delivery vehicle to be made safe. If driveable, remaining material discharged into receiving area or vehicle removed from site. Spilt materials removed to reception pit. Area to be cleaned.

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event




Receiving area.

Delivery of particularly malodorous load.

Fugitive release of highly odorous emissions from receiving area – potential to lead to odour pollution at nearby receptors.

Training covering the acceptability/rejection criteria for waste acceptance. Waste receiving operator will identify particularly malodorous load at site entrance and alert Site Manager. Site Manager will either:

1. Reject the load (return to supplier or send to another appropriately permitted facility)

2. Accept the load and inform operators who will isolate the load once discharged into the receiving area and prioritise it for transfer into the composting. Site Manager will record receipt of load and actions in Site Log and liaise with supplier to prevent similar loads being received in future.

Waste receiving operators trained in waste acceptance criteria for the Ottawa facility. Site Manager adequately trained and suitability experienced to determine acceptability of malodorous loads after consultation and communication with the customer

Receiving area.

Fast-acting doors malfunction and remain open.

Potential for fugitive odorous emissions from open doors – potential to lead to odour pollution at nearby receptors.

Doors can be operated by remote control from the Receiving Area or manually. Receiving area doors are normally operated via electric motors, but do have manual functioning to allow for manual closing of doors. The routine maintenance schedule includes fast-acting doors.

Ensure damaged door is rendered ‘out of service’ and all remaining doors are used instead. Manually close jammed or damaged doors as soon as practical. Report damaged or jammed doors to maintenance team for priority repair.

Personnel access doors on the main process building.

Doors/windows accidentally or deliberately left open.

Potential for fugitive odorous emissions from open doors – may cause odour to be detected at nearby sensitive Receptors.

Personnel doors fitted with suitable door closers and kept shut always when not in use. All employees trained on the need to keep all doors to the facility closed always.

Clear signage adhered to all external doors (inside and out). All site staff required to ensure doors are closed behind them.

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event




Primary shredder.

Breakdown of primary shredder.

Unable to shred incoming waste. Potential for anaerobic conditions to develop within reception pit leading to releases of malodours – potential to lead to odour pollution at nearby receptors.

Primary shredder routinely maintained in accordance with manufacturer’s recommendations. Spare parts held on site to enable basic repairs as appropriate. Arrangements will be made to obtain a rental unit if repairs will take a long time Facility designed to have 3 days of waste receiving space without processing.

The facility process downstream of primary shredder will continue to operate normally. Incoming waste will continue to be received and stored until repairs made. The Site Manager to decide whether to divert incoming waste loads to other licensed facilities until repairs can be completed. Reason for failure to be investigated and maintenance schedule revised if necessary.

Biofilter

Biofilters odour destruction efficiency reduced below 80%.

Potential to cause Odour pollution at nearby receptors.

Daily inspection of biofilter media. Routine olfactory boundary monitoring. Meteorological data recorded on site using on site by staff observation and Met Office data. Site Manager to liaise with regulators and local community. If required implement an Action Plan in consultation with the MOECC to identify corrective actions and timescales. Highly unlikely this event would affect all 4 of facility biofilters. Once suspect biofilter identified, the airflow to it can be stopped and redirected too other 3 properly operating biofilters

Site Manager to review results of daily biofilter media inspections and liaise with specialist contractors. If biofilter is suspected to be operating with reduced performance. MBT Manager to decide which of the following actions should be carried out: 1. Organize sampling and analysis to determine

the biofilters destruction efficiency and quantify the residual odours emitted to atmosphere.

2. Increase frequency of sniff-test surveys. 3. Review maintenance plan and schedule and

revise if required. 4. Liaise with MOECC if complaints anticipated.

Reason for reduced performance investigated and problem rectified. Follow – up testing undertaken.

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event




Processing hall.

Mechanical breakdown of extraction or aeration fans.

Building air extraction rates will be reduced.

Process fans draw ‘dirty’ air from within shredding area and process hall. If extraction fans failed, the dirty air would still be extracted due to redundancy of biofilter and stack fans, but at reduced rates. Routine maintenance plans and schedules for biofilter and all building process fans. Supply of spare fans and motors on site.

Site Manager to ensure the maintenance plan and schedule are being followed and findings are recorded. Depending on how many fans are malfunctioning, the Site Manager to decide whether to continue to accept and process incoming waste, or to divert loads to another facility. Indoor air quality testing to be performed on an accelerated basis to ensure safe working atmosphere inside the facility. Site Manager to ensure basic repairs are carried out as soon as practicable. Reason for breakdown to be investigated and maintenance schedule revised if required.

Screening Hall Mechanical or electrical breakdown of the screening line

May lead to a surplus of material to be screened inside the compost tunnels

Surplus spare parts for the screening line so repairs can be made in timely fashion Daily, weekly and monthly maintenance requirements to be met via the facility maintenance plans

Site manager to ensure maintenance performed on screening line as per maintenance plans. Basic repairs to be carried out as soon as practicable. Reason for breakdown to be investigated and maintenance schedule revised if required.

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event




Process building.

Ineffective operation of odour abatement plant (biofilter and ammonia scrubbers).

Potential to cause Odour pollution at nearby receptors.

Daily inspection of biofilter and ammonia scrubber in accordance with manufacturers recommendations. Testing performed continuously on biofilters and at least daily on ammonia scrubbers to ensure removal efficiency Routine olfactory boundary monitoring. Meteorological data recorded on site. Facility has a redundancy of odour abatement equipment (1 ammonia scrubber, 3 biofilters and bioscrubber) so exhaust airflow can be redirected through efficient odour removal equipment while inoperative equipment is repaired or replaced. If required implement an Action Plan in consultation with the MOECC to identify corrective actions and timeframes.

Site Manager to review results of daily inspections and liaise with manufacturers. Site Manager to seek internal advice and decide which of the following actions should be carried out:

1. Organise sampling and analysis to determine the nature of any defects. 2. Determine if exhaust airflow can be routed through working odour devices

while inoperative sections repaired. 3. Increase frequency of sniff-test surveys. 4. Review maintenance plan and schedule and

revise if required. 5. Liaise with MOECC if complaints anticipated.

Reason for reduced performance Investigated and problem rectified. Follow – up testing undertaken.

Main process buildings.

Adverse weather conditions such as extreme atmospheric, temperature inversions or extreme wind turbulence.

Poor dispersion of fugitive and point source waste odours. Damage to fast-acting doors – potential for odour pollution to occur at nearby receptors.

On site weather station will help notify facility operators as to potential odour impacts due to differing or adverse weather conditions

Site Managers to ensure meteorological forecast is reviewed daily. Should forecast indicate potential poor dispersion, Senior Operations Manager to decide whether to increase frequency of site perimeter olfactory monitoring. If odour detected, review wind direction data and conduct additional olfactory monitoring at appropriate off-site receptors. Avoid so far as is practicable any non- essential odorous activities upwind of sensitive receptors.

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event




Main process buildings.

Electrical power failure.

Unable to operate air movement fans and supply air to compost tunnels or operate gas blowers

The facility possesses a back-up generator which produces enough emergency power to operate essential functions such as emergency lighting, odour abatement equipment, essential processing functions, etc.

In the event of a power failure, all electrical power requirements will be prioritized and only essential processes or needs will be operated

Operations Manager to liaise with utility provider to determine likely length of power outage. Depending of predicted length of power outage Site Manager to decide whether to contact emergency power generator supplier. Site Manager to decide whether to divert incoming loads until power can be restored.

Site Managers to liaise with MOECC to inform them of the general situation and actions taken.

orgaworld canada ltd. london facility...(omp) for the london facility. this odour management plan...

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