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					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 Regulations
Section 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
                       Iowa/Ohio Street area complaints 2006-2007
                  50


                  45


                  40


                  35
# Of Complaints




                  30


                  25


                  20


                  15


                  10


                  5


                  0
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
Facility                              Process            Facility                                Process
Name
    Potential Odor Sources - List
        Address          Address      Equipment          Name
                                                         Boulevard
                                                         Customs             2227 Queen St.
                                                                                                 Equipment
                                                                                                 Spray booth - Auto
                                                                                                 body painting
                                                         Grand Central                           Spray Booth - Auto
Moka Joe's Coffee   2118 James St.    Roaster            Collision, Inc.        1811 Iowa        body painting
Three Sun's
Roasting                                                                                      Spray Booth - Auto
Company             2209 Queen St.    Roaster              20/20 Customs      2145 Queen St. body painting
Haskell                               Spray booth for      Olsen Auto Body                    Spray Booth - Auto
Corporation         1001 Meador Ave finishing, lacquer     & Collision       1919 Humbolt St. body painting
                                      Paint Booth - Doors, Custom Design &
Price and Visser    2207 Valencia St. cabinets             Awning (CDI)       423 Kentucky       Spray Booth
                                      Minor painting with
                                      spray cans - touch-                                        Spray Booth - Auto
Al's I-5 RV Inc      2039 Moore St.   up                  Final Finish        611 Kentucky       (touch-up bumpers)
Diehl's Collision                     Spray Booth - Spray Bellingham High                        Three-sided Spray
Center              1820 James St.    coating cars        School              2020 Cornwall      Booth
                                                         Brooks
                                      Spray Booth -      Manufacturing                           Lumber treating
Windsor Plywood     2119 Queen St.    Lacquer            Company              2120 Pacific St.   facility specializing
                                                                                               Staining, Some
                                     Spray Booth -       Pearson                               minor painting at
Tero Company        2127 Lincoln St. Lacquer             Construction        2034 Franklin St. night
                                                                                                 Another owner
Steve Hall                            Spray Booth -                                              suggested painting
Woodworking          2139 Humbolt     Lacquer            Chuck's Shop         1830 Grant St.     at
Towne Painting                        Spray Booth -                                              Mobile Repair Unit
Co.                 2116 Queen St.    Lacquer            Northwest Honda        2010 Iowa        On-Site
                                                                                                 Mobile Repair of
                                      Spray Booth -       - Veteran's                            bumpers w/spray
Greg Aanes          2109 Queen St.    Lacquer             Autobody                               guns
Bellingham                            Spray Booth - spray Pro-tent & Pro-                        Possible touch-up
Collision Repair     2034 Moore St.   coating cars        deal                1400 Kentucky      painting
Potential Odor Sources Identified
  NWCAA’S Actions
2003
 • 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
    Brooks Manufacturing - 2008

•    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
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)

info@nwcleanair.org

www.nwcleanair.org

				
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