Odor Management Plan

							Odor Management Plan
    San Francisco, CA
                     Odor Management Plan

Table of Contents

1.0   Purpose
2.0   Odor Management Plan Coordinator
3.0   Background
4.0   Source Inventory
5.0   Control Technology
6.0   Incoming Byproduct Management
7.0   Plant Operations
8.0   Control Equipment Maintenance
9.0   Control Equipment Monitoring
10.0 Training
11.0 Regulatory
12.0 Complaint Response


List of Appendices
Appendix A         Darling Odor Complaint Form
Appendix B         Control Equipment Monitoring Form
                         Odor Management Plan

1.0   Purpose

The subject Odor Management Plan (the Plan) is required to be maintained, updated,
and made available to new employees in connection with the Darling International Inc.
(Darling) lease with the Port of San Francisco.

2.0   Odor Management Coordinator

The role of the Odor Management Coordinator (OMC) is essential to the implementation
and supervision of this plan. The OMC will act as a liaison between Darling and the
Port, local community, and the Bay Area Air Quality Management District (BAAQMD). In
addition the OMC is responsible for all recordkeeping, monitoring, and reporting
required as a part of this plan.

The designated OMC’s for the Darling San Francisco facility is the acting Plant Manager
and General Manager.

3.0   Background
Darling operates a food processing by-product recycling facility at 429 Amador Street on
Pier 92 in the Port of San Francisco. The facility also provides used cooking oil
collection and trap grease services to area food service establishments. Darling is a key
service provider to area businesses including packers, restaurants, food service
establishments, butchers, and grocers. These services play a critical role in protecting
public health, the environment, and assuring the businesses we serve remain viable.

The products produced by the recycling process include Tallow (animal fat), Yellow
Grease (used cooking oil), and Meat and Bone Meal (protein). All these products are
typically sold into the non-ruminant animal feed market. Tallow and Yellow Grease are
also used in the Oleo Chemical and Biodiesel industries.

Because of the potentially odorous nature of the byproducts we recycle Darling
operates and maintains state of the art odor abatement technology in an effort to limit
the potential for our facility to create a public nuisance.

4.0   Source Inventory


            Source Descriptions                         Control Equipment

 The unloading of byproducts into the         42,000 CFM Plant Room Air Scrubber
 recycling process.                           utilizing a chemical oxidant.
 Staging and handling of byproducts in the    42,000 CFM Plant Room Air Scrubber
 plant.                                       utilizing a chemical oxidant.
 Staging and handling of finished products   42,000 CFM Plant Room Air Scrubber
 in the plant.                               utilizing a chemical oxidant.
 Emissions from the recycling process        Air Cooled Condenser and associated
 (Cooking System).                           10,000 CFM Cyclone and associated
                                             10,000 CFM Thermal Oxidizer.
 Storage and handling of finished Tallow     42,000 CFM Plant Room Air Scrubber
 and Yellow Grease.                          utilizing a chemical oxidant.
 Storage and handling of finished Meat       Loadout building and access door
 and Bone Meal.                              management.



5.0   Control Technology



                                   Plant Room Air Scrubber – Darling utilizes a wet
                                   scrubber technology which removes odorous
                                   compounds from the plant air with a scrubbing
                                   solution containing a chemical oxidant. The
                                   scrubbing solution is recycled through the packing
                                   which causes the plant air to make intimate contact
                                   with the solution allowing the chemistry to react with
                                   the odorous compounds forming new compounds of
                                   a non-odorous nature. Fresh water and chemistry
                                   are added to the system at a defined rate to maintain
                                   removal efficiencies. See the image to the left for a
                                   simple illustration. Room air scrubbers help maintain
                                   the plant under negative pressure to prevent the
                                   release of untreated air from the facility. The
                                   scrubber operates continuously in conjunction with
                                   the recycling process. See figure on left.




Scrubber Chemistry – Darling currently utilizes scrubber chemistry with a trade name
of RADOX. This chemistry is proven to have superior reaction rates and chemical
conversion capabilities as compared to chlorine dioxide, ozone, and sodium
hypochlorite based chemistries. This chemistry also helps limit the need for scrubber
cleaning because of its ability to prevent mineral and residue build-ups in the system.

Thermal Oxidizer – Certain parts of the recycling process have the potential to
generate odorous compounds of a higher intensity. These processes include the
presses, cooker, condenser, and centrifuges. The process gases produced by this
equipment are captured and pulled by a fan to a Thermal Oxidizer (TO). See the image
above for a simple illustration. The TO uses heat to destroy the odorous compounds.
The unit operates at 1400 ºF. Darling captures the waste heat from the TO to produce
steam for the recycling process. See figurer next page.




Wastewater Chemistry – The wastewater generated by the recycling process is
potentially odorous. To address this issue Darling treats the wastewater with Sodium
Hypochlorite before it is discharged to the City sewer system.

5.0   Incoming Byproduct Management
Because of the potentially odorous nature of the byproducts Darling recycles it is
paramount to odor abatement and finished product quality that raw materials are
processed in as expeditious manner as possible. This effort is supported by the
following actions:

   a) Byproducts are unloaded within 24 hours of entering the property.

   b) Darling works closely with its byproduct suppliers to manage collection schedules
      and routes to limit outside staging as much as possible.

   c) The unloading area is kept clean and free from spillage of byproducts and any
      significant spills are cleaned up immediately.

6.0   Plant Operations
   a) The plant shall not operate unless the odor control system is functioning.

   b) The control equipment is maintained in good operating condition.
   c) The main processing plant doors, meal building doors, and meal load out building
      doors are kept closed except during actual entry or exit of trucks and/or
      personnel.

   d) Where feasible raw material trucks and trailers will be covered in transit.

7.0   Control Equipment Maintenance
   a) An inventory of critical spare parts maintained at the facility.

   b) The scrubber system is cleaned on a periodic basis.

   c) Odor abatement equipment Inspections are performed on a daily basis.

8.0   Control Equipment Monitoring

   a) Scrubber make-up and recycle water flow rates and pressure drops are checked
      daily to assure scrubber performance.

   b) The chemical feed system pumps and operating parameters for the chemical
      feed system are checked daily.

   c) Sniff tubes connected to the scrubber discharge are checked daily to assure
      scrubber performance.

   d) The thermal oxidizer is on a continuous temperature monitor with an alarm
      system to assure the proper destruction temperatures are maintained.

   e) The wastewater dosing system is checked daily to assure the pump is
      functioning and dosing is adequate.

   f) If the main processing building negative pressure cannot be maintained a review
      of the facility will be conducted to ensure the integrity and tightness of the
      containing structure. The balance of make-up air to the system will be a part of
      the review process.

9.0   Training

All plant employees are trained on the facility’s Odor Management Plan through its
computer based interactive training program. Employees are scheduled for this training
as a new hire and received an annual refresher.
10.0 Regulatory

Darling operates in full compliance a permit to operate form the Bay Area Air Quality
Management District (BAAQMD). Our operation meets the standards of performance
(Best Available Control Technology) for rendering plants which includes the use of
thermal oxidation for treating process gases.

11.0 Complaint Response
All odor complaints, confirmed or unconfirmed, are required to be brought to the
attention of the acting plant manager and general manger for the facility. Each
complaint must be investigated and a Complaint Report (see Appendix A) completed
and submitted to the Regional VP, Operations Executive VP, and Corporate
Environmental Affairs. From the reports a corrective action plan is developed as
necessary.

 •   Neighborhood Hotline Number – Darling provides a hotline number for the
     surrounding community to call if there is a concern about our facility. All calls are
     logged by time and they are directed to plant management. All calls where a return
     phone number is provided will receive a follow-up call.

                                1-888-896-0185
        Appendix A

Darling Odor Complaint Form
           Appendix B
Control Equipment Monitoring Form