SS38: Odors Brief Summary: This control measure would revise Air ...
SS38: Odors Brief Summary: This control measure would revise Air District Regulation 7 to reduce emissions of odorous substances and place emission limits on odor compounds. Revisions to Regulation 7 would also incorporate industry requirements to develop and identify odor management practices and control measures, and integrate odor detection technologies and evaluation methods. The rule amendment process would include reviewing the effectiveness of the current standards and consider best available technologies to reduce odors. Purpose: Reduce emissions from odorous compounds and improve enforceability of Regulation 7. Source Category: Stationary source and area source: industrial and commercial operations Regulatory Context and Background: In 1970, the Air District was directed by the State Legislature to establish standards for the emission of identifiable odorous substances. On August 2, 1972, the Air District adopted Regulation 2, Division 15 - Odorous Substances, which set emissions limits for five odorous compounds. The rule was originally intended to reduce odorous emissions from operations such as refineries, sewage treatment plants, and rendering plants. In 1976, the regulation was amended to alter the applicability to sources that generated citizen odor complaints, to establish general limitations on odorous substances to be evaluated by an odor panel, and to set limitations on total reduced sulfur (TRS) from kraft pulp mills. Later the rule was renamed Regulation 7 – Odorous Substances. Between 1976 and 1982, the Air District restructured the regulations which resulted in two substantive amendments to Regulation 7 including, removing the sampling and analysis procedures for odorous substances and including those in a Manual of Procedures, and removing kraft pulp mill requirements and creating a new regulation entitled TRS from Kraft Pulp Mills. Through the Air District’s Compliance and Enforcement Program odorous facilities are identified and those facilities are placed on a list of plants subject to Regulation 7. Since adoption of Regulation 7 in 1972, changes in the Bay Area’s population density and the closer proximity of industrial and manufacturing processes to residential areas and public spaces has resulted in significant odor impacts in certain communities. In 2015, the Air District received and responded to 4,946 odor complaints. Seventy-three percent of those odor complaints came from a single community in the Bay Area, alleging odors from solid waste and other organic waste related facilities in the area. In 2011, in response to the California Legislature’s goal of reducing solid waste going to landfills by 75 percent, CalRecycle recommended a statewide strategy to divert organic wastes from landfills. As a result, cities and counties across the Bay Area began utilizing old and new 1
technologies to divert organic wastes and to convert organic wastes to energy and reusable materials. The decomposition of organic waste, once almost exclusively occurring at landfills and sewage treatment plants, is now creating odors at diverse operations of all sizes. These process changes to existing operations and addition of new types of operations have the potential to cause significant increases and changes in odors throughout nearby communities. Strengthening the requirements and odor standards of the rule will help further reduce odor nuisances and allow the District to enforce limits on odorous compounds that negatively impact air quality in the Bay Area. Implementation Actions: The Air District will: Propose amendments to Regulation 7 to strengthen odor standards and enhance enforceability. An evaluation of newer air monitoring technologies will be aimed at increasing enforceability of the rule with respect to a wider range of odorous compounds and sources. Amending Regulation 7 will include the following emission reduction strategies and objectives: o Evaluate the complaint threshold that triggers applicability of the regulation. o Evaluate and identify source types that can attribute to odor complaints. o Identify odorous compounds that are associated to industrial and commercial operations. o Review the effectiveness of existing odor thresholds and emissions limits. o Evaluate methods of detection and monitoring practices of odorous compounds. o Amend regulatory requirements to ensure best management practices for the control of odorous emissions, such as the requirement of odor mitigation plans. Emission Reductions: N/A Emission Reduction Methodology: N/A Costs: N/A Co-Benefits: There are a wide range of chemical compounds that are odorous, some of which are toxic air contaminants (TAC), and others which are non-methane organic compounds (NMOC) that contribute to the creation of ground level ozone. Beyond reducing odor nuisances and impacts to surrounding communities, reducing odorous compounds reduces the emission of TACs and NMOCs.
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Issue/Impediments: There may be opposition from industries that have odorous sources of operations that have received a substantial number of odor complaints and are subject to the rule. Source(s): 1. California Department of Resources Recycling and Recovery (CalRecycle). August 2015. AB341 Report to the Legislature. Publication # DRRR-2015-1538.
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technologies to divert organic wastes and to convert organic wastes to energy and reusable materials. The decomposition of organic waste, once almost exclusively occurring at landfills and sewage treatment plants, is now creating odors at diverse operations of all sizes. These process changes to existing operations and addition of new types of operations have the potential to cause significant increases and changes in odors throughout nearby communities. Strengthening the requirements and odor standards of the rule will help further reduce odor nuisances and allow the District to enforce limits on odorous compounds that negatively impact air quality in the Bay Area. Implementation Actions: The Air District will: Propose amendments to Regulation 7 to strengthen odor standards and enhance enforceability. An evaluation of newer air monitoring technologies will be aimed at increasing enforceability of the rule with respect to a wider range of odorous compounds and sources. Amending Regulation 7 will include the following emission reduction strategies and objectives: o Evaluate the complaint threshold that triggers applicability of the regulation. o Evaluate and identify source types that can attribute to odor complaints. o Identify odorous compounds that are associated to industrial and commercial operations. o Review the effectiveness of existing odor thresholds and emissions limits. o Evaluate methods of detection and monitoring practices of odorous compounds. o Amend regulatory requirements to ensure best management practices for the control of odorous emissions, such as the requirement of odor mitigation plans. Emission Reductions: N/A Emission Reduction Methodology: N/A Costs: N/A Co-Benefits: There are a wide range of chemical compounds that are odorous, some of which are toxic air contaminants (TAC), and others which are non-methane organic compounds (NMOC) that contribute to the creation of ground level ozone. Beyond reducing odor nuisances and impacts to surrounding communities, reducing odorous compounds reduces the emission of TACs and NMOCs.
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Issue/Impediments: There may be opposition from industries that have odorous sources of operations that have received a substantial number of odor complaints and are subject to the rule. Source(s): 1. California Department of Resources Recycling and Recovery (CalRecycle). August 2015. AB341 Report to the Legislature. Publication # DRRR-2015-1538.
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