Complying with State Odor Regulations at Solid Waste Management Facilities
Solid waste management facilities in the United States come in a variety of forms: Composting operations, materials recovery facilities (MRFs), construction and demolition (C&D) debris processors, sanitary landfills. But for all the diversity within the waste facility universe, they all have one thing in common: They must comply with odor and nuisance regulations set by the state.
While these regulations differ a bit from state to state, the agencies that enforce them tend to do so in response to complaints from neighbors. That is, odor violations aren’t like workplace safety regulations, in which the state will send inspectors out to the workplace to ensure compliance. Unless neighbors begin lodging complaints with the state agency in charge, waste-management facility owners generally don’t have to worry about the regulations.
This creates a situation in which it is much cheaper to avoid creating odor nuisances in the first place than it is to remove problems after the state agencies get involved. In short, the trick is to avoid complaints. The best way to do this, of course, is to comply fully with all relevant standards and rules in the first place. Here are a few things every operator of a solid waste management facility should know about odor regulations, and staying on the right side of them.
State Department of Natural Resources Solid Waste Management Rules: One Example
As we’ve stated, standards and laws regarding odor nuisances at waste management facilities differ from state to state. They also differ somewhat from facility-type to facility-type. Given this wide variance, we’re forced to choose at least one concrete example to show what sorts of language these statutes can take.
In Missouri, where Solus Group is located, the state Department of Natural Resources provides rules regarding solid waste management, which are entered into the Code of State Regulations. As an example, here are the rules the MODNR has established covering odors at sanitary landfills, which are only licensed to accept municipal waste, D&C waste, bulky items, and other solids that won’t dissolve easily in the presence of water:
10 CSR 80-3 (17) Cover (A):Requirement. Cover shall be applied to minimize fire hazards, infiltration of precipitation, odors and blowing litter; control gas venting and vectors; discourage scavenging; and provide a pleasing appearance.
10 CSR 80-3 (17) Cover (C) 1:Where a liner and leachate collection system are in place, an alternative daily cover may be approved by the department on a site-specific basis, if the owner/operator demonstrates that the alternative material controls run-on, runoff, disease vectors, fires, odors, blowing litter and scavenging without presenting a threat to human health and the environment.
Those are the only mentions of odor in the entire chapter. As you can see, the usage is rather vague, which helps to explain why it doesn’t generally come into play unless people start lodging complaints about odors coming from the nearby landfill.
Similar language appears in the Missouri Code covering demolition landfills, but the Code provides a little more guidance in the case of waste processing facilities. For these operations — which include solid waste salvagers, compost plants, incinerators, and transfer stations — the rules regarding odors turn up more often. For instance, in the following:
10 CSR 80-5.010 (3) Site Selection (B) 2:A report evaluating the effect of noise, odors, air pollutants, and potential explosions or fires upon surrounding land uses shall be submitted to the department.
10 CSR 80-5.010 (8) Aesthetics (C) 3:Immediate action is to be taken to eliminate odors, dust or excess noise from the solid waste processing facility which is creating a nuisance.
10 CSR 80-5.010 (11) Records (C) 3:[Records shall be maintained covering] vector, odor, dust and litter control efforts.
Note that these regulations don’t criminalize the presence of odors in solid waste facilities; indeed, sometimes they are unavoidable. The important thing is that operators move quickly to respond to odors that are bothering nearby residents, and that they know exactly how to eliminate these odors, or at least limit their area to unoccupied spaces. In order to accomplish this requirement, operators have to be able to trace the source of odors that are causing a nuisance.
Identifying the Causes of Odors Within Solid Waste Facilities
There are scientific tools and procedures that can help pinpoint the source of odors within waste facilities. Unfortunately, the options are essentially limitless within the walls of the operation. The presence of waste creates the possibility of strong odors. That said, here are a few common places within waste-handling facilities that tend to be problematic:
- Sorting lines and other equipment used to process waste, including conveyors, separation chambers, filters, screens, and air separators.
- Stockpiles of waste.
- Sludge pools and leachate ponds.
- Stack flare pipes.
- Any surface that comes in contact with waste.
There are plenty of tools that can help pinpoint the source of unpleasant odors, over and above the simple human nose. Chemical detection and “air fingerprinting” solutions provide an objective reading of odors. Hand-held field olfactometers can help produce this data. Once you detect the source of an odor, though, the real trick is to choose the right mitigation strategy to eliminate the problem.
How to Control Odors at Solid Waste Facilities
It may be that a measure of unpleasant odors will always be part of waste management. This doesn’t typically become a serious problem, as we note above, unless neighbors start to complain. To prevent this from happening, operators of solid waste facilities — MRFs, landfills, waste-to-energy providers, and others — must follow strict daily protocols to avoid developing a problem in the first place.
Many of these will be familiar to you. They include tasks such as:
- Change daily cover protocols to cover waste with high risk of odor bleed immediately following the dump, rather than waiting until the end of the day.
- Switch to an alternative daily cover (ADC) with more powerful odor-control characteristics. For instance, moving from dirt to biocover can often filter out some of the objectionable odors from some types of waste.
- Waste and odor travel with contact to moisture. Is waste and its cover sloped to prevent accumulation of liquid? If not, this can help cut down on detectable odors outside of the facility.
- Speeding up waste-handling processes can reduce exposure of odor-causing substances to the air, limiting uncovered time considerably. Automate waste dumping within the facility by using mobile Bin Tippers to quickly, safely disperse odor-causing load to reduce concentration.
- Improving material handling at the facility can also reduce hauling truck wait times, preventing trucks from backing up into neighborhoods and waiting in line while spreading odors among residents.
- Chemical additives, deodorants, and odor-neutralizing agents may help your operation to reduce odor generation. Generally, these solutions should only be used when absolutely necessary, given the additional costs associated with them. But always remember that they are an option.
While we’ve focused on state regulations, which can differ from place to place, many waste facility operators ask about federal odor regulations. The State of Maine’s Department of Environmental Protection points out that, while these standards would typically fall under the auspices of the federal Environmental Protection Agency, this institution doesn’t currently regulate odor-causing compounds.
“In the United States, odor is not regulated by the U.S. Environmental Protection Agency as a pollutant, since there is not a direct link between the odor perceived by individuals to the presence of a specific concentration of an odorant that may have potential health effects,” says one report from the Maine Department of Environmental Protection. “The most frequent resolution of odor complaints and problems has been through state or local nuisance laws.”
Ultimately, avoiding the pitfalls of local odor regulations will depend on an active, well-informed odor-mitigation program. Focus on prevention rather than reaction to complaint. Given the freeform nature of many states’ odor-nuisance regulations, the law is rarely concerned with how exactly you keep odors from reaching neighbors. In the absence of official complaints, solid waste facility operators can usually assume they’re complying with their state odor regulations.
“Report on Odor and Gas Management at Solid Waste Facilities.” DigitalMaine. Maine Department of Environmental Protection, 1 Jan. 2009. Web. 14 Nov. 2018.
“Rules of Department of Natural Resources, Division 80—Solid Waste Management, Chapter 3—Sanitary Landfill.” SOS.MO. Missouri Department of Natural Resources, n.d. PDF. 14 Nov. 2018.
“Rules of Department of Natural Resources, Division 80—Solid Waste Management, Chapter 4—Demolition Landfill.” SOS.MO. Missouri Department of Natural Resources, n.d. PDF. 14 Nov. 2018.
“Rules of Department of Natural Resources, Division 80—Solid Waste Management, Chapter 5—Processing Facility.” SOS.MO. Missouri Department of Natural Resources, n.d. PDF. 14 Nov. 2018.
Sullivan, Pat. “Battle of the stink.” WasteTodayMagazine. GIE Media, Inc., Sept./Oct. 2017. Web. 14 Nov. 2018.
Sullivan, Pat. “Sniffing for answers.” WasteTodayMagazine. GIE Media, INc., Nov./Dec. 2017. Web. 14 Nov. 2018.