Field Copy. Sampling Plan. Odor Assessment Program. Event 1 (1 of 6) Washington County Solid Waste & Recycling. Nature s Needs Composting Site

Transcription

1 Washington County Solid Waste & Recycling Nature s Needs Composting Site Odor Assessment Program Sampling Plan Event 1 (1 of 6) Field Copy Revision 2 March 7, 2013 Prepared by Thomas R. Card Environmental Management Consulting th Way SE, Enumclaw, WA USA Fax: trcard@earthlink.net Charles E. Schmidt, PhD Live Oak Road, Red Bluff, CA Fax: Chuck McGinley St. Croix Sensory, Inc Stillwater Blvd. N., Stillwater, MN cmcginley@fivesenses.com

2 Table of Contents 1. INTRODUCTION... 1 BACKGROUND AND OBJECTIVES... 1 SCOPE OVERVIEW... 1 LOCATIONS ASSESSMENT OF PREVIOUS DATA... 4 SITE HISTORY... 4 Food Waste Demonstration Project and Complaint History Complaints and Odor Monitoring Board Actions... 5 NEIGHBORHOOD OBSERVATIONS AND COMPLAINTS... 5 RECOLOGY SELF-MONITORING AMBIENT SAMPLING PROGRAM... 5 NASAL RANGER TRAINING... 5 AMBIENT MONITORING BACKGROUND INFORMATION... 6 Historical Observed Odor Patterns... 6 Locations of Possible Other Odor Sources... 6 Critical Locations... 8 ODOR OBSERVATION HOTLINE AMBIENT SAMPLING METHODOLOGY ON-SITE SAMPLING PROGRAM PLANT DESCRIPTION SAMPLING LOCATIONS SAMPLING METHODS NASAL RANGER FIELD SCENTOMETER SAMPLING (OFF-SITE) FLUX CHAMBER SAMPLING (ON-SITE) TEDLAR BAG SAMPLING SUMMA CANISTER SAMPLING PROCESS DATA COLLECTION SAMPLE HANDLING FIELD QC CRITERIA SHIPPING ANALYTICAL METHODS OLFACTOMETRY (EN 13725) FIXED GASES BY ASTM D DATA ANALYSIS AND REPORTING DATA VALIDATION REPORT PROJECT IMPLEMENTATION SCHEDULE PROJECT SCHEDULE LABORATORY SHIPPING ADDRESSES Olfactometry Laboratory Fixed Gas Laboratory... 21

3 REQUIRED SITE ASSISTANCE SITE SAFETY AND HEALTH PROJECT EQUIPMENT Figures Figure 1.1 Nature s Needs Location Map. Figure 1.2 North Plains Detail Map Figure Possible Other Odor Sources Near Nature s Needs. Figure Specific Ambient Sampling Locations of Concern (Large View). Figure Specific Ambient Sampling Locations of Concern (Small View). Figure Site Aerial Photo Figure 4.2 Site Plan Figure 5.1. Example Chain of Custody Form. Figure 8.1 Shipping Locations Tables Table 4.1 Sampling Locations Table Summary of Field Quality Control Information Acronyms Used ASTM EAS EN EPA LPM MDL PPBV QA QA/QC USEPA American Society for Testing and Materials Environmental Analytical Services European Norm Environmental Protection Agency Liters per Minute Method Detection Limit Parts per Billion by Volume Quality Assurance Quality Control/Quality Assurance United States Environmental Protection Agency

4 1. Introduction Background and Objectives Recology Oregon Compost, Inc. (Recology), is the operator of the the Nature s Needs compost facility located directly southeast of the City of North Plains in unincorporated Washington County, Oregon (see Figures 1.1 and 1.2). The facility has received complaints regarding offensive odors traveling off-site. Recology has continuously made improvements to better manage odor emissions. The goal of this project is to assess the odor generation and off-site odor impacts of the Nature s Needs compost facility following a set of operational changes related to the franchise agreement for the facility between Recology and Washington County. Scope Overview This project will include a total six sampling events, two sampling events will have simultaneous on-site source assessment and off-site ambient monitoring of odors originating from the facility. The remaining events will include off-site monitoring only. The first off-site sampling event described in this plan, Event 1, will be the most comprehensive sampling event. A second on-site sampling will follow in or around June 2013 following the change to a residential only Type 3 feedstock. The following sampling events will also have sampling plans. This first event will include sampling 24 identified process locations at the Nature s Needs site using the USEPA Surface Isolation Emission Flux Chamber. Simultaneous to the on-site measurements, off-site ambient sampling will be conducted using the Nasal Ranger field scentometer. This sampling plan also discusses the procedures for gathering, validating, and summarizing previous data generated by both the public and Recology staff. Sampling Event 1 has the following critical dates: 3/11/2013 Public Meeting 6:30 PM at Jesse Mays Community Center 3/12/2013 Nasal Ranger Training at Washington County Offices 3/13/2013 Ambient and On-site Sampling 3/14/2013 Ambient and On-site Sampling Locations The Nature s Needs Composting Facility is located at 9570 NW 307th Ave. North Plains, OR Ambient Odor Sampling will take place in the vicinity of North Plains, OR at locations submitted by the City of North Plains and Washington County The public meeting on Monday, March 11, will be held at Jesse Mays Community Center, NW Hillcrest St., North Plains. Nasal Ranger training will take place at the offices of Washington County in Room 105 at 155 N. First Ave., Hillsboro, OR

5 Figure 1.1 Nature s Needs Location Map. Nature s Needs Composting Facility

6 Figure 1.2 North Plains Detail Map Nature s Needs Composting Facility

7 2. Assessment of Previous Data Site History Recology Oregon Compost, Inc. (Recology), holds a disposal site franchise issued in 2009 by Washington County for the Nature s Needs Compost Facility (Nature s Needs). The compost facility just North of U.S. 26 and East of the City of North Plains. Prior to 2009 the facility was under different management. In addition to the acceptance of yard debris, Nature s Needs had been conducting a commercial food waste composting demonstration project (demonstration project) since July Washington County initially allowed food waste to be accepted at the facility as a demonstration project through December 31, Food Waste Demonstration Project and Complaint History In December 2011, the Washington County Board of Commissioners (Board) received public testimony on whether the demonstration project at Nature s Needs should be extended or made a permanent part of the franchise agreement. Testimony from 11 citizens cited offensive off-site odor in the area of North Plains and requested that the Board extend the demonstration project rather than take the Solid Waste Advisory Committee and staff s recommendation to approve it as a permanent provision of the franchise agreement. The Board did not take staff s recommendation and further extended the demonstration project to the end of December Complaints and Odor Monitoring In October and December 2012, as the deadline for a decision about the demonstration project neared, the Board again received citizen testimony. In October 2012 the County received a citizen petition signed by approximately 425 individuals, and 35 letters from the North Plains business community; all were in opposition to the facility citing odor issues and requested that the facility be prevented from accepting food waste. In December 2012, 18 citizens testified that Nature s Needs should not be allowed to continue its demonstration project due to off-site odor concerns. In addition to the letters of opposition submitted to the Board, 100+ letters of support were delivered to the County in January Adding to the opposition noted above, in calendar year 2012 (January through December), Washington County received approximately 1,250 odor complaints. These complaints were submitted from approximately 300 individual households and or businesses. In addition to responding to complaints, in calendar year 2012, Washington County Code Enforcement staff made 38 visits to the Nature s Needs facility and surrounding area as part of its regular field monitoring of the facility. On-site and off-site odor was detected, though malodor was found in only one instance, resulting in a notice of non-compliance issued in February Number of Odor notations made during off-site inspections: 18 Odor notations made during on-site inspections: 20 In March/April 2012, odor monitoring of the area in and around North Plains was conducted by a group consisting of non-county staff, non-solid waste program staff and County Solid Waste and Recycling Program staff. There were 95 individual reports filed. Off-site compost odor was reported on five (5) occasions. 4

8 2013 Board Actions As the December 31, 2012 extension of the demonstration project neared its end, the Board extended the expiration date by one additional month in order to provide Recology more time to develop a plan for moving forward. At a public hearing on January 22, 2013, the Board received testimony from 43 individuals; approximately 75 percent were in opposition (31 individuals testifying in opposition and 12 individuals testifying in support) to the facility citing offensive odor concerns. The Board voted unanimously to terminate the demonstration project and modify the franchise agreement with Nature s Needs with new, more restrictive terms and conditions, including third-party odor monitoring, prohibition of commercial food waste as of April 1, 2013 and the flexibility to move odor causing activities to nighttime operations. Termination of the demonstration project authorized the acceptance of Type 3 feedstock, originating from residential sources only, through the term of the franchise, July of Additionally, the new franchise agreement has a condition that if at any point through July 2015, the Board finds that the more restrictive terms and conditions are not being met, or it finds the odors created by the facility to be unacceptable as determined by the Board it may terminate the acceptance of all incoming Type 3 feedstock, from residential and commercial sources. Neighborhood Observations and Complaints Odor complaints from Calendar year 2012 and 2013 through February 8 have been provided and are in the process of review. In addition, public testimony from the 12/18/1012 and 1/22/2013 Washington County Board meetings has been provided and is in the process of review. Recology Self-monitoring The Recology self monitoring data and complaint log has been received and is currently under review. 3. Ambient Sampling Program The first ambient sampling program will occur on Wednesday and Thursday, March 13 and 14, It will be preceded by a one day Nasal Ranger training session held on Tuesday, March 12, 2013 at the Washington County offices in Hillsboro. Nasal Ranger Training Nasal Ranger training, for up to 11 participants will be held between 8:00 AM and 12:00 PM on Tuesday, March 12, 2013 at the Washington County offices in Hillsboro. There will be field practice between 1:00 PM and 3:00 PM in North Plains. Participants in the field practice will rendezvous at the North Plains City Hall at 1:00 PM. 5

9 The following are the anticipated attendees for the training session: Washington County Theresa Koppang Thomas Egleston Andre Bjornskov Kelee Hirn-Sheppard Recology Oregon Compost, Inc. Leandra Garner Alex Hutton-Tine Jessica Campuzano Lesli Lanzar City of North Plains Martha DeBry Sara Baker Oregon Department of Environmental Quality & Metro Stephanie Rawson, Audrey O Brien Will Ennis Ambient Monitoring Background Information Historical Observed Odor Patterns Time of Day Based on complaints, there does not appear to be any distinct pattern as to when the odors are most prevalent. Many of the odor complaints received are lodged in the morning commute (6:30AM to 9:30 AM) and evening commute (5:00 PM to 7:00 PM) hours. The City Manager of North Plains has indicated that the odors appear to be more prevalent during the afternoon. This would seem logical as Recology has reported that most site activity occurs during the afternoon. Time of Week Odor complaints do not appear to have a relation to the time of week. Complaints are received on any given day. Staff has made observations that odor appears to be somewhat more prevalent on Fridays. This could be the case of facility operators moving more material and turning more compost rows as they prepare to button-up the facility for the weekend. Season There has not appeared to be a correlation with the season and the odor levels. There is a strong perception that the hot summer months will be worse, however complaint volumes do not necessarily support that. The winter months are when the area experiences air inversions, and there are increased odor complaints during strong air inversion events. Locations of Possible Other Odor Sources Figure 2.1 presents a list and the locations of other possible odor sources in the area. 6

10 Figure 2.1 Possible Other Odor Sources Near Nature s Needs.

11 Critical Locations The City of North Plains has provided the following 10 locations as important sites for monitoring, in priority from highest to lowest. 1. The Sunshine Market, 9950 NW Glencoe Rd, North Plains, OR Corner Bistro, NW Glencoe Rd, North Plains, OR St. Edwards Church, NW 313th Ave, North Plains, OR Pacific Tile and Stone, NW West Union Rd, North Plains, OR McKay Creek Subdivision, NW McKay Creek Court, North Plains, OR North Plains Elementary School, NW North Ave, North Plains, OR Intersection of Beach Road and Glencoe Road, Hillsboro, OR North Plains Senior Center, NW Commercial St, North Plains, OR Highland Court Subdivision, NW Highland Court, North Plains, OR Intersection of Commercial Street and 321st Avenue, North Plains, OR In addition to these locations, Washington County staff has identified the following 10 locations as important sites for monitoring. 1. Intersection of NW Gordon Road and NW Commercial Street, North Plains, OR Intersection of NW Hillcrest Street and NW 318th Avenue, North Plains, OR Intersection of NW Glencoe Road and NW Commercial Street, North Plains, OR Terminus of NW Kaybern Street, North Plains, OR Mile Post 58 on U.S. Highway 26, Westbound 6. Intersection of NW Jackson School Road and NW Meek Road, Hillsboro, OR Intersection of NW Jackson Quarry Road and NW Helvetia Road, Hillsboro, OR Intersection of NW Pacific Street and NW Main Street, North Plains, OR Intersection of NW Gordon Road and NW North Avenue, North Plains, OR Intersection of NW Glencoe Road and NW Scotch Church Road, Hillsboro, OR These locations are provided in Figures 2.2 and 2.3. In the figures the North Plains locations are prefixed by NP and the Washington County locations by WC. 8

12 Figure 2.2 Specific Ambient Sampling Locations of Concern (Large View). See Detail Map for These Locations NP4 Pacific Tile and Stone WC7 Jackson Q & Helvetia WC5 Hwy 26 MP 58 NP7 Beach Rd & Glencoe WC10 Glencoe & Scotch Ch. WC6 Jackson & Meek Note: Locations provided by North Plains are prefixed by NP and locations provided by Washington County are prefixed by WC

13 Figure 2.3 Specific Ambient Sampling Locations of Concern (Small View). WC9 Gordon & North NP6 North Plains Elementary NP3 St. Edwards Church NP8 Senior Center NP5 McKay Creek SD WC2 Hillcrest & 218th WC1 Gordon & Commercial NP4 Pacific Tile & Stone WC3 Glencoe & Commercial NP10 Commercial & 321st WC4 Kaybern WC8 Pacific & Main NP9 Highland Court SD NP2 Corner Bistro NP1 Sunshine Market NP7 Beach Rd & Glencoe Note: Locations provided by North Plains are prefixed by NP and locations provided by Washington County are prefixed by WC

14 Odor Observation Hotline The public can report observed off-site odor from the compost facility during the sampling event using the Odor Observation Phone Hotline and/or the at Note that this address is specific to the sampling project and different than the current odor complaint process established through the City of North Plains.. The above is the preferred communication channel, however, texts and phone calls are welcome to the third-party odor monitoring The following information must be provided: 1. Name. 2. Location. 3. Time of observation. 4. Brief description of odor. 5. Brief description of wind direction and speed if known (estimates are fine). 6. Contact info for follow-up questions (note when the best time for follow up contact is). This may be helpful for follow-up questions that may occur immediately after the message is received. Note: This is not a complaint line, or a replacement for the normal governmental communication channels. This is to help the third-party ambient sampling team be aware if odors are being observed. Ambient Sampling Methodology This first scheduled ambient sampling program will occur on Wednesday and Thursday, March 12 and 13, 2013, concurrent with the on-site measurement program. The purpose of this Ambient Odor Monitoring is to measure the presence, if any, of odors in the community that may be perceived as nuisance odors by residents, businesses or others. The designated inspector(s) will observe the ambient air at the monitoring locations to determine if odor is present. If odor is not present the inspector will note and record the absence of odor on the Field Data Sheet. Because meteorology varies through a 24-hour day, the inspector will conduct multiple observations at each location throughout the monitoring period. Variations in meteorology will be considered when selecting the observation times. However, monitoring is planned only during daylight hours. The inspector will record weather conditions and all odor and non-odor measurements on the Field Data Sheet utilizing the olfactory senses and a field olfactometer. Any other noteworthy activities and other observations, including noise, dust, mist, etc. will also be noted and recorded on the Field Data Sheet and on supplemental pages as needed. The inspector(s) will attempt to make the following findings: 1. The presence or absence of an odor at a specific Monitoring Location. 2. The D/T setting where odor is first observed on the Field Olfactometer. 3. The selection of Odor Descriptors that characterize the observed odor. 4. The description of the weather conditions. 5. The investigation and opinion of the probable sources and causes of observed odor. 6. The scheduling of the monitoring. 7. The addition, substitution, and deletion of odor monitoring locations. 11

15 4. On-Site Sampling Program Plant Description The Nature s Needs composting facility currently takes a mixture of green-waste, including yard debris, and food waste from both residential and commercial sources and produces finished compost. An aerial photo (Summer 2012) is shown in Figure 4.1. Feedstock is received and immediately blended to achieve desired porosity and carbon/nitrogen ratio. The blended mix is then placed into a Phase I aerated static pile (ASP). The facility has a three phase process. Phase I is an aerated static pile with a 15 day retention time. The aeration air has odor control provided by a wood chip biofilter. After 15 days, the Phase I pile is broken down and rebuilt across the center lane in to a Phase II pile, which lasts for 15 days. Phase II is aerated similar to Phase I, but at a lower rate. Both Phase I and Phase II are covered during operation with a Compostex cover. After Phase II, the material is cured in windrows for 30 days. The windrows are periodically mixed with a row turning device. In Phase I and Phase II the air rate is controlled by a temperature set point. Product is stored for up to six months on site. Storm water runoff is collected in a tank and an aerated pond. Well water is used for dust control. Water for moisture management of the compost comes from a variety of sources. Figure 4.2 provides site details and process dimensions. Sampling Locations Table 4.1 provides a list of the pre-selected sampling locations. Provisions will be made to take up to four additional samples if possible odor sources are identified during the sampling event. All sample locations will have samples analyzed for Odor Thresholds per EN13725 and helium/methane/carbon dioxide by ASTM D Since this is a covered, negative air aerated static pile facility, most of the air emissions are anticipated to occur during material handling and mixing. Therefore, many samples are planned to be taken immediately after placement. The emissions rate from this will allow for the emissions estimate during the transfer operations. In addition, emissions from the covered ASPs will be measured during key process days in order to develop an emissions curve for the duration of the compost cycle. Mixing events for the windrows will be quantified by taking measurements immediately after, and as long as four hours after a mixing event. Ten (10) sample locations are planned for the first sampling day and fourteen (14) sampling locations are planned for the second sampling day. The goal of the first sampling day is to take all the samples that require site coordination. The biofilters, that have advection flow, will have the flow rate determined by using a helium traced sweep gas and the analyzing for the helium concentration in the flux chamber air. This methodology is documented in South Coast Air Quality Management District Rule The pond will be sampled by extracting several buckets of pond water into a plastic lined tub, with the flux chamber suspended over the tub. The tub will be agitated to simulate the surface aerators. The sampling team will measure the process dimensions during the sampling event to compute total site emissions. Each day a replicate and blank sample will be taken for QA/QC. 12

16 Figure 4.1 Site Aerial Photo Aerated Storage Ponds Phase III Phase I Phase II Leachate Treatment Tank Product Receiving Product Phase III Wood Grinding 13

17 Figure 4.2 Site Plan W N S E Phase I Negative Air ASP 75' x 28' each?? m2 each 15 Process Days Phase II Negative Air ASP 75' x 28' each?? m2 each 15 Process Days Phase III (Cure) W indrows North 125' x 22' each?? m2 each 30 Process Days A B Aerated Storage Ponds 350' x 92' 3,000 m2 3 Surface Aerators Leachate Treatment Tank 30' dia 66 m2 Phase I Biofilter 480' x 20'?? m2 C Product Stockpiles?? m2 each Phase II Biofilters A: 80' x 20',?? m2 B: 120' x 20',?? m2 C: 100' x 20',?? m2 Receiving Area Office Entrance W ood Grinding Phase III (Cure) W indrows South 170' x 20' each?? m2 each 30 Process Days 1" = 200' 0 ft 200 ft 14

18 Table 4.1 Sampling Locations Odor Helium/GHG Location Day 1 Day 2 Day 1 Day 2 Phase I Uncovered Just Built ASP 1 1 Phase I Covered Just Built ASP 1 1 Phase I Day 1 Biofilter 1 1 Phase I Day 3 ASP 1 1 Phase I Day 3 Biofilter 1 1 Phase I Day 15 Covered 1 1 Phase I Day 15 Biofilter 1 1 Phase II Uncovered Just Built ASP 1 1 Phase II Covered Just Built ASP 1 1 Phase II Day 16 Biofilter 1 1 Phase II Day 18 ASP 1 1 Phase II Day 18 Biofilter 1 1 Phase II Day 30 Covered 1 1 Phase II Day 30 Biofilter 1 1 Phase III Just Built Windrow 1 1 Phase III Day 33 Pre Mix 1 1 Phase III Day 33 Post Mix Immediate 1 1 Phase III Day 33 Post Mix 2-4 hr 1 1 Phase III Day 60 Windrow 1 1 Product Immediately after Screening 1 1 Product 24 hours Post Screening 1 1 Storage Pond 1 1 Leachate Treatment Tank 1 1 Representative Wetted Roadway 1 1 Rep Rep Blank Blank Total

19 5. Sampling Methods Nasal Ranger Field Scentometer Sampling (Off-site) The use of the Nasal Ranger will be limited to trained and certified operators. It will be used in compliance with manufacturers requirements and recommendations. Flux Chamber Sampling (On-site) The surface emission isolation flux chamber (flux chamber) can be used on any liquid surface and on solid surfaces. The only requirement regarding application is that there must be access to the surface for testing. If the surface cannot support the chamber, the chamber must be suspended or equipped with a flotation devise or suspended from over-head. Photo 3.1 USEPA Flux Chamber with Sampling Equipment. For sampling natural or uncontrolled systems the most critical issue regarding application is that the location and number of locations for testing be sufficient so that these data can be used to calculate the total emissions from the emitting surface area. The User's Guide (US EPA, "Measurement of Gaseous Emission Rates from Land Surfaces Using an Emission Isolation Flux Chamber- User's Guide," EPA 600/ (NTIS PB ), February 1986) provides guidance that relies on the area involved and the homogeneity of the source; or the coefficient of variation of these emission data for determining representative testing. For sampling engineered systems (process tankage) the representative surface areas are selected based on the level of process knowledge of the engineered system. Given that the soil/gravel/liquid surface tested is relatively uniform, it is anticipated that the measurements will be representative of the air emissions from the site. The operation of the flux chamber involves: 1. identifying the test area; 2. initiating sweep gas flow rate to the flux chamber; 3. operating the chamber for at least four residence times; 4. collecting exhaust gas for analysis and/or recording instrument response; 5. decontaminating the chamber; and 6. relocating the measurement equipment to the next test area. The specific operating protocol for is given below. 1. Locate the flux chamber, sweep gas, sample collection equipment, and field documents at the test location. 2. Document site information, location information, equipment information, name of sampler, date, and time on the Field Data Sheet. 16

20 3. Select the exact test location and place the chamber on the surface to be sampled. The chamber should be sealed, when possible, along the base preventing air infiltration. Place thermocouples to monitor soil/air temperature inside and outside of the chamber. Temperature data are used to show that the emission event was not disturbed during the measurement or to correlate emission rate to temperature. 4. Initiate the sweep gas flow rate and set the rotometer at 5.0 liters per minute. Constant sweep gas flow rate is critical. Record time. 5. Collect instrument background data (gas analyzers, thermocouples) and record data. 6. Connect the purge pump. A total of 5.0 liters per minute is added to the chamber and the gas not sampled is exhausted out the pressure equalization port in the top of the chamber. The chamber is operated at near atmospheric pressure. Do not exceed an exhaust gas sample/purge rate of 2.5 liters per minute. This will prevent entraining of ambient air into the chamber and maintain an exhaust rate of at least 2.5 liters per minute out of the pressure equalization port. 7. Operate the chamber sweep air flow rate at 5.0 liters per minute and record data every residence time (6 minutes) for four to five residence times or 24 to 30 minutes. Record data. The chamber is at steady-state. 8. Interface the bag sampler/ Tedlar bag, canister, solid sorbent media to the purged sample line and collect the gas sample. Do not exceed a collection rate of 2.5 liters per minute at any time. This will prevent unwanted dilution of chamber exhaust gas by ambient air. 9. Label sample bag, record sample collection or real-time monitoring data on the data sheet. 10. Store the sample(s) in the appropriate storage and/or shipping container. 11. Document sample collection in field master log book. 12. Discontinue the flux measurement, shut off the sweep air, remove chamber and secure equipment. 13. Decontaminate the chamber where contact was made with the soil using a clean paper towel and water (if needed) to remove any soil and condensation from the inside of the chamber. Purge the sample lines with sweep gas (5 lpm) for 2 minutes. 14. Relocate equipment to the next test location and follow steps 1) through 14). Tedlar Bag Sampling Grab samples using Tedlar bags will be collected from ambient air and the exhaust line of the flux chamber at steady-state conditions for speciation by gas chromatography or odor analysis. Sampling rate will be maintained at less than 2.5 lpm from the flux chamber. Tedlar bags will collected by interfacing the sampler to stack ports or the sampling port on the flux chamber using the 1/4" Swagelock fittings, drawing a vacuum on the decompression lung sampler and filling the bag collecting a 1-to- 10 liter sample. All sample bags will be pre-conditioned by partially filling, then expelling, the bag contents with the sample prior to taking the final sample. Summa Canister Sampling Grab samples using Summa Canisters will be collected from the exhaust line of the flux chamber at steady-state conditions for fixed gas analysis. Sampling rate will be maintained at less than 2.5 lpm from the flux chamber. Summa Canisters will be collected by interfacing the sampler to stack ports or the sampling port on the flux chamber using the 1/4" Swage-lock fittings, opening the canister valve slowly, and collecting a 1-to-10 liter sample. 17

21 Process Data Collection The following summarizes the process data requirements for the sampling: 1. ASP process temperatures. Sample Handling Chain of Custody- All sampling media will be recorded using a chain of custody sheet as shown in Figure 5.1. A copy of the chain of custody will be kept with the field samplers, and a copy will be shipped to the lab along with the samples. The lab will review the chain of custody, make any necessary annotations, and return a copy of the chain of custody with the reporting of the lab results. Field QC Criteria The field QC activities scheduled for the field testing are summarized in Table 5.1. Deviation in schedule or frequency in QC activities will require corrective action including documentation of corrective action in the field notebook and notifying EMC of the deviation and corrective action. Table Summary of Field Quality Control Information Sampling Method Activity Frequency Criteria Comment Flux Chamber Rotometer Single- Once per year Define Rotometer None Point Calib. Setting Field Blank All media 5% None Use As Baseline Data Media Blank Sample All Media 5% +50% RPD Qualify Exceedences Replicate Sample All media 5% +50% RPD Qualify Exceedences Shipping Samples will be packaged according to media preservation and shipping instructions (per method); all samples will be shipped using commercial shippers allowing for sample hold times to be met by the laboratories. Odor samples will be shipped overnight for next day delivery and analysis, and canister samples will be shipped standard two or three day delivery. Shipping receipts will be retained by the field crew. 18

22 EN13725 Det. Threshold EN13725 Rec. Threshold ASTM E-544 Intensity Char/Hedonic Tone Figure 5.1. Example Chain of Custody Form. Environmental Management Consulting Chain of Custody Record Form Serial Number For Information Regarding These Samples # Client Address and Phone Number Laboratory Name EMC F Please Contact: O St. Croix Sensory Client Name F Tom Card Analysis Requested Laboratory Address Environmental Management Consulting C 1150 Stillwater Blvd. N. Project Manager th Way SE O Stillwater, M N Enumclaw, WA N Laboratory Phone T Requested Completion Date trcard@earthlink.net A I Laboratory Contact C G N Donna McGinley O R E Sample Station M A R Container Number Date Time P B Sample ID Number S Bag Can Tube Remarks Odor Sampler Date/Time Relinquished by Date/Time HAZWRAP/NEESA Y N QC Level Recieved by Date/Time Relinquished by Date/Time COC Ice Ana Req Temp AM B Recieved by Date/Time Relinquished by Date/Time Cust Seal ph Sample Condition Recieved by Laboratory Date/Time Sample Shipped Via Air Bill No. UPS FEDEX BUS Hand Other Remarks

23 6. Analytical Methods Olfactometry (EN 13725) Odor samples will be analyzed using an olfactory panel and butanol calibration. Gas samples are collected in purged Tedlar bags using a decompression device where gas is collected by filling a bag without passing the sample through a pump. Tedlar bag samples are collected, stored in light-shielded cardboard containers, and shipped to the lab via overnight express mail for analysis within 24-hours. The odor samples are diluted to below olfactory detection limits and then introduced to a gas delivery system. A panel of eight members trained in odor response serves as the odor "detector". Panel members are asked to smell air samples delivered to one of three nose cones (the other nose cones have clean air), one of which has the diluted sample. The concentrations of sample are increased until one-half of the odor panel members can detect the odor. The odor measurement is concluded when detection by four of the eight panel members is recorded. The odor concentration is expressed as the number of dilutions that were required for one-half of the panel members to record detection: dilutionto-threshold (D/T) level. Typical method quality control includes field blank samples and duplicate analysis. Odor concentrations can be used to evaluate odor strengths, ambient odor, or in modeling exercises to estimate a downwind odor strength. Fixed Gases by ASTM D-1945 Fixed gases including methane and carbon dioxide, along with helium, which is used as a trace gas in order to determine advective flow from various sources tested, will be analyzed by GC-thermal conductivity detection (GC/TCD). The sample will be taken from a Summa polished stainless steel canister. The detection limit for GC/TCD is about 0.008% for helium and in the low or sub-ppmv for the other fixed gases. (note- trace gas added at 10% of the sweep air into the chamber). 7. Data Analysis and Reporting Data Validation All field and sample data will be reviewed and challenged against the method QC specifications. Data not meeting method specifications will be flagged appropriately. Report The data will be presented in a report that provides a description of the sampling effort and tabular emission rates for each process. All field notes, chain of custody forms, and laboratory reports will be included in the report. 20

24 8. Project Implementation Schedule The project will be executed on the schedule given below. The project team will arrive the morning of testing at All equipment and field supplies will be inventoried and pre-testing calibrations will be performed that day. There will be a safety briefing between at It is anticipated that all testing will be completed within two days. All field progress will be recorded in a project log book and all chain-ofcustody will be completed on the day of sample collection. All shipping records will be retained as part of the field data set and the person shipping samples is responsible for contacting the laboratory prior to sample receipt. Project Schedule Draft Sampling Plan 3/1/2013 Final Draft Sampling Plan Within Five (5) Days of Receipt of Comments Nasal Ranger Training 3/12/2013 Field Sampling 3/13/2013 3/14/2013 Draft Report Ten (10) Working Days After Receipt of Lab Data Final Report Within 10 Days of Receipt of Comments Laboratory Shipping Addresses Olfactometry Laboratory St. Croix Sensory, Inc Stillwater Blvd. N. Stillwater, MN Contact: Donna McGinley x11 Fixed Gas Laboratory Environmental Analytical Services 173 Cross Street San Luis Obispo, CA Contact: Dr. Steve Hoyt (805)

25 Figure 8.1 Shipping Locations

26 Required Site Assistance The following assistance is anticipated to be provided. Washington County 1. Permission, along with notification and access requirements, to access private adjacent land to the Nature s Needs site. [Completed as of March ] Nature s Needs 1. Weather data from site weather station logged at 5 minute intervals during entire sampling event. 2. A diagram showing the ages of all the piles/windrows on site as of Monday, March Provide Chuck McGinley a site tour and the opportunity to audit the Recology self-monitoring program at , Tuesday, March Operations Schedule for Wednesday, March 13. a. Build Phase III windrow on Monday, March 11 on North Pad b. Have the site open for our access at 0700 Wednesday, March 13. c. Build another Phase III windrow next to the above at 0730 Wednesday, March 13. d. Mix March 11 Windrow at 0830, Wednesday, March 13. e. Transfer ASP from Phase I to Phase II at 0930 Wednesday, March 13. f. Assumption that a Phase I ASP will be in the process of being built all day. g. Screen a finished windrow at 1330, March 13. h. Place cover on Phase I ASP No special operating schedule will be required for Thursday, March A public/media viewing opportunity has been scheduled for Thursday, March 14, between 11:00 AM and 1:00 PM. 7. Provide process temperature data for the operating ASPs to assure that the sampled ASPs are representative of normal operations. Table 8.1 below shows the detailed site operation requirements for the sampling event. 23

27 Table 8.1 Detailed Site Assistance Requirements Schedule (On-site Sampling Activity Duration Highlighted). Time Monday, March 11, 2013 Tuesday, March 12, 2013 Wednesday, March 13, 2013 Thursday, March 14, :00 7:30 Build Phase III Windrow 8:00 8:30 Mix 2 Day Old Windrow 9:00 9:30 Build Phase II ASP 10:00 10:30 11:00 11:30 12:00 12:30 13:00 Build Phase III Windrow (any time during day) 13:30 Screen finished windrow 14:00 Place Cover on Phase I ASP 14:30 15:00 15:30 16:00 16:30 17:00 17:30 18:00 18:30 Public Meeting Chuck McGinley Site Tour/ Self Monitoring Plan Audit Site Safety and Health All on site personnel are required to have high visibility attire or vest. Project Equipment The list of field equipment and expendable supplies for the proposed field testing is provided below. All sampling media (prepared as per method specifications) will be provided by the contract laboratory, including Tedlar bags. Dr. C.E. Schmidt will supply all other sampling equipment and expendable supplies. The complete flux chamber system shall include the following: 1. US EPA flux chambers as per EPA design including stainless steel Swage-lock fittings, 2. Support cooler with a mounted rotometer (0-to-5 liter per minute) through the cooler walls, 3. Brass, 2-stage regulator for bottled air (CGA 590 fitting for air and 1/4" Swage-lock (male) adapter fitting, 4. Ten foot, 1/4" Teflon line with female fittings, 5. Ten foot, 1/4" Teflon air inlet/outlet support line, 6. Large size plastic support cooler, 7. Set of miscellaneous hand-tools including an adjustable crescent wrench for the CGA 580 regulator fitting, small adjustable crescent wrench for the 1/4" swage fittings, assorted medium and small size screw drivers, 8. Teflon sheet (1/32" or thicker) for blank system testing, 24 Public/Media Event

28 9. Type K thermocouple wires (2, 12') and temperature readout, 10. Rigid-wall shipping/storage crate for the flux chamber mounted on roller wheels, 11. Decontamination supplies including Alconox soap, paper towels, and wash water, 12. Ultra high purity air (some Helium traced) bottles (size 150), 13. Purge pump for sample line purging, 14. Ropes for suspension from extendable ladder, 15. Decompression lung (2), 16. Tedlar bags, canisters, sample tubes, sample pumps, 17. Sample shipping containers, 18. Hand tools, 19. Hand held anemometer, 20. Hot wire anemometer, ft measuring tape, 22. Camera, and 23. Sampling tubs/equipment for pond sample 25