Presented by: Chris Ethridge District Supervisor Air Quality Division MDEQ Southeast Michigan District Office

Presented by: Chris Ethridge District Supervisor Air Quality Division MDEQ Southeast Michigan District Office

By legal definition, air pollution is the presence in the outdoor atmosphere of air contaminants in quantities, of characteristics, under conditions and circumstances, and of a duration that are or can become injurious to human health and property in this state.

An air nuisance is defined in the Michigan Air Pollution Control Regulations R336.1901(b); a person shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause unreasonable interference with the comfortable enjoyment of life and property.

Air complaints encompass both air pollution issues and/or nuisance conditions. Examples of air pollution issues are volatile organic compound emissions or toxic fume emissions. Examples of nuisance conditions can be strong odors or damage to one s property.

Types of Air Complaints Air complaints Odors Visible emissions Fallout

Waste processing (e.g. waste water treatment) Paint spraying (e.g. auto assembly plant) Chemical manufacturing (e.g. ethylene glycol production) Cooking (e.g. coffee roaster) Combustion Processes (e.g. metal heat treat facility) Odors

Visible Emissions Combustion processes (e.g. coal-fired power plant) Waste processing (e.g. garbage incinerator) Open burning

Fallout Heavy manufacturing (e.g. steel mill) Road construction (e.g. asphalt plant, concrete crushers) Painting Operations (e.g. bump shop)

Complaints AQD Staff do not Handle Noise complaints Usually handled by local authority Indoor air complaints Usually handled by OSHA Drive-by complaints Complaints dealing with mobile sources

Michigan Air Pollution Regulations that Relate to Complaints R336.1301 Pertains to 20% opacity standard R336.1310 Pertains to open burning R336.1901 Pertains to air contaminants which cause health and nuisance problems R336.1910 Pertains to proper maintenance and operation of air pollution control equipment R336.1911 Pertains to minimum specifications of a malfunction abatement plan R336.1912 Pertains to facility malfunctions

Procedures Used when Responding to Odor Investigations Complaints Visible Emissions reading (Method 9 or Method 9D) Collection of fallout sample Collection of facility samples (i.e. coal, flyash, paint) Review of facility records

Odor Investigations Rule 901 compliance Intensity Frequency Duration

Intensity refers to a determination by the inspector of the strength of the odors. An observed odor in violation of Rule 901 would be described as a Distinct and definite objectionable odor. Intensity

Frequency refers to how often odors in violation of Rule 901 are observed by the inspector. Frequency can also refer to how many complaints are received in a given amount of time. Frequency

Duration Duration refers to the actual time span odors are observed in violation of Rule 901.

Air Quality Inspector s odor surveillance form

Map of suspected source, wind direction, and the inspector s selected odor observation points

Visible Emissions Investigation Method 9 Readings Method 9D Readings Plant records Continuous Opacity Monitor (COM) readings, plant personnel visible emission readings

Air Quality Inspector s visible emissions observation form

Method 9D Opacity Measurement for Fugitive Dust Sources Opacity measurement is based on an average of 12 consecutive readings recorded at 15 second intervals Valid opacity observations shall be made from a position at least 15 feet away from the source, with the sun behind the observer, and approximately 4 feet above the surface from which the emissions are being generated Consecutive readings must be suspended for any 15 second interval when other vehicle plumes interfere with plume being observed

Fallout Investigations Collecting Evidence Ghost Wipes, petri dishes for fallout samples Complainants and company personnel statements Plant records AQD staff observations

Suggestions for Handling Complaints Determine whether or not your facility may be causing the problem Identify the source of the problem (e.g. fixing malfunctioning air pollution control equipment) Contact the complainant(s) to discuss possible compromises or solutions Create procedures internally to address any potential sources which may be causing problem: Malfunction Abatement Plans Odor Management Plans Fugitive Dust Management Plans Hold a public hearing or informational meeting with general public

Industry Public Relations Informational tour of facility in question Creating or offering a complaint hotline Setting up a website which includes updates of actions facility has taken to correct identified problem Responding directly to complaints received

Malfunction Abatement Plan Rule 911 A complete preventative maintenance program Identification of personnel responsible for preventative maintenance program Identification of operating variables to be monitored Description of corrective procedures or operational procedures taken in the event of a malfunction Inventory of spare parts vital to proper operation of process and air pollution control equipment Inclusion of odor management and fugitive dust management plans

Fugitive Dust Management Plan Periodic calcium chloride applications to roadways Onsite water truck Wheel-wash system for trucks Enclose conveyor belts Enclose material piles to shelter from wind

Odor Management Plan Install additional air pollution control equipment (e.g. thermal oxidizer for a coating operation) Raise stacks to increase dispersion Identify any fugitive emissions which may be causing odors and correct the leak Modify production process using less odorous material or substitute material