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Memo
To: Tom Petrucci, Township Manager
Plainfield Township, azareth PA 18064
This Technical Memo (TM) contains comments resulting from Material Matters (MM) review of the
above referenced submission by Synagro on January 09,2019. For this review we focused on the original
pdf submission as the base for initial DRAFT Mark-Up comments (See accompanying pdf DRAFT Mark-
Up file). In this TM, comments are linked to the aforementioned pdf file by citing the pdf page number
and topic. This narrative is intended to summarize, clarify, and in many cases supplement review
comments initially inserted as DRAFT pdfMark-Ups. This approach will be helpful to insure that
remaining nuisance concerns are addressed.
Over-all Comment:
This updated NMCP submission addresses comments provided in the previous MCP submission by
Synagro, which has been incorporated in this latest version. However, several comments remain, as
provided herein.
Item 4. Nuisance Monitoring and Documentation - Name the "outlined procedure" and where the
procedure is located within the NMCP.
Item 6. Walk through observations - The walk through items listed should be expanded to include all
potential sources of odors, with observations documented.
Pages 19 thru 22 - Community Response Plan - Odor Monitoring and Documentation Performance
Standard:
1. Minimum routine monitoring frequency shall be daily and include times of day associated with
peak nuisance odor events, as revealed in three-year historical odor complaints (gathered by
SBHRC).
2. H2S monitoring equipment: All references to 0.1 ppm H2S shall be replaced with 0.01 ppm in this
section.
3. NH3 monitoring shall be included in this section.
4. NH3 monitoring equipment: Minimum required detection level shall be 0.1 ppm H3
5. 0-6. IfH2S and/or NH3 concentration exceeds established thresholds ..... or odor is observed and
confirmed by SBHRC personnel during investigation:
a. Document field instrument reading(s), and
b. Record that the presence of an off-site odor has been confirmed by investigating SBHRC
personnel.
6. 0-7. Insert "Proceed to preliminary identification of potential odor source" ..... then include
remaining narrative in current step 0-7.... Ending with reference to Professional Odor Support
(POS)
7. General comment. Provide specific (unambiguous) language describing circumstances triggering
POS evaluation specified in existing step 0-10. (Revise and/or add steps bridging existing 0-6
thru 0-9 to provide unmistakable clarity.)
8. Professional Odor Support (POS)
Off-site Dynamic Dilution Olfactometry (i.e. Dynamic Triangular Forced-Choice Olfactometry,
DTFCO) ofTedlar bag samples is OT an appropriate method for assessing low concentration
odor samples that have been significantly diluted with odorless ambient air, distant from the odor
source. There are several reasons for this, including:
a. Preconditioned Tedlar™ bags still have a residual background odor that is routinely
greater than 10 OU/m 3. Off-site fugitive odors will presumably contain low concentration /
dilute odorants. If detection by a neighbor or passer-by is "questionable", it is essential to
1 Brandt, R.C., MAA. Adviento-Borbe, HA Elliott, E.F. Wheeler. 2011. Protocols for Reliable Field Olfactometry
Odor Evaluations. J. Appl. Engr. Agr. Vol. 27(3): 457-466
Pages 19 thru 22 - Community Response Plan - Noise Monitoring and Documentation Performance
Standard:
Under Action Items in the event of confirmed noise concern - What is "second staff'?
Page 31- Attachment - Nuisance Mitigation and Control- Focus Areas - Dewatered Biosolids
Receiving and Storage Area:
Under Operational Mitigation - Insert "appropriate negative pressure value range that must be
measured routinely and maintained".
Also insert "daily observation and documentation of odors adjacent to tlucks waiting to offload
during peak daily offloading times".
Under Actions to Take if receiving and storage area operating improperly - What is "In-Route
drive agreement"?
Page 34 - Attachment - Nuisance Mitigation and Control- Focus Areas - Process Wastewater
Storage and Loadout:
Under Operational Mitigation - Insert - Monitor performance and service carbon filter to maintain
effectiveness. Minimum filter cartridge change-out frequency is 4-months. More frequent change-
out is based on daily inspection findings.
Page 38 - Housekeeping
8.0 Procedures, Specific Tasks. Add the Dewatered Biosolids Receiving Station and surrounding
area as a housekeeping area with appropriate inspection schedule.
7.0 Operating Parameters & Limits - Include details about temperature monitoring system, system
testing, and fire suppression system, if any.
Pages 158 and 159 - Attachment - Potential Source Inventory Map and Complaint Log List:
It is understood that the Synagro is requesting information for these exhibits from Pen Argyl Borough
and Plainfield Township. Similar information may also be available from the PADEP.