Synagro Nuisance Mitigation and Control Plan For Plainfield Township Biosolids Plant Land Development Plan

SLATE BELT HEAT RECOVERY CENTER
NUISANCE MITIGATION AND CONTROL PLAN
[IMAGE TO BE REPLACED AT CONSTRUCTION]
July 2019
A current copy of this document shall be available at the Slate Belt Heat Recovery Center at all times.
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TABLE OF CONTENTS
1.0 Executive Summary ....................................................................................................................... 1-1

2.0 Design & Pre-Construction Activities ............................................................................................. 2-1
3.0 Operations & Preventive Monitoring Activities ............................................................................... 3-1
4.0 Complaint Response ...................................................................................................................... 4-1
Attachment A – Design & Pre-construction Activities ................................................................................A-1
Potential Source Inventory Map .............................................................................................................A-2
Complaint Log List ..................................................................................................................................A-3
Nuisance Mitigation by Design ...............................................................................................................A-4
Air Dispersion Modeling..........................................................................................................................A-5
Attachment B – Operational and Preventive Monitoring ............................................................................B-1
Preventive Monitoring Checklists ...........................................................................................................B-1
Operational Nuisance Mitigation and Control .........................................................................................B-7
Standard Operating Procedures ...........................................................................................................B-13
Professional Odor Training Table of Contents .....................................................................................B-82
Prevention, Preparedness, and Contingency Plan (PP&C Plan) .........................................................B-84
Attachment C – Complaint Response ........................................................................................................C-1
Community Response Program .............................................................................................................C-2
Complaint Response Checklists .............................................................................................................C-6
Professional Odor Support Methodology .............................................................................................C-19
Attachment D – Example Documentation ..................................................................................................D-1
Daily Housekeeping Electronic Log........................................................................................................D-2
Truck Arrival / Departure Electronic Log ................................................................................................D-6
Training Electronic Log ...........................................................................................................................D-8
Example Maintenance Management Work Order ................................................................................D-10
Facility Complaint Log ...........................................................................................................................D-11
Truck Complaint Log .............................................................................................................................D-13
i
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1.0 Executive Summary
The Nuisance Mitigation and Control Plan (NMCP, or “Plan”) has been developed for the Slate Belt Heat
Recovery Center (SBHRC, or “Company”) to outline the measures to achieve the facility goal of having no
offsite nuisance incidents during day to day operations of the Class A Biosolids Thermal Drying Facility.
The Plan supplements and exceeds the requirements otherwise imposed through state-regulated permits
for operation of the facility. This SBHRC goal is rooted in being a good neighbor commencing with design
of the facility, which is based upon over 25 years of Synagro operational experience and continues with
pro-active day-to-day operational procedures and monitoring. The Company’s open and easy community
communication channels will lead to meaningful investigation into any perceived nuisance involving the
facility, resulting in prompt follow up actions that resolve a SBHRC source of nuisance when confirmed.
The Company nuisance mitigation philosophy is driven by years of industry experience in the design and
operation of similar facilities, with an overall concept of control, capture and treatment methodologies that
are included within the design and operations of the facility. Facility design and operational nuisance
mitigation are the mainstay of this Plan.
The Plan identifies and highlights SBHRC commitments associated with Design Criteria and Pre-
Construction Activities, Operations and Preventive Monitoring Program, and while investigating
complaints following the Community Response Plan. The following description of the plan activities is
provided; followed up with attached detailed documents that support SBHRC objectives and activities.
Documentation and record keeping of process conditions, monitoring events, and overall program
adherence is a Plan component that is emphasized throughout the Plan to allow for internal and external
performance review. SBHRC maintains documentation at the facility demonstrating this Plan is followed.
The preventive monitoring and CRP documentation is available onsite for review by Federal, State, and
Local officials during normal business hours.
This living Plan document may be updated during the operational life of the SBHRC, with the mutual
consent of the Township. Revisions are intended to maintain the no nuisance goal as operational
experiences inform a Company continuous improvement program. SBHRC will hold a regularly scheduled
monthly meeting with the Township to the discuss this Plan, the implementation of the Plan, and
associated documentation.
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2.0 Design & Pre‐Construction Activities
The SBHRC facility is designed to receive dewatered biosolids trucked on to the site, process the
dewatered biosolids via thermal treatment to evaporate water using heat captured through the waste heat
recovery component in conjunction with the Green Knights Economic Develop Corporation landfill gas to
energy plant to minimize use of fossil fuels. The result is a Class A biosolids product, regulated by the
Pennsylvania Department of Environmental Protection (PADEP) for use as a renewable biofuel and as an
organically based soil amendment and fertilizer. The SBHRC design focuses on maintaining control of
any potential nuisance, whether odor, dust, noise, etc, as the first priority intended to minimize the
potential nuisance condition through the design of an enclosed process.
The following performance standards are addressed by the design of the facility, will be controlled on the
property or measured at the property line, and are met or exceeded by the provisions in this Plan.
 Pennsylvania Odor Emissions Limitations [25 PA Code § 123.31(b)]: A person may not permit the
emission into the outdoor atmosphere of any malodorous air contaminants from any source, in
such a manner that the malodors are detectable outside the property of the person on whose land
the source is being operated.
 Pennsylvania Nuisance Minimization and Control Requirements [25 PA Code § 283.219]: The
operator shall control and minimize (a) the attraction, harborage or breeding of vectors; and (b)
conditions that are harmful to the environment or public health, or which create safety hazards,
odors, dust, noise, unsightliness and other public nuisances.
 Definition of Nuisance Characteristics of Plainfield Township Zoning Ordinance § 410.3.A: A
nuisance characteristic is any noise, radioactivity, vibration, glare, smoke, odor, air pollution and
dust, which exceeds the performance standards established under relevant ordinances.
Based on the Company’s experience designing, constructing, and operating similar facilities there are six
key areas identified for the design of the SBHRC project that mitigate the potential for nuisances. The
design mitigation focus areas utilize adopted engineering standards and practices focused on control,
capturing and treating potential nuisance conditions.
The focus areas include:
 Heat Recovery & Supplemental Heating Area;
 Dewatered Biosolids Receiving and Storage Area;
 Biosolids Thermal Drying Process;
 Class A Product Load out & Storage Area;
 Process Wastewater Storage & Loadout Area; and
 Odor Control System (OCS)
Fundamental design practices mitigate the potential for nuisance conditions. Performance specifications
are utilized to ensure delivered equipment will be adequate to avoid nuisance operating conditions. The
required performance specifications are established through applying both the facility nuisance potential
and project specific nuisance criteria at the property boundary. Potential odor emissions are addressed in
the design phase with an AERMOD air dispersion model to inform the OCS performance specification.
Supporting documentation for the Design and Pre-construction Activities in Attachment A includes:
 Focus Area Nuisance Mitigation and Control – Design Mitigation;
 Air dispersion modeling objectives and modeling frame work;
 Pre-construction known Potential Nuisance sources within a 1-mile radius – Figure (as requested
by local authorities); and
 Pre-construction Complaint Log List by potential source within a 1-mile radius (as requested by
local authorities).
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3.0 Operations & Preventive Monitoring Activities
Continuous operations oversight and follow up by trained employees and frequent nuisance prevention
monitoring are the cornerstones of this plan. The SBHRC actions are intended first to prevent a potential
nuisance condition through good housekeeping and keen operational oversight, second to correct the
cause of a confirmed nuisance, and third to document the SBHRC actions take to correct a confirmed
nuisance.
SBHRC operations begin at the time the facility is commissioned and continue through the operating life
of the facility. The absence of operational nuisance conditions is initially verified at the property boundary
through nuisance prevention monitoring and completion of an air dispersion model utilizing stack tested
emission rates during commissioning.
After commissioning, this Plan incorporates the details of key mitigation performance indicators to ensure
no nuisance conditions are maintained. Additionally, specific preventive monitoring and complaint
response procedures outline the process, documentation, and communication including conditions that
initiate enhanced monitoring and follow up action.
The standard operating procedures that employees are trained on and required to follow, include specific
actions to correct a situation that has the potential to become a nuisance well before an issue is detected
at the property boundary. SBHRC will utilize this Plan in conjunction with the operating documentation for
permit conditions required by the Pennsylvania Department of Environmental Protection (PADEP) to
document facility operating compliance.
As part of the operations Plan, details are included for the prevention of potential nuisances related to
truck traffic through enforcement of the use of only approved hauling routes and through the employment
of hauling and facility standard operating procedures. Generators will be worked with to mitigate and/or
resolve issues, to the extent reasonable, upfront and at an ongoing basis. This may result in generators
being removed from the approved acceptance list until modifications at their facilities have been
completed to address the potential for a nuisance condition. All truck traffic entering the SBHRC site will
have arrival and departure times and inbound source documented as well as be clearly labeled in
accordance with PennDOT and Federal Department of Transportation standards.
A site-specific Prevention, Preparedness, and Contingency (PP&C) plan is part of the Pennsylvania
Department of Environmental Protection issued General Operating Permit and includes planning
associated with non-nuisance incidents, such as spills and other emergency conditions that could occur
at the facility and cause potential nuisance conditions. The PP&C plan is provided as an attachment to
this Plan document.
All SBHRC employees will receive documented training on this Plan during onboarding as well as annual
refresher training. Additionally, SBHRC subcontractors that routinely conduct work at the SBHRC will also
receive documented training to support an effective program. Such training documentation, as well as the
documentation for the Operations and Preventive Monitoring Activities set forth below, will be available at
the SBHRC facility for review.
Supporting documentation for the Operations and Preventive Monitoring Activities in Attachment B
include:
 Preventive Monitoring checklist

 Focus Area Operational Nuisance Mitigation and Control Measures
 Standard Operating Procedures
 Prevention, Preparedness, and Contingency Plan (PP&C)
Example documentation is provided in Attachment D.
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4.0 Complaint Response
The SBHRC responds to nuisance complaints through the Community Response Plan (CRP). The CRP is
a tool to facilitate effective communications with the public when a concern arises from a suspected
nuisance condition. The attached Community Response Plan consists of a Facility Contact Sheet, a
Community Complaint and Response Form as well as an Employee/Community Response Training
Program.
All responsible employees are trained and provided annual refresher training on nuisance conditions, the
Community Response Plan, and complaint response monitoring activities and follow-up. Specifically, the
training will involve a complete understanding of the Community Response Program, identification of
where the complaint log book is maintained and the proper procedures for recording and responding to a
complaint. Training will also include the identification of facility operating conditions which may lead to a
complaint.
The SBHRC invites two municipal representatives, one each from Plainfield Township and Pen Argyl
Borough, to the professional odor specific training provided to employees. The intention is to be inclusive
and open with the community and our hosts during complaint investigations.
The CRP and nuisance specific complaint response checklist are included in Attachment C. A summary
of the specific actions, outlined in the Complaint Response Checklists, for each nuisance type, after a
complaint is logged include:
 Step by Step approach including status and completion date tracking;
 GCSL and Township notification requirements;
 Complaint response monitoring (including deployment to complaint location);
 Prescriptive documentation;
 Follow up actions ranging from SOP adherence to determination and implementation of system
improvements, if necessary;
 Additional documentation; and
 Review the effectiveness of the follow up actions.
Professional odor support is a complaint investigation method used after complaints have been logged
from the downwind direction for one-week or more, the perceived presence of a nuisance odor exists, and
SBHRC staff are unable to determine who or what the source may be. The effort uses of impartial trained
expert professionals to determine the odor source causing the complaint. The professional effort will
include a series of three field odor surveys conducted during consecutive morning, mid-day and evening
periods designed to account for diurnal meteorological fluctuations and potential local source operating
schedules. A summary report will memorialize the effort, findings and provide the recommended course of
action if SBHRC is found to be the source.
Supporting documentation for Complaint Response in Attachment C include:

 Community Response Plan
 Community Response Plan, Complaint Monitoring, and Action Flow Charts
 Complaint Response Checklists
 Professional Odor Support Methodology
Example documentation is provided in Attachment D.
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Attachment A – Design & Pre‐construction Activities
 Potential Source Inventory Map
 Pre-project Complaint Log List
 Nuisance Mitigation by Design
 Air Dispersion Modeling
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Potential Source Inventory Map
[THE FOLLOWING POTENTIAL NUISANCE SOURCE LOCATION WITHIN 1 MILE RADIUS OF
THE SBHRC PROJECT SITE WILL BE PLOTTED ON A MAP, OF SCALE AT LEAST 1” = 1000
FEET, PRIOR TO SUBSTANTIAL COMPLETION]
The following potential GCSL onsite nuisance dust and odor sources have been identified from the GCSL
Nuisance Minimization and Control Plan:
The following potential offsite nuisance dust and odor sources have been identified from the GCSL
Nuisance Minimization and Control Plan:
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The following potential nuisance sources and locations are associated with PA DEP complaint records:
[TO BE UPDATED UPON AVAILABILITY]
The following potential nuisance sources and locations have been provided by Plainfield Township:
[SBHRC REQUESTS PLAINFIELD TOWNSHIP PROVIDE A LIST OF ADDITIONAL KNOWN

POTENTIAL NUISANCE CONTRIBUTORS, WITHIN 1 MILE REDIUS OF THE PROJECT SITE, AND
INCLUDE THE LOCATION PHYSICAL ADDRESS]
The following potential nuisance sources and locations have been provided by Pen Argyl Borough:
[SBHRC REQUESTS PEN ARGYL BOUROUGH PROVIDE A LIST OF ADDITIONAL KNOWN

POTENTIAL NUISANCE CONTRIBUTORS, WITHIN 1 MILE RADIUS OF THE PROJECT SITE, AND
INCLUDE THE LOCATION PHYSICAL ADDRESS]
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Complaint Log List
The following list has been compiled from complaint logs provided by GCSL, Plainfield Township, Pen
Argyl Borough, participating local entities required to log complaints as stipulated by Plainfield Township
and Pen Argyl Borough, and PA DEP.
[TO BE COMPILED AND PROVIDED PRIOR TO SUBSTANTIAL COMPLETION]
[SBHRC REQUESTS PLAINFIELD TOWNSHIP AND PEN ARGYL BOUROUGH PROVIDE A LIST OF
LOCAL ENTITIES THAT HAVE A NUISANCE MITIGTION AND CONTROL PLAN (OR VARIENT OF)
REQUIRIING RECEIPT OF COMPLAINTS. SBHRC, OR ITS CONSULTANT, WILL REACH OUT TO
EACH ENTITY ONE TIME TO OBTAIN 3 YEARS OF COMPLAINT LOG HISTORY]
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Nuisance Mitigation by Design
Specific design mitigation features at the SBHRC include the following:
 Heat Recovery & Supplemental Heating

 Waste heat recovery unit sound performance specification associated with combustion
turbine full capacity operation, verified at startup;
 Supplemental heating system sound performance specification operating at full load, verified
at startup;
 Equipment specific manufacturer sound attenuated enclosures, provided as required; and
 Supplemental heater OEM supplied combustion control system ensuring complete
combustion and automatic gas supply shut off.
 Dewatered Biosolids Receiving and Storage Area;
 Dewatered biosolids storage in an enclosed tank via a receiving unit with closing cover, with
ventilation to the facility OCS;
 Area storage system components with ventilation on backup power;
 Normally closed receiving unit cover;
 Manually initiated automatic tipping minimizes receiving unit cover open time; and
 Truck alignment indicators position trailers for proper tipping angle and direction, and.
 Containment at/around the Biosolids Receiving Area to capture and control stormwater,
pumped to the Process Wastewater Storage Tank
 Biosolids Thermal Drying Process;
 Conveyance and pumping of dewatered biosolids via enclosed equipment;
 Thermal dryer equipment that is fully enclosed and ventilated to the facility OCS;
 Equipment installed inside insulated building providing sound attenuation;
 Dryer process equipment noise performance specification;
 NFPA 652 Dust Hazard Design Standard;
 Class A product conveyance equipment that is fully enclosed and ventilated to the facility
dust collector and OCS; and
 Critical equipment supplied backup power.
 Class A Product Load out and Storage Area
 Class A Product storage within an enclosed silo and ventilation to facility OCS;
 Loadout nozzle that extends to bed of transport trailer during loadout to minimize dust
potential;
 Area storage system components with ventilation on backup power;
 Containment at/around loadout area to capture and control spilled material; and
 Containment at/around loadout area to capture and control stormwater pumped to the
Process Wastewater Storage Tank.
 Process Wastewater Storage & Loadout Area.
 Process wastewater storage within enclosed tank ventilated to the facility OCS;
 Process wastewater pumped into DOT approved liquid hauling trailer utilizing positive sealed
connections;
 Automated totalized metered fill station protecting from liquid hauling trailer overfill;
 Potential process wastewater loadout spills captured in loadout containment is returned to
Process Wastewater Storage Tank; and
 Containment capture pump station vent utilizes cartridge carbon filter.
 Odor Control System (OCS)
 OCS and ventilated area exhaust fans on backup power;
 Redundant recirculation and chemical dose systems;
 Performance specification based on Air Dispersion Modeling;
 Performance verification based on stack test results and air dispersion model; and
 Continuous monitoring via facility SCADA.
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Air Dispersion Modeling
Two AERMOD Air Dispersion modeling efforts will be completed by qualified professionals and results
utilized to ensure sound system design and to confirm that the actual performance effects on the property
boundary are in compliance with the nuisance criteria.
Phase Objective Results Schedule

Design to inform odor control system performance Prior to Final
specification and ensure the property boundary Design
performance standards will be met
Commissioning after successful facility commissioning and based on Within six weeks of
actual emission measured during compliance stack successful facility
testing commissioning
Each model input will utilize data, such as,

 most recent five years of 1-hour weather station data from Grand Central Sanitary Landfill or
PADEP and Township pre-approved weather station;
 weather data including temperature, wind speed, wind direction, and precipitation;
 local surface characteristics and terrain/topology; and
 Supplemental heater emissions characteristics based on fuel quality and confirmed by vendor.
The receptor spacing listed below for the SBHRC project are for sources of minor significance and
emissions that do not prevent or interfere with the attainment or maintenance of the State of Pennsylvania
ambient air quality standards:
 Property boundary receptors with a spacing no greater than 25 meters;
 A polar (or Cartesian) grid of receptors from the property boundary to 500 meters with a spacing
no greater than 25 meters;
 A polar (or Cartesian) grid of receptors from 500 meters to 1,000 meters with a spacing no
greater than 50 meters; and
 If concentrations above DT are anticipated beyond 1,000 meters, then a polar (or Cartesian) grid
of receptors from 1,000 meters to 2,000 meters with a spacing no greater than 100 meters.
Each air dispersion model will include results and output as follows. These modeled criteria will comply
the OCS preliminary design emissions presented in the facility air Plan Approval 48-00111A application
dated March 20, 2018 and the final issued air plan approval.
Design Commissioning
 Air dispersion model will be solved for each 1-hour over the five year period of input weather
data.
 Plots showing H2S, NH3, and Odor Units that indicates the locations of the 99th percentile
concentration isopleth for each parameter;
 Tabulation of the steady state stack  Estimation of dewatered biosolids receiving
conditions such as, exhaust flow rate, and storage impacts on property boundary
physical characteristics, and H2S and NH3 H2S, NH3, and OU/m3 model output
discharge concentrations to minimize the  Performance correlated to Odor Preventive
potential for nuisance conditions at the Monitoring Documentation conducted
property boundary during startup
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Attachment B – Operational and Preventive Monitoring
Preventive Monitoring Checklists
The following checklists are to be completed to the extent required to guide practice and documentation
of routine and preventive nuisance monitoring. The checklists all require a basic level of documentation
associated with monitoring. Additional actions are required as identified, if the performance standard is
not maintained.
 Odor Preventive Monitoring Procedure

 Noise Preventive Monitoring Procedure
 Dust Preventive Monitoring Procedure
Documentation will be compiled within 48 hours of the time of monitoring and available for review.
Documentation associated with root cause evaluations will be amended to the file documentation within
24 hours of receipt.
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ODOR PREVENTIVE MONITORING PROCEDURE
Initials: Date: Time: AM PM
Wind Wind
o
Speed: mph Direction Temp F Humidity %RH
Standards and Equipment:

Odor Intensity Quantification & Characterization
 8-point n-Butanol odor intensity quantification per ASTM Method E-544-18
 8-point n-Butanol field kit
 Carbon filter respirator
 Training: All employees at onboarding and annual refresher training
Handheld Hydrogen Sulfide meter with specification

 Range: 0.01 -3 ppm H2S
 Accuracy: 0.001 ppm H2S, or 5% of measure
 Calibration: As required by Manufacturer, Maintenance Management System Scheduled
Monitoring Frequency: Daily and in accordance with PADEP Plan Approval 48-00111A requirements
Action Item
O-1 o Conduct requalification per n-Butanol SOP, notify Site Manager if olfactory sensitivity not
adequate
o Refresh self with odor of butanol bottles 1-3 before leaving the office (controlled
environment)
o Wear carbon filter respirator to observation location
O-2 Downwind quadrant monitored Circle one  NE NW SW SE
Observation direction Circle one  CW CCW
Odor Intensity
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O-3 Conduct odor intensity quantification continuously along downwind Start Pt | End Pt | Peak
property boundary perimeter
o Record odor intensity observed at start point
o Record odor intensity observed at end point
o Record peak odor intensity observed
o Record location on Quadrant Map where odor observations
made
O-4 Described odor character observed, if any
Odor H2S
Intensity & Measure
Character
O-5a If peak odor intensity equal to or less than 1: PPM
o Record H2S reading observed at identified < 1 odor intensity ------
location
o Monitoring complete, file this as documentation
O-5b If peak odor intensity equal to 1 and less than 2 then: PPM
o Monitor upwind boundary perimeter and record peak odor
intensity and locate on quadrant map
o Record upwind H2S reading observed at peak odor intensity
o Describe upwind odor character
o Conduct/Reconduct daily housekeeping, document findings
of potential nuisance source and action taken, if any
O-5c If peak odor intensity equal to 2 and less than 3 then: PPM
Only one of O-5a thru O-5e applies

of potential nuisance source corrected, if any
o Inspect OCS operating parameters and NMCP focus areas to
confirm operational indicators in range
O-5d If odor intensity equal to 3: PPM
of potential nuisance source corrected, if any
o Review all NMCP SOP and validate operations, adjust as
needed to prevent potential nuisance odor
O-5e If odor intensity greater than 3 then: PPM
o Conduct actions listed in step O-9
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Documentation Status Date
Completed
O-6 Daily housekeeping records / findings
O-7 Written inspection findings and facility wide corrections associated
with NMCP focus areas operational indicators
Verify OCS parameters are in range and trend data is properly saving
O-8 Written finding of all NMCP SOP review focused on standard
operations. List actions taken to prevent potential nuisance odor and
provide recommended SOP adjustments, if any
Additional Action if peak odor intensity greater than 3 Status Date

Completed
O-9 Conduct root cause evaluation and develop corrective action plan
o Evaluation to include preventive monitoring records, actions
taken to correct potential nuisance, and plan / schedule for
condition correction
o Conduct/Reconduct daily housekeeping, document findings of
potential nuisance source corrected, if any
o Review odor control related SOP and validate operations,
adjust as needed to prevent potential nuisance odor
o Generate Maintenance Management System work order
focused on corrective action (if required)
Additional Documentation if peak odor intensity greater than 3 Status Date

Completed
O-10 Prior 12 hour weather data (wind direction, speed, air temperature, and
relative humidity) from time of monitoring event
O-11 Prior 12 hours OCS Datalog including scrubber flow and pH and
pressure drop trend charts
O-12 Prior 12 hours SBHRC Truck Arrival / Departure Log
O-13 Facility history trends including tipper position, loadout valve position,
recycle air differential pressure
O-14 Root cause evaluation and corrective action plan, and follow through
actions completed
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NOISE PREVENTIVE MONITORING PROCEDURE
Wind Wind
o
Noise Monitoring Equipment

Handheld decibel measurement device
 Range: 30 dBA – 130 dBA
 Accuracy: +/- 2 dBA
Monitoring Frequency: Once per month

Action Item Measure
N-1 Handheld monitoring walking entire property line:
If measure equal to or less than 70 dBA then:
o Document maximum instant reading
o Monitoring complete, file this as documentation dBA
N-2 If measure greater than 70 dBA, then: dBA
o Proceed with actions / resolution dBA
o Coordinate with staff assistant for source investigation / identification dBA
o Remain in place, continue monitoring; dBA
o Document noise level at location each 5 minutes, up to 30 minutes dBA
dBA
dBA
dBA
Actions if noise measure greater than 70 dBA Status Date
Completed
N-3 If noise source is thermal drying process
o Identify source based on location and operating
equipment
o Verify all outside doors are closed
o Power off non-essential equipment loads
N-4 If noise source is outdoor equipment:
o Power off non-essential equipment, i.e. temporary
equipment
o Work with temporary equipment vendors to provide
solution
N-5 Conduct root cause evaluation and develop corrective action plan
o Document source identified during investigations
o Generate Maintenance Management System work order
focused on corrective action (if required)
Documentation if noise greater than 70 dBA Status Date

Completed
N-6 Prior 12 hour weather data (wind direction, speed, air temperature,
and relative humidity) from time of monitoring event
N-7 Prior 12 hours Facility History including hourly throughput, tipper
position, and heat source utilization from time of monitoring event
N-8 Noise monitoring equipment data table output and site
location/time/duration
N-9 Root cause and corrective actions (i.e. Work orders for equipment
related corrective actions, evaluation report, etc)
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DUST PREVENTIVE MONITORING PROCEDURE
Wind Wind
o
Dust Monitoring
EPA Method 9 Visual Emissions (VE)
 Staff Certification: Per EPA Method 9 Requirements
 VE Observation Forms / Clipboard / Pen
 Stopwatch / Timer
Monitoring Frequency: Weekly, In accordance with PADEP Plan Approval 48-00111A requirements
Action Item Status Date
Completed
D-1 Conduct visual emissions at stack and property boundary. If
less than:
o 20% for more 3 minute observation period, or
o 60% at any time
Then:
o Monitoring complete, file D-6 documentation
D-2 If permit limits exceeded then:
o Proceed with actions / resolution
Actions if permit limits are exceeded: Status Date
Completed
D-3 Conduct site daily housekeeping rounds. Clean standing dust /
debris per SOP. Document on Housekeeping Log.
D-4 Identify source through site investigation
o Investigate Nuisance Mitigation and Control Focus
Areas to confirm operational indicators
o Verify SOPs are being followed, refresher train for
identified deficiencies
D-5 Conduct root cause evaluation and completed corrective action
o Generate Maintenance Management System work
order focused on corrective action (if required)
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Documentation if permit limits are exceeded: Status Date
Completed
D-6 Compiled staff EPA Method 9 naked eye visual observations of
stack emission
D-7 Prior 12 hour weather data (wind direction, speed, air
temperature, and relative humidity) from time of monitoring
event
D-8 Prior 7 days dust collector weekly pressure drop
D-9 Prior 12 hours Facility History including hourly throughput and
loadout valve position
D-10 Prior 12 hours SBHRC Truck Arrival / Departure Log
D-11 Root cause and corrective actions (i.e. Work orders for
equipment related corrective actions, evaluation report, etc)
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Operational Nuisance Mitigation and Control
SBHRC has developed and provided focus area plans associated with specific project activities. The
focus area plans provide the details of design and operational practices established to mitigate and
control potential nuisance conditions. Furthermore, guidance is provided to employees to validate that the
mitigation features are working and to provide steps to take if the feature is not working
 Heat Recovery & Supplemental Heating;

 Dewatered Biosolids Receiving and Storage Area;
 Biosolids Thermal Drying Process;
 Class A Product Load out and Storage Area; and
 Process Wastewater Storage & Loadout Area.
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HEAT RECOVERY & SUPPLEMENTAL HEATING
NUISANCE MITIGATION AND CONTROL PERFORMANCE STANDARD
Activities at the waste heat recovery and supplemental heating equipment can have the potential to
generate nuisance conditions (i.e. noise and odor). The following provides a summarization of the
SBHRC design and operational mitigation approaches employed to minimize and control these potentially
nuisances as well as proper performance indication and corrective actions.
Operational Mitigation
 Routine rounds include noise monitoring and documentation along property line
 Maintenance management system to assure continuous equipment performance to support no
nuisance potential
 Periodic stack test verifying regulatory compliance and combustion system regulatory operational
range
Checked during rounds through the facility:
System indicators mitigation is properly working:
 Equipment specific noise performance specification passed at startup

 Routine noise inspection does not indicate greater than 70 dBA at property line
 Combustion control system operating within regulated operational range
Actions to take if mitigation is not working properly:
 If noise performance specification not passed at startup

 Notify equipment supplier of deficient contract condition
 Resolution to include any and all measures up to and including removal of deficient
equipment and replacement with equipment capable of meeting specification
 Verify resolution meets noise limit at property boundary
 If noise level exceedance at property line is verified:
 Notify Site Manager
 Verify equipment operating specifications, adjust equipment to specification
 Verify maintenance frequency and verify timely completion of maintenance
 If required, contact vendor/equipment service provider to repair
 If noise level exceedance at property line continues:
 Conduct root cause analysis and evaluate recommendations, implement as necessary
 If supplemental heater operating outside the regulated operational range:
 Adjust combustion control setting per OEM Operation and Maintenance manual
 Contact vendor/equipment service provider to repair or limit control parameter to
regulated range, if required
07/24/2019
DEWATERED BIOSOLIDS RECEIVING & STORAGE AREA
Activities at the dewatered biosolids receiving and storage area have potential to generate nuisance
conditions (i.e odors). The following provides a summarization of the SBHRC design and operational
mitigation approaches employed to minimize and control these potentially nuisances as well as proper
performance indication and corrective actions.
 Dewatered biosolids receiving with prevention of spillage, containment, and documented daily
housekeeping;
 First in / first out design with 1.5 days of storage to minimize odor generation potential;
 Continuous monitoring of receiving unit suction duct negative pressure;
 Stop biosolids deliveries if OCS is offline;
 All haulers trained on system SOP to complete unloading operation within the design cycle time
System indicators mitigation is providing proper control:
 OCS flow and pH operating within  Receiving unit cover closes at design rate
regulated range  Receiving unit cover limit switch indicates
 All OCS equipment (fans, pump, chemical closure to design position
dosing) online  Receiving unit suction duct negative
 Backup power system properly functions pressure maintained within design
when automatically exercised under load operation range outlined in OCS Monitoring
 Property boundary preventive monitoring SOP
during unloading indicates no malodor  Daily housekeeping with and around the
condition facility documented
Actions to take if mitigation not providing proper control:
 If OCS flow or pH operating outside regulated range

 Adjust flow control valves, pumps, and/or chemical addition per SBHRC Operation and
Maintenance Manual regain performance
 If OCS equipment (fan, pump, or chemical dosing) not operating and will not restart after 3
attempts
 Stop receiving biosolids / call known inbound trucks drivers to divert
 Review OEM O&M Manual to troubleshoot / resolve or manually operate
 Contact vendor/equipment service provider to repair
 If receiving and storage area operating improperly
 Notify Site Manager for immediate relay of diversion notification to inbound drivers
 Verify deliveries received following Dewatered Biosolids Receiving Procedures
 Inbound drivers required to adhere to In-Route Stop Driver Agreement
 Review OEM O&M Manual to troubleshoot / resolve or manually operate
 Repair defect. If required, contact vendor/equipment service provider to repair
 If necessary, conduct alternatives analysis recommending improvements to meet
performance standards
 If area and facility operational mitigation providing proper control:
 Site Manager to communicate with identified generator to mitigation condition to prevent
potential nuisance condition
 If necessary, suspend acceptance of verified nuisance source until mitigation/resolution
implemented
07/24/2019
THERMAL DRYING PROCESS
Activities associated with the thermal dryer process have potential for nuisance (i.e odor, noise, dust)
conditions. The following provides a summarization of the SBHRC design and operational mitigation
approaches employed to minimize and control these potentially nuisances as well as proper performance
indication and corrective actions.
 OCS servicing all appropriate equipment, operating with defined performance criteria and
monitoring and reporting systems to document;
 Ability to monitor dust collection system and alarm notification of upset condition;
 Typical employee access to dryer process through interior doors;
 Facility weather station to monitor conditions and allow for pro-active mitigation of potential
nuisance conditions;
 Ability to cease thermal dryer operations, while maintaining OCS performance during power
outage;
nuisance potential;
 Housekeeping within and around the facility as a daily function;
System indicators mitigation is properly working:

 OCS flow and pH operating within  Daily housekeeping with and around the
regulated range; facility documented;
 All OCS equipment (fans, pump, chemical  Dust collection equipment key performance
dosing) online; indicators within specification;
 Backup power system properly functions  Minimal dust accumulated in OCS
when automatically exercised under load;  Noise testing at commissioning passes
 Dust collection equipment online; performance test
Actions to take if mitigation is not properly working:

 Adjust flow control valves, pumps, and/or chemical addition per OEM and SBHRC
Operation and Maintenance Manual regain performance
attempts
 Stop biosolids feed to dryer / call known inbound trucks drivers to divert
 Review EOM O&M Manual to troubleshoot / resolve or manually operate
 If dust collection equipment operating improperly
 Adjust Maintenance Management System work order frequency to maintain proper
operation
 If noise level exceedance at property boundary is verified:
 Close thermal dryer building exterior doors;
 Identify equipment source, verify operational specifications, adjust if necessary
 Verify maintenance frequency and verify completion of timely maintenance
 If noise level exceedance at property line continues:
 Conduct root cause analysis and evaluate recommendations, implement as necessary
07/24/2019
CLASS A PRODUCT STORAGE & LOADOUT AREA
Activities at the Class A product storage and loadout area have potential to generate nuisance conditions
(i.e. odor and dust). The following provides a summarization of the SBHRC design and operational
performance indication and corrective actions.
 Continuous OCS parameter monitoring and control
 Product loadout SOP, requires trucks tarped at all-times other than loadout time
 Housekeeping around the facility as a daily function
System indicators mitigation is providing proper control:

 OCS flow and pH operating within  Daily housekeeping with and around the
regulated range facility document no Class A product spills
 All OCS equipment (fan, pump, chemical  Load out chute working automatically
dosing) online  Pump Station vent cartridge filter checked
 Backup power system properly functions daily for potential nuisance
when automatically exercised under load
Actions to take if mitigation not providing proper control:

attempts
 If product loadout nozzle / equipment operating improperly
 If dust collection equipment operating improperly
 Verify Class A Product Loadout and Storage SOP is followed
 Adjust Maintenance Management System work order frequency to maintain proper
operation
 If Class A product accumulated in the load out area
 Reference housekeeping SOP for day to day cleanup
 Reference Prevention, Preparedness, and Contingency Plan
07/24/2019
PROCESS WASTEWATER STORAGE & LOADOUT
Activities associated with process wastewater storage and loadout has the potential to generate nuisance
conditions (i.e. odors). The following provides a summarization of the SBHRC design and operational
performance indication and corrective action.
 Process wastewater loadout spill prevention, containment, cleanup and return to wastewater
storage tank;
 OCS servicing storage tank includes defined performance criteria and monitoring and reporting
systems to document;
 Process wastewater storage containment sampling requirements outlined in operating permits
validates no breach of primary tank;
nuisance potential;
 Housekeeping within and around the receiving and loadout area as a daily function;
 Odor control provisions during OCS offline
Checked during all rounds through the facility:
System indicators are providing proper control:

 OCS flow and pH operating within  No evidence of leaks or spills observed
regulated range and documented during daily
 All OCS equipment (fans, pump, chemical housekeeping;
dosing) online  Process wastewater containment sample
 Backup power system properly functions analytics less than limits
when automatically exercised under load
Actions to take if not providing proper control

 If OCS flow or pH operating outside regulated range
 If OCS equipment (fan, pump, or chemical dosing) not operating and will not restart after 3
attempts
 If wastewater collection/storage or fill station equipment operating improperly
 If wastewater storage or loadout containment captures wastewater leak or spill
 Visually inspect equipment and systems, create urgent work order to inspect confined
spaces
 Repair identified defect. If required, contact vendor/equipment service provider to repair
07/24/2019
Standard Operating Procedures
 Housekeeping
 Control Room Log Book
 Dewatered Biosolids Receiving Procedures
 Thermal Drying Process Monitoring Procedures
 Class A Biosolids Product Loadout Procedure
 Process Wastewater Storage and Loadout Procedure
 Trailer Tarping, Truck Route, and In-Route Stops Driver Agreement
 Odor Control System Monitoring
 Odor Control System Operation and Maintenance Manual
 n-Butanol Odor Intensity Field Kit Requirements
 Backup Power Procedures
07/24/2019
Facilities Policies and Procedures
Date: Doc Number:

Rev: 001
2/14/2019 CA - 012
TITLE SOP – Housekeeping

Page: 1 of 5
& its impact on vector control, odor control, and dust
1.0 Purpose
• General Housekeeping Requirements

o Procedure provides basic information of structure and expectations for housekeeping.
o Completion of the housekeeping log required
o It includes information on primary housekeeping impacts.
 Housekeeping Impact on dust
• Procedure provides information on hazards of dust and housekeeping
procedures for controlling dust.
 Housekeeping Impact on odor control
• Eliminating dust and exposed sludge makes a positive impact on
controling odors at the facility.
• Controlling dust within the facility improves our quality of life and also
reduces the chance of having an external odor complaint.
 Housekeeping Impact on outdoor project site
• Maintaining a site clean from small and large biosolids spills will result in
a presentable site, control odors and the eliminate source from unwanted
vectors.
2.0 Scope
2.1 Scope Statement
To ensure site housekeeping is maintained to standards for safety and odor control.
2.2 Contents:
1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
2.2 Table of Contents
3.0 Risks & Hazards
4.0 Definitions & Abbreviations
5.0 Responsibilities
6.0 Qualifications
7.0 Operating Parameters & Limits
8.0 Procedures
9.0 Reference Documents
10.0 Revision Log
11.0 Training Log
Page 1 of 5
Date: Doc Number:

Rev: 001
2/14/2019 CA - 012

Page: 2 of 5
3.0 Risks & Hazards

o Improper housekeeping can lead to
 Loss of face with customer
 Excessive internal building odor leading to external odor control complaints and
general quality of life for operations group
 Vector attraction to the site
o Excessive dust can lead to fires or explosions resulting in equipment damage, injury, and
loss of life.
4.0 Definitions and Abbreviations

Synagro Operations: On shift operator(s)
Synagro Management: Plant Manager, Operations Manager, or delegate
All operators and maintenance are responsible for cleaning during their normal duties.
All maintenance personnel are responsible for cleaning up after completion of work orders.
All operations personnel are assigned an area of responsibility once per quarter. They are responsible for
planning and coordinating housekeeping in this area in addition to normal cleanup jobs.
All operations personnel are responsible to assist other operations personnel in housekeeping.
6.0 Qualifications
All operators & maintenance personnel should review these procedures as a part of standard training.
There are no special qualifications beyond standard site specific training.

Dust cannot exceed the thickness of a penny on any surface, including upper rafters.
Page 2 of 5
Date: Doc Number:

Rev: 001
2/14/2019 CA - 012

Page: 3 of 5
8.0 Procedures
Step Activity
Site Manager will assign housekeeping areas to each operator on a quarterly
basis
Housekeeping Operators/Maintenance are to review their housekeeping area and to make a
plan for improvement of this areas housekeeping. To accomplish this plan
Areas they should communicate resource needs, including costs, and assistance
from other operators. This should be communicated to management who
will prioritze resources.
Control room should be cleaned by night shift, every night.
Receiving Area should be checked at least once per day. Small biosolids
cake spills need to be cleaned immediately after a received load with a
broom and shovel. Large spills need to be cleanned in accordance with the
Prevention, Preparedness, and Contingency Plan.
Hopper/Rams/Pumps should be checked at least once per week. If
excessive buildup is present then a work order should be entered to
Specific Tasks tighten/add packing. Work should be split across all 4 shifts.
Conveyor Discharge Supersacks should be removed to dumpster as it is
filled.
Class A Product Loadout Area should be checked at least once per day.
Small product spills need to be cleaned immediately with a broom and
shovel. Large spills need to be cleanned in accordance with the Prevention,
Preparedness, and Contingency Plan.
Site Manager should complete housekeeping audits on a weekly basis in
Auditing
conjunction with operators.
Do not use compressed air to clean surfaces.
Only use vacuums approved for dust collection.
Use cleaning methods that do not generate dust clouds, if ignition sources
Dust Hazard
are present
Whenever possible we should keep surfaces clean of dust. Generally
accepted level of flammable dust is less than the thickness of a penny.
Odor Control Investigate unusual odors when they are found. If needed refer to
procedures for OCS equipment operation. If housekeeping related then
operator should resolve or contact site management to do so.
Page 3 of 5
Date: Doc Number:

Rev: 001
2/14/2019 CA - 012

Page: 4 of 5
9.0 Reference Documents:
Dust reference
https://www.osha.gov/dts/shib/shib073105.html
10.0 Revision History
Facility SBRHC Revision/Review History Log

# Date of
Description/Author
Revision/Review
2/14/2019 SBHRC
1
10
Page 4 of 5
Date: Doc Number:

Rev: 001
2/14/2019 CA - 012

Page: 5 of 5
11.0 Training Log
Name Date Signature
Page 5 of 5
Doc Number:
Date: 10/16/18 Rev: 04
CA-005
TITLE SOP –Operating Logs Page: 1 of 6
1.0 Purpose
Procedure establishes guidelines to facilitate proper communication between shifts and
between operations and management. Communication is key for proper operation and
improvement.
The act of logging the various values also helps operators determine when there are
abnormal or non-ideal circumstances, and to take corrective action.
Another primary purpose of these documents is to ensure compliance with various permit
and legal requirements.
2.0 Scope
2.1 Scope Statement
The various logbooks are an integral part of the operator’s daily duties. This procedure is a
guideline for the daily entries that must be made.
2.2 Contents:
1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
8.0 Procedures
8.1 Various Daily/Monthly Logs
8.1.1 Permit Required Documentation
8.1.1 Process Variable logging
8.2 Control Room Log Book
8.3 Visual Management Boards
10.0 Revision Log
11.0 Training Log
Page 1 of 6
Doc Number:
Date: 10/16/18 Rev: 04
CA-005
3.0 Risks & Hazards

3.1 Various logs provides basis for shift to shift communication.
3.1.1 Poor communication can result in operational problems, delayed maintenance,
safety, and environmental concerns.
3.1.2 Failure to keep logs up to date can lead to missing abnormal or non-ideal
operating conditions.
3.2 Various logs provide required documentation for permits and other legal requirements.
3.2.1 Failure to meet permit documentation requirements can lead to fines or at worst
case ceased operations.

4.1 Synagro Operations: On shift operator(s)
4.2 Synagro Management: Plant Manager, Operations Manager, or delegate
5.1 Synagro operations are responsible for proper completion of all logs.
5.2 Synagro management is responsible for review of logs.
6.0 Qualifications
All operators should review these procedures as a part of standard training. There are no special
qualifications beyond standard site specific training.

N/A
Page 2 of 6
Doc Number:
Date: 10/16/18 Rev: 04
CA-005
8.0 Procedure:
8.1 Various Daily/Monthly Logs

8.1.1 All entries to hand written logs are to be made in Black or Blue ink ONLY! DO
NOT use white out in the logbook. Mistakes in the logbook are to be crossed out
with a SINGLE line and operator should initial and date the correction.
8.1.2 A complete list of logs with designated form number is contained in the excel file
“operator logs and round sheets.xls”. This is stored on Syntel and on SBHRC
cloud drive.
8.2 Permit Required Documentation
8.2.1 All permit and contractual requirements are designated as such in the various
logs.
8.2.2 These fields must be filled in! When unable to do so, a reason must be
provided for why they were not filled in. This reason should be recorded on the
form itself and in the Control Room Log Book.
8.2.3 Forms have been designed so that most all permit values are both hand written
and computer recorded. This is for back-up of critical data.
8.2.4 Fields do not need to be filled in at the exact time listed on the form. General rule
is to obtain reading any time prior to the next hour.
8.2.5 The chart below shows all the permit required readings that must be filled in.
[INSERT SCADA SCREEN IMAGE WITH PERMIT REQUIRED READINGS]
8.3 Process Documentation

8.3.1 All process variables are designated as such in the various logs.
8.3.2 These fields do not always need to be filled in. It is okay to miss these entries.
Generally best practice is to explain why in the comments on the form or in the
Control Room Log Book.
8.3.4 Fields do not need to be filled in at the exact time listed on the form. General rule
is to obtain reading within ~30 minutes of time listed on form.
8.3.5 Forms have been designed so that process values are either hand written or
computer recorded except when it is convenient to do both. Values gotten from
field instruments are generally hand written. Values gotten from the control
systems are generally recorded in computer.
8.4 Control Room Log Book

8.4.1 All entries are to be made in Black or Blue ink ONLY! DO NOT use white out
in the logbook. Mistakes in the logbook are to be crossed out with a SINGLE line
and operator should initial and date the correction.
8.4.2 As a minimum the following must be entered each shift.
1. Date: Format is 00/00/0000
Page 3 of 6
Doc Number:
Date: 10/16/18 Rev: 04
CA-005
2. Time: Military format.

3. Personnel on shift: Start with the person running the board, followed by all
other operations personnel on shift.
4. Plant Status: Dryer Trains running, lead Auxiliary Equipment running, Tank
levels, what is pumping where and any other relevant equipment status(what’s
broke and why).
5. Start and Stop times: Enter the Start and Stop times of all equipment that is
started or stopped on your shift.
6. For the purpose of tracking down time, Dryer start and stop times are
when the feed pump is started and stopped.
7. Problems encountered during your shift.
8. Changes encountered during your shift.
9. Operational changes made to the process.
10. Any contact with GCSL.
11. Any other pertinent information you deem necessary.
8.4.3 Turnover. At the end of each shift the information you enter in the log book will
be reviewed with the oncoming shift.
1. Review EACH entry with the oncoming shift.

2. Make sure the oncoming shift understands what is written in the Log Book.
3. Oncoming shift needs to make sure they understand what is written in the Log
Book.
4. Make sure you review any changes to the process, made within the last hour,
with the oncoming shift.
5. Each oncoming operator and outgoing operator will sign his name below the
last entry from the previous shift. This will be indicative of your
understanding of what took place during the previous shift and that you have
transferred your shift information on to the next shift.
8.5 Visual management boards

8.5.1 Visual management boards are for communication only and are not legal
documents.
8.5.2 Each shift should update relevant information during shift change-over.
8.5.3 Abnormal conditions/events should be pointed out.

Operator logs and round sheets.xlsx located on Syntel and SBHRC Cloud Drive
Page 4 of 6
Doc Number:
Date: 10/16/18 Rev: 04
CA-005
Facility SBHRC Revision/Review History Log

# Date of
Author/Description
Revision/Review
1 12/22/15 D Benson author
2 10/16/2018 SBHRC revision
3 .
10
Page 5 of 6
Doc Number:
Date: 10/16/18 Rev: 04
CA-005
11.0 Training Log
Procedure Name
Form Number CA-005 Revision # 04
Name Date Signature
Page 6 of 6
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011
TITLE SOP – Dewatered Biosolids Receiving Page: 1 of 6
1.0 Purpose
This procedure sets forth the expectations for Slate Belt Heat Recovery Center (SBHRC) and
their responsible employees. It is intended to provide reasonable guidance to meet Community,
Regulatory and Company requirements for operating in the dewatered biosolids receiving.
2.0 Scope
2.1 Scope Statement
This procedure covers the activities necessary to ensure the proper operation of the dewatered
biosolids receiving.
2.2 Contents:
1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
8.0 Procedures
8.1 Dewatered Biosolids Receiving
8.2 Tailgate and Tire Rinse
8.3 Best Practices Trucking
8.4 Best Practices - Area
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards
3.1 Personnel are not allowed inside the designated no access zone while trailer tipping is
occurring to prevent injury or death by heavy weight impact. Improper operation of the
dewatered biosolids receiving system and the activities in the area, can lead to odor
complaints. This could damage the SBHRC customer relationships or may results in permit
violations
3.2 Proper PPE must be worn at all times during loadout.
3.2.1 Hard Hat
3.2.2 Steel Toe Boots
3.2.3 Safety goggles.
3.2.4 High visibility vest
Page 1 of 6
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011

4.1 Synagro Operations: On shift operator
4.2 Synagro Management: Site Manager, Operations Lead, or delegate
4.3 SWM: Stormwater Management
5.1 SBHRC Operations is responsible for operating the systems and activities in the biosolids
receiving area as prescribed in the [tipper manufacturer] and [receiving unit enclosure cover]
O&M manual.
5.2 Truck drivers are responsible for understanding the provided training and operation of the
trailer tipper, receiving unit enclosure cover, and rinse systems. If abnormal operation of the
any systems is observed during operation, such as, extended periods with the cover open, the
driver must immediately notify the Site Manager.
5.3 SBHRC Site Manager is responsible for providing a safe work environment and the tools
necessary to operate the biosolids receiving area.
6.0 Qualifications
All operators should review these procedures as a part of standard annual training. There are
no special qualifications beyond standard site specific training

7.1 Dewatered Biosolids Receiving Unit Level
7.1.1 HI Level 90%
7.1.2 LO Level N/A
7.2 Receiving Unit Ventilation
7.2.1 Exhaust Air Fan Status Online at all times
7.2.2 Unit 1 suction duct pressure HI Level [XX] “ WC
7.2.3 Unit 2 suction duct pressure HI Level [XX] “ WC
7.3 Tipper Hydraulic Pressure Gauge
7.3.1 HI [] psig
7.3.2 LO [] psig
7.4 Receiving Unit Cover Limit Switch
7.3.1 Open
7.3.2 Closed
Page 2 of 6
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011
8.0 Procedures
8.1 Dewatered Biosolids Receiving
8.1.1 Visually inspect vehicle to ensure no materials are leaking and that tarp and tailgate are
secure.
8.1.2 Ensure receiving unit capacity available
8.1.3 Verify Odor Control System is fully functional
8.1.4 Dewatered biosolids unloading sequence:
8.1.4.1 Allign the trailer with the ground level tipper
8.1.4.2 Position the trailer on the tipper until it meets backstop
8.1.4.3 Decouple tractor from trailer, drive tractor clear of tipper, min 10 feet
8.1.4.4 Remove trailer tarp and secure rear trailer doors open with chains
8.1.4.5 Proceded to automatic tipper control station, initiate tipper cycle
8.1.5 Verify dewater biosoilds receiving unit cover opens clear of unloaded biosolids
8.1.6 Verify dewatered biosolids receiving unit closed limit switch following cycle
8.1.7 Verify tipper lowered to ground level
8.1.8 Close and secure rear trailer doors, secure tarp over trailer
8.1.9 Rinse tires, tailgate and tipper clean of dirt and debris
8.1.101 Couple trailer and return to scale house
8.2 Tailgate and Tire Rinse

8.2.1 Ensure the rear trailer doors closed and bed is tarped securely
8.2.2 Rinse only in the designated area over the SWM permitted capture system
8.2.3 Focus rinsing on areas of dirty and debris, minimizing water use
8.2.4 Rinse from top down
8.2.5 Rinse tires and underbody clear of material and to capture system
8.2.6 Rinse tipper deck free of debris
8.2.7 Shut off rinse water and coil hose on rack
8.3 Best Practices Trucking

8.3.1 Ensure trailer is tarped. No movements allowed untarped
8.3.2 Repair tarp and trailer tailgate systems if defect found, do not use until repaired
8.3.2 Visually inspect vehicle to ensure no materials are leaking
8.3.3 Do not exit the tipper if biosolids are on the tipper deck after tipping
8.3.4 Do not drive through biosolids.
8.3.5 Move from area after unloading to avoid queuing of inbound loads
8.3.6 Follow access road speed limits at all time
8.3.7 Left turns give right of way to oncoming traffic
8.4 Best Practices Area

8.4.1 Do not rinse biosolids into the containment area, rather, transfer to receiving unit
8.4.2 If biosolids seen on the tipper deck, transfer to receiving unit with shovel
8.4.3 Clean containment area drain free of obstructions immediately
8.4.4 Complete receiving procedure safely and efficently
8.4.5 Clean containment area drain free of obstructions immediately
Page 3 of 6
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011
[Equipment Supplier] O & M Manuals

SBHRC Odor Control System O&M Manual
Date of
# Description/Author
Revision/Review
1 2/14/2019 SBHRC
10
Page 4 of 6
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011
11.0 Training Log
Procedure Name
Name Date Signature
Page 5 of 6
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011
Page 6 of 6
Date: Doc Number:

Rev: 00
4/28/2019 CA - 001
TITLE SOP – Thermal Drying Process Monitoring Procedures Page: 1 of 5
1.0 Purpose
The following procedures relate to the control and operation for the thermal drying process with emphasis on
potential nuisances conditions and minimizing safety hazards. It is our collective responsibility to operate the system
that is compliant with OSHA safe work place standards and immediately address conditions that may result in
nuisance conditions. In general, operational and environmental compliance are dictated by the SBHRC Pennsylvania
(PA) Department of Environmental Protection (DEP) General Permit; XXXXX.
2.0 Scope
2.1 Scope Statement
To ensure compliance with SBHRC General Permit XXXXX and conditions agreed to with Plainfield
Township in accordance with potential nuisance mitigation and control.
2.2 Contents: Odor Control

1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
7.0 Equipment List
8.0 Procedures
8.1 Thermal Drying System
8.2 Summary of Process Gas Pressure Monitoring
8.2.1 Process Gas Pressure Monitoring Operate Parameters
8.3 Summary of Process Gas Temperature Monitoring
8.3.1 Process Gas Temperature Monitoring Operating Parameters
8.TBD
8.4.1 TBD
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards
3.1 Permit violations may result in
3.1.1 Damage to customer relations
3.1.2 Significant fines
3.1.3 Plant shutdown
3.2 Odor complaints may result in
3.2.2 Damage to local confidence and relations
3.2.3 Significant fines and increased operating expense
3.3 Deflagration
3.3.1 Damage to equipment
3.3.2 Injury

Page 1 of 5
Date: Doc Number:

Rev: 00
4/28/2019 CA - 001
NMCP – Nuisance Mitigation and Control Plan

PE – Pressure element
TE – Temperature element
5.1 SBHRC operations is responsible to operate the plant within permit compliance and to cease operations if unable
to do so. In the event of permit issues, SBHRC operations is responsible to notify SBHRC Site Manager.
5.2 SBHRC Site Manager is responsible for proper maintenance and operation of odor control systems, as they are
managed assets. For compliance or odor issues, SBHRC Plant Manager is responsible for notification to the
Facility Area Manager and establish resolution of issue.
5.3 SBHRC Plant Manager is responsible for any notifications resulting to compliance issues with General Permit
XXXX.
6.0 Qualifications
All operators are to review these procedures as a part of standard training. Specify operator training on thermal
drying equipment is provided by the Supplier at system startup.
7.0 Equipment List

Equipment Criticality To
Equip # Name Function Location Operations
EAF- Dryer Exhaust Do Not Operate Dryer
Conveys Dryer Air To Odor Control Devices Dryer #1
XXX Fan-1 #1 Unless Functional
XXX Fan 2 #2 Unless Functional
8.0 Procedures
8.1 Thermal Dryer System
8.1.1 [UPDATE TO INCLUDE OEM SPECIFIC CONTENT WHEN AVAILABLE]
8.2 Summary: System Process Gas Pressure Monitoring
Monitoring process gas pressure throughout the system provides key indication that the system is properly
operating and conveying flow as designed. The Control Room Operator will have access to realtime instrument
readings for each of the points list below.
Page 2 of 5
Date: Doc Number:

Rev: 00
4/28/2019 CA - 001
8.2.1 Process Gas Pressure Monitoring - Operating Parameters
[TO BE UPDATED WITH INSTRUMENTATION DETAILS AT FINAL DESIGN]
EQUIP # LOCATION LOG INSTRUMENT MIN MAX UNITS

XXX Facility Data Log PE-XXX TBD TBD “ WC
XXX Facility Data Log PE-XXX TBD TBD " WC
XXX Facility Data Log PE-XXX TBD TBD " WC
XXX Facility Data Log PE-XXX TBD TBD " WC.
8.3 Summary: System Process Gas Temperature Monitoring
Monitoring process gas temperature throughout the system provides key indication that the system is properly
operating and safely meeting design and regulatory requirement. The Control Room Operator will have access
to realtime instrument readings for each of the points list below.
8.3.1 Dry System Process Gas Temperature Monitoring - Operating Parameters:
EQUIP # LOCATION LOG INSTRUMENT MIN MAX UNITS

O
XX Dryer 1 Outlet Facility Data Log TE-XXX xx xx F
O
XX Dryer 2 Outlet Facility Data Log TE-XXX xx xx F
O
XX Facility Data Log TE-XXX xx xx F
8.5 OCS Forced Outage Dryer Shutdown Sequence
[TO BE UPDATED AS NEEDED BASED ON FINAL DESIGN}
8.5.1 Stop wet feed to dryer

8.5.2 Complete processing of material in dryer
8.5.3 Transfer product to storage
8.5.4 Initiate dryer cooldown sequence
8.5.5 [TBD] Complete dryer shutdown sequence
8.6 TBD
[TO BE UPDATED AS NEEDED BASED ON FINAL DESIGN, TO INCLUDE DEFLAGRATION

MONITORING ]

• Dryer Facility Operation and Maintenance Manual
• Standard Pellet Sampling Practices (Physical, Fecal, and Metals)
Page 3 of 5
Date: Doc Number:

Rev: 00
4/28/2019 CA - 001
10.0 Revision Log

Date of
Revision/Review
1 2/14/2019 SBHRC
2 4/28/2019 SBHRC draft
10
Page 4 of 5
Date: Doc Number:

Rev: 00
4/28/2019 CA - 001
11.0 Training Log
Odor Control
Form
CA - 002 Revision # 002
Number
Name Date Signature
Page 5 of 5
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Rev: 00
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TITLE SOP – Class A Product Loadout Page: 1 of 5
1.0 Purpose
This procedure sets forth the minimum expectations for Slate Belt Heat Recovery Center
(SBHRC) and their responsible employees. It is intended to provide reasonable guidance to meet
Community, Regulatory and Company requirements for operating the Silo Loadout system.
2.0 Scope
2.1 Scope Statement
This procedure covers the activities necessary to ensure the proper operation of the Class A
Product Loadout system.
2.2 Contents:
1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
8.0 Procedures
8.1 Pre-Start Procedures
8.2 Startup Procedure
8.3 Shutdown Procedure
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards
3.1 Improper operation of the Silo Loadout system can lead to odor complaints, particulate
release to the atmosphere, and violation of our Air Permits. This could damage our customer
relationship.
3.2 The release of particulate to the atmosphere could result in and NOV and fines.
3.3.1 Hard Hat
3.3.4 Gloves
3.3.5 Respiratory protection as needed (dust respirator).
3.4 Deflagration or product heating
Page 1 of 5
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4.2 Synagro Management: Plant Manager, Operations Manager, or delegate
5.1 Synagro Operations is responsible for operating the Silo Unloading system as prescribed in
the [equipment supplier] O&M manual.
5.2 Synagro Management is responsible for providing a safe work environment and the tools
necessary to operate the Silo Unloading system.
6.0 Qualifications
All operators should review these procedures as a part of standard training. There are no
special qualifications beyond standard site specific training

7.1 Silo levels.
7.1.1 HI Level 80%
7.1.2 LO Level N/A
7.2 Silo Temperature (Continuous monitoring via thermocouple)
7.2.1 HI Temp 120oF
7.2.2 LO Temp N/A
7.3 Silo Carbon Monoxide (Continuous monitoring)
7.3.1 HI CO 150 ppm
7.3.2 LO CO N/A
7.4 Nitrogen Inerting System
7.3.1 TBD
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8.0 Procedures
8.1 Pre-Startup
8.1.1 Ensure trailer is available.
8.1.2 Ensure adequate silo level prior to loading trailer.
8.1.3 Check Loadout Dust Collector for the following alarms
8.1.4 Inspect spout loading stations for the following.
8.1.4.1 Open slide gates on each spout and check for pluggage. Should be able to
see conveyor screw.
8.1.4.2 Check pendant operation. Spouts should raise and lower properly.
8.2 Loadout
8.2.1 Position trailer in loading bay under the appropriate spout and chock the wheels.
8.2.2 Contact control room and have the operator enable/start the following
8.2.2.2 Enable the “Silo Loading” 1 or 2.
8.2.2.3 Enable the “Station Loading” 1 or 2.
8.2.3 Start the Loadout Dust Collector Rotary Valve at the local switches.
8.2.4 Select the Silo # and Station # on the remote pendant.
8.2.5 Lower the spout to six inches from the bottom of the trailer.
8.2.6 Start loading the trailer by pressing the start button on the remote pendant.
8.2.6.1 The slide gate will open on the appropriat loading spout.
8.2.6.2 Screw conveyor will start to the appropriat loading station.
8.2.6.3 Slide gate will open to the selected silo and product will start flowing to
the trailer.
8.2.7 When the pile reaches the top of the trailer, press stop button on pendant.
Equipment will shut down in reverse order.
8.2.7.1 Raise the spout and move the trailer to the next pile position.
8.2.7.2 Lower the spout and restart the the unloading.
8.2.7.3 Continue until trailer has reached desired weight.
8.2.8 When trailer is full press the stop button and raise the spout to the up position.
8.2.9 Move the trailer to the scale for weight. If under desired weight, return to loadout
and add more product. If at weight, have driver hook up trailer to his truck or
place trailer in silo to await drivers return to haul off site.
8.3 Shutdown.
8.3.1 Raise all silo spouts to full up position.
8.3.2 Place control pendant in proper storage location. Wrap in plastic bag to protect
pendant from moisture.
8.3.3 Contact control room and request the Silo Loadout System be disabled and the
lower baghouse pulse jets be turned off.
Page 3 of 5
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8.3.4 Inspect Dust Collector for for proper operation or excessive dust accumulation.
Clean if needed.
.
[equipment manufacturer] O & M Manuals
Date of
Revision/Review
1 2/14/2019 SBHRC
10
Page 4 of 5
Date: Doc Number:

Rev: 00
2/14/2019 CA - 011
11.0 Training Log
Procedure Name
Name Date Signature
Page 5 of 5
Date: Doc Number:

Rev: 00
2/14/2019 CA - 012
TITLE SOP – Process Wastewater Storage and Liquid Loadout Page: 1 of 5
1.0 Purpose
This procedure sets forth the minimum expectations for Slate Belt Heat Recovery Center
(SBHRC) and their responsible employees. It is intended to provide reasonable guidance to meet
Community, Regulatory and Company requirements for operating in the process wastewater
storage and liquid loadout area.
2.0 Scope
2.1 Scope Statement
This procedure covers the activities necessary to ensure the proper operation of the process
wastewater liquid loadout area.
2.2 Contents:
1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
8.0 Procedures
8.1 Process Wastewater Loadout
8.2 Process Wastewater Storage
8.3 Process Wastewater Containment
8.4 Process Wastewater Storage Odor Control
8.5 Capture Pump Station
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards
3.1 Improper operation of the process wastewater liquid loadout system can lead to odor
complaints or spills. This could damage the SBHRC customer relationship and may result in
penalties.
3.2.1 Hard Hat
3.2.4 Gloves
Page 1 of 5
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4.3 SWM: Stormwater Management
5.1 Synagro Operations is responsible for operating the systems and activities in the process
wastewater liquid loadout area.
5.2 Synagro Management is responsible for providing a safe work environment and the tools
necessary to operate the process wastewater liquid loadout area.
6.0 Qualifications
All operators should review these procedures as a part of standard training. There are no
special qualifications beyond standard site specific training

7.1 Process Wastewater Storage Tank Level
7.1.1 HI Level [90% converted] feet
7.1.2 LO Level N/A
7.1.3 HI HI Level [TBD] feet
7.2 Process Wastewater Ventilation
7.2.1 WW Storage Exhaust Air Fan Online at all times
7.2.2 WW Storage duct pressure HI Level [XX] “ WC
7.3 Process Wastewater Hauling Volumes
7.3.1 Tanker 5,600 gal
7.3.2 Backhaul 4,600 gal
7.4 Process Wastewater Storage Containment Collected Precipitation Release
7.4.1 Conductivity high level 2,000 umhos
7.4.2 Visual clarity Clear, no discoloration, and free of oil sheen
7.4.3 Field pH 6.0 to 9.0 S.U.
Page 2 of 5
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8.0 Procedures
8.1 Process Wastewater Loadout
8.1.1 Allign the trailer with the ground level tipper
8.1.2 Position trailer on the tipper until meeting backstop and over containment area
8.1.3 Place tractor parking brake ON
8.1.4 Connect the process wastewater fill hose ensuring coupling are positively sealed
8.1.5 Driver opens tanker fill valves
8.1.6 Driver contacts control room and have the operator enable/start the following
8.1.6.1 Driver communicates loadout volume to control room operator
8.1.6.2 Control room operator selects fill volume based verified carrying capacity
8.1.6.2 Control room operator enables the Process Wastewater Loadout pump
8.1.6.3 Verify flow totalization increases/stops at fill volume setpoint
8.1.6.4 Manually disable Process Wastewater Loadout pump if setpoint exceeded
8.1.7 Driver closes tanker fill valves
8.1.8 Disconnect process wastewater fill hose and neatly place in storage location
8.1.9 Verify trailer / tanker is secure for roadway travel
8.1.10 Depart facility to unloading destination
8.2 Process Wastewater Storage

8.2.1 Monior liquid level from control room
8.2.2 Notify Site Manager if HI Level is meet for delivery arrival coordination
8.2.3 Contact / Coordinate contract liquid hauler as dicated by operational needs
8.2.4 Stop feed to dryer facility and complete processing of material if HI-HI level meet
8.3 Process Wastewater Containment

8.3.1 Daily visual inspect for leaks at penetrations and leak detection point
8.3.2 Precipitation Quality verification and release procedure
8.3.2.1 [To be developed and approved by PA DEP via NPDES Permit]
8.3.2.2 No release of collected precipitation allowed without DEP approval
8.4 Process Wastewater Storage Tank Odor Control

8.4.1 Ventilation line isolation damper open at all times during normal operation
8.4.2 During dryer facility shutdown and process wastewater stored
8.4.2.1 Maintain operation of Odor Control System
8.4.2.2 Ensure storage tank isolation damper is open allowing flow to OCS
8.4.3 During odor control system shutdown (planned or forced)
8.4.3.1 Stop feed to dryer, clear dryer, stop condensate pumps
8.4.3.2 Short duration, less than 48 hours, close tank vent isoloation valve
8.4.3.3 Long duration, coordinate temporary odor control system installation
Page 3 of 5
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8.5 Capture Pumpstation

8.5.1 Daily rounds to ensure carbon cartridge filter is securely attached to vent pipe
8.5.2 Replacement of carbon media in cartridge filter
8.5.2.1 Initial CMMS reoccuring work order for media replace each 4 months
8.5.2.2 Adjust media replacment frequency based on odor monitoring results
8.5.3 Normal operation with hatch open is not allowed
Date of
Revision/Review
1 2/14/2019 SBHRC
Page 4 of 5
Date: Doc Number:

Rev: 00
2/14/2019 CA - 012
11.0 Training Log
Procedure Name
Name Date Signature
Page 5 of 5
SLATE BELT HEAT RECOVERY CENTER, LLC
[##] Pen Argyl Road

Pen Argyl, PA 18072
TBD ph./TBD fx.
Date: January 2019
To: Synagro Drivers
Subject: Trailer Tarping, Truck Routes, and In-Route Stop Driver Agreement
__________________________________________________________________________________
All drivers must keep all trailers tarped at all times unless operating in the Slate Belt Heat Recovery Center
Facility receiving area. You are required by company policy to keep loaded and empty trailers tarped at all time
(with the only except for drivers who are required to remove their tarp when leaving trailers at treatment plants).
If you have mechanical difficulties that will not allow you to operate the trailer tarp you much contact
your supervisor immediately for clearance prior to transporting the trailer in question.
All truck traffic carrying loads into or out of the SBHRC facility are required to follow the designated and
approved truck route exiting from Interstate 78 or Interstate 80 in Wind Gap to travel on Rt. 33. From I78, use
Rt. 512 east to the GCSL access drive. From I80, use North Broadway in Wind Gap to Rt. 512 east. Trucks much
travel the same route when exiting the landfill and facility.
Under NO circumstances may any trucks travel Alpha Road, Pen Argyl Road, Delabole Road, or Grand Central
Road.
All in-route stops while transporting a loaded or empty trailer will not be permitted unless at a truck stop facility.
This rule applies to when a temporary diversion notification is received. The municipalities we work with have
regulations in place that are intended to keep bio-solids transportation within designated routes. Mechanical
breakdowns would be an exception to this requirement.
There is a ZERO tolerance policy in effect regarding this issue and we have had provided training and meetings
related to this. There will be NO EXCEPTIONS. Failure to comply with these requirements can result in
disciplinary action up to immediate termination!
PLEASE do everything you can to help keep all offsite trailers tarped and within their designated routes.
Thank you
Management
Date
Employee Signature
Employee Name (printed)

910 W. Pennsylvania Ave
Pen Argyl, Pa 18072 610.863.1399
APPROACH ROUTE
Traveling South:
 Follow PA-33 S to Wind Gap
 Take exit ramp for Wind Gap
 Make a LEFT off exit ramp.
 Follow N. Broadway St
approximately 1 mile
 At the light, make a LEFT onto
PA-512
 Follow PA-512 approximately
1.3 miles.
 Destination will be on the
RIGHT. Grand Central
Sanitary Landfill
Traveling North:
 Follow Pa-33 N to Wind Gap
 Take the PA-512 exit toward
Bath/Wind Gap
 Turn RIGHT onto Pa-512 N
and continue to follow
approximately 1.3 miles
 Destination will be on the
RIGHT.
Trucks must travel the same route when exiting the landfill.
Warning:
Under NO circumstances may any trucks travel Alpha Road, Pen Argyl Road, Delabole Road,
or Grand Central Road.
Any driver found to be in violation of the designated truck route requirements will be subject to
disciplinary action. Discipline may include banning driver from facility either temporarily or
permanently.
Please Obey All Posted Speed Limits and

Truck Traffic Directional Signs
Date: Doc Number:

Rev: 02
04/29/2019 CA - 002
TITLE SOP – Drying Facility Odor Control System Page: 1 of 7
1.0 Purpose
The following procedures relate to the control of odors both inside and outside the drying facility. Odor control is
part of our Core Mission at SBHRC with the goal of no odor nuisance conditions at the property boundary during
day-to-day operation. Odors leaving the facility have the potential to impact the surrounding community. It is our
responsibility to prevent this through operation of the odor control equipment and good housekeeping practices.
Odor control within the facility is important to the quality of our working environment and control of these odors
prevents odor excursions to the outside.
In general odor control and environmental compliance are dictated and required by the SBHRC Pennsylvania (PA)
Department of Environmental Protection (DEP) Air Permit; XXXXX.
2.0 Scope
2.1 Scope Statement
To ensure compliance with SBHRC Air Permit XXXXX and conditions agreed to with Plainfield
Township in accordance with potential nuisance mitigation and control.
2.2 Contents: Odor Control

1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
7.1 Equipment List: Odor Control
8.0 Procedures
8.1 Odor Control Management System
8.2 Summary of Odor Control System
8.2.1 Odor Control System Operating Parameters
8.3Summary of Dust Collection / Removal System
8.3.1 Dust Collection / Removal System Operating Parameters
8.4 Summary of Exhaust Air Fans
8.4.1 Exhaust Air Fan Operating Parameters
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards

3.1 Permit violations may result in
3.1.2 Significant fines
3.2 Odor complaints may result in
3.2.2 Damage to local confidence and relations
3.2.3 Significant fines and increased operating expense
Page 1 of 7
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NMCP – Nuisance Mitigation and Control Plan

Exception – a concern initiated via the Community Response Plan
OCS – Two stage wet Odor Control System to reduce odor compounds
ARP – Acid stage recirculation water pump
ADP- Acid dosing pump
CRP – Caustic stage recirculation water pump
CDP – Caustic dosing pump
EAF- Exhaust air fans; fans moving air within the enclosed process to another process and/or through scrubbers
OCF- Odor control fans; set of fans moving air out of the building through environmental control devices
5.1 All SBHRC operations management and staff are responsible to operate the plant within permit compliance and
to cease operations if unable to do so. In the event of permit issues, SBHRC operations is responsible to notify
the SBHRC Plant Manager.
5.2 The SBHRC Plant Manager is responsible for proper maintenance and operation of odor control systems, as they
are managed assets. For compliance on odor issues, the SBHRC Plant Manager is responsible for notification to
the Facility Area Manager and establish resolution of issues.
5.3 The SBHRC Plant Manager is responsible for any notifications resulting from compliance issues with Air Permit
XXXX.
6.0 Qualifications
All operators are to review these procedures as a part of standard training. There are no special qualifications beyond
standard site specific training
7.0 Equipment List and Operational Criticality

XXX Fan-1 #1 Unless Functional
XXX Fan 2 #2 Unless Functional
Do Not Operate Dryer
2 Stage Wet Removes NH3 & H2S From Dryer Facility Exhaust
OCS Ground Level Facility Unless
Scrubber Stream
Functional
OCF- Odor Control Exterior
Draws Air through Wet Odor Control System Facility Unless
XXX ID Fan South
Functional
Acid Stage Do Not Operate
ARP- Exterior
Recirc Pump Recirculates acid stage sump water Dryers Unless 1 ARP
XXX South
1 Is Operational
Page 2 of 7
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Acid Stage
ARP- Exterior
Recirc Pump Recirculates acid stage sump water
XXX South
2
ADP- Acid Dosing Inside
Meters acid solution to acid stage sump water Do Not Operate
XXX Pump 1 Ground Level
Dryers Unless 1 ADP
ADP- Acid Dosing Inside Is Operational
Meters acid solution to acid stage sump water
XXX Pump 2 Ground Level
Caustic Stage
CRP- Exterior
Recirc Pump Recirculates caustic stage sump water
XXX South Do Not Operate
1
Dryers Unless 1 CRP
Caustic Stage
CRP- Exterior Is Operational
Recirc Pump Recirculates caustic stage sump water
XXX South
2
Caustic
CDP- Inside
Dosing Pump Meters caustic solution to caustic stage sump water
XXX Ground Level Do Not Operate
1
Dryers Unless 1 CDP
Caustic
CDP- Inside Is Operational
Dosing Pump Meters caustic solution to caustic stage sump water
XXX Ground Level
2
EAF- Receiving
Conveys receiving unit air to OCS TBD Facility Unless
XXX Unit Fan
Functional
EAF- Baghouse ID Conveys air from conveyance and product storage to
TBD Facility Unless
XXX Fan the OCS
Functional
DC- Separates dust from the dry product conveyance and Stop Dryer Feed
Baghouse TBD
XXX storage air streams prior to treatment in the OCS Unless Functional
EAF- WW Storage Conveys air from process wastewater storage tank to
TBD Facility Unless
XXX Fan the OCS
Functional
Carbon Stormwater Do Not Operate
Exterior,
Cartridge Capture Pump Filter Device on Pump Station Vent Dryers Unless
South
Filter Station Operational
8.0 Procedures
8.1 Odor Control System Management
8.1.1 [UPDATE TO INCLUDE OEM SPECIFIC CONTENT WHEN AVAILABLE, SEE ATTACHED
AS EXAMPLE]
8.1.2 The OCS, dust collector, and ancillary associated equipment list in this SOP are all required to have
manufacturer’s equipment maintenance requirements, procedures, and intervals included in the
computerized maintenance management system (CMMS) to automatically generate work orders,
initiating maintenance, and requiring documented actions to close out the work order.
Page 3 of 7
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8.1.3 Data from online instrumentation recorded to the OCS Data Log and Facility Data Log are available
for NMCP documentation if required.
8.1.4 To facilitate routine communication between the Plant Manager, Lead Operator, and Lead Mechanic,
SBHRC will hold daily (weekday) operations meeting whenever possible. When not possible due to
illness, vacations, etc this will be communicated to SBHRC operations team by the Plant Manager.
8.1.5 SBHRC will maintain odor control compliance records and make available in accordance with the
NMCP. Exceptions will be communicated verbally in addition to a report following the NMCP
documentation requirements.
8.1.6 During abnormal events, an odor control plan shall be put in place. Typical precautions include
increased operator rounds, reduced operations, employment of rental OCS equipment, etc
8.2 Summary: Odor Control System - Wet Scrubbing
The OCS is primarily designed to reduce H2S (via acid stage) and NH3 (via caustic stage) from the exhaust
stream. The wet scrubber type OCS is the primary means of emissions control from the dryer facility to
maintain compliance with the emissions of H2S and NH3. The equipment has the secondary impact of
removing particulate solids due to the spray environment and arduous path.
8.2.1 Odor Control System - Operating Parameters
EQUIP # EQUIPMENT PARAMETER LOG INSTRUMENT MIN MAX UNITS

Solution
XXX OCS – Acid Stage OCS Data Log FE-XXX TBD TBD GPM
recirculation rate
Recirc solution
XXX OCS - Acid Stage OCS Data Log AE-XXX TBD TBD " S.U.
pH
Solution
XXX OCS – Caustic Stage OCS Data Log FE-XXX TBD TBD " GPM
recirculation rate
Recirc solution
XXX OCS – Caustic Stage OCS Data Log AE-XXX TBD TBD " S.U.
pH
8.3 Summary: Dry Product Dust Collection / Removal

Potential dust created from the conveying and storing dry product is drawn from the enclosed product side
of the dryer facility is removed by dust collector DC-XXX. The dust collector has bag filters that capture and
accumulate material ad serve as the filter agent.
8.3.1 Dry Product Dust Collection / Removal Operating Parameters:

Differential Pressure
XX Baghouse OCS Data Log dPE-XXX xx xx “ WC
across equipment
Page 4 of 7
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8.4 Summary: Exhaust Air Fans
Exhaust air streams are pulled from each dryer train separately and from downstream of the condenser
where evaporated water is removed from the system. Additionally, exhaust air is drawn by fans from the receiving
units, process wastewater storage tank, and dry product conveyance and silo storage systems. Pressure monitoring
within the ventilation duct system and at select equipment ensures potentially odorous air is flowing to the OCS.
Overall, the ventilation system is designed so that the duct system drawing air from the potentially odorous areas
remain under slight vacuum.
8.4.1 Exhaust Air Fans Operating Parameters:

Dryer 1 Facility Data
EAF-XX Current Draw AE-XXX xx xx Amp
Exhaust Fan Log
EAF-XX Fan Discharge Pressure PE-XXX X X " WC
Exhaust Fan Log
Dryer 1 Suction Duct Facility Data
xxx dPE-XXX X X " WC
Exhaust Differential Pressure Log
Exhaust Fan Log
Exhaust Fan Log
Dryer 2 Suction Duct Facility Data
Exhaust Differential Pressure Log
Receiving Unit Facility Data
Fan Log
Receiving Unit Facility Data
Fan Log
Baghouse ID Facility Data
Fan Log
Baghouse ID Facility Data
Fan Log
WW Storage Facility Data
Fan Log
Fan Log
Receiving Unit Suction Duct Facility Data
xxx dPE-XXX xx xx " WC
1 Differential Pressure Log
Receiving Unit Suction Duct Facility Data
2 Differential Pressure Log
Conveyance Facility Data
xxx Suction Duct Pressure PE-XXX X X " WC
Exhaust Header Log
Facility Data
xxx Silo Exhaust Suction Duct Pressure PE-XXX X X " WC
Log
xxx Suction Duct Pressure PE-XXX X X " WC
Exhaust Log
Page 5 of 7
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Rev: 02
04/29/2019 CA - 002

• OCS Operation and Maintenance Manual
• Dust Collector Operation and Maintenance Manual
• Exhaust Air Fans Operation and Maintenance Manual
• Dryer Facility Operation and Maintenance Manual
10.0 Revision Log

Date of
Revision/Review
1 12/27/2018 Initial
2 04/29/2019 SBHRC Draft NMCP
10
Page 6 of 7
Date: Doc Number:

Rev: 02
04/29/2019 CA - 002
11.0 Training Log
Odor Control
Form
CA - 002 Revision # 002
Number
Name Date Signature
Page 7 of 7
“Operation of the Odor Control System”
TO BE UPDATED AT STARTUP TO REFLECT ACTUAL

EQUIPMENT OPERATIONS
Objective: The objective of this document is to explain the proper procedure to safely
start-up, operate and shutdown the Odor Control System (OCS).
Required PPE: (Personal Protective Equipment): Steel Toe Boots and Eye Protection
are required. Gloves and Hearing Protection are left to the discretion of the operator.
“Odor Control System Operations”
Section Process Description
1. Start up of the Odor Control System (OCS).
2. Monitoring of the Odor Control System (OCS).
3. Shutting Down the Odor Control System (OCS).
2
1. “Start up of The Odor Control System” (OCS).
1.1 Open the Sulfuric Acid (H2SO4) ball valve (Figure 1). The ball valve is
located in the chemical containment area at the tank.
Figure 1
1.2 Open the Sodium Hypochlorite (NaCOL) ball valve (Figure 2). The ball
valve is located in the chemical containment area at the tank.
Figure 2
3
Open the Sodium Hydroxide (NaOH) ball valve (Figure 3). The ball
1.3
valve is located in the chemical containment area at the tank.
Figure 3
1.4 At the main control panel. Turn the main power disconnect switch
(Figure 4) to the on position. Note: The main power may already be on.
Figure 4
4
1.5 At the control panel, locate the switch labeled “H2SO4 Feeder” (Figure
5) and turn the selector switch to the “Auto” position.
Figure 5
1.6 At the control panel, locate the switch labeled “NaOH Feeder” (Figure
Figure 6
5
1.7 At the control panel, locate the switch labeled “NaOCI Feeder” (Figure
Figure 7
Note: The switches mentioned in the above steps (1.4-1.6) may already be in
the correct positions.
1.8 Open the potable water ball valves (Figure 8) feeding the sumps on
scrubbers stage 1 and stage 2. There is one ball valve per stage. The ball
valves are located at the bottom right hand side of each scrubber’s sump.
Figure 8
6
1.9 Makeup water flow to the sump of each scrubber is set at 1 – 3 GPM
and may be adjusted using the adjustable flow meters (Figure 9).
Figure 9
1.10 Check the water level at the inspection windows of both stages 1 and 2
sumps (Figure 10). The water level should be about half way to the top
of the window.
Figure 10
7
1.11 At the control panel, select the desired recirculation pump that is to be
run on stage 1. Do so by selecting position “A” or “B” at the control
panel stage 1 recirculation pump selector switch (Figure 11).
Figure 11
1.12 Open the ball valve (Figure 12) in-line above the corresponding
recirculation pump that has been selected to operate on stage 1.
Figure 12
8
1.13 At the control panel, locate the switch labeled “Scrubber No.1” (Figure
13) and turn the selector switch to the “Auto” position. Note: this switch
may already be in the “Auto” position.
Figure 13
1.14 At the control panel, select the desired recirculation pump that is to be
run on stage 2. Do so by selecting position “C” or “D” at the control
panel stage 2 recirculation pump selector switch (Figure 14).
Figure 14
9
Open the ball valve (Figure 15) in-line above the corresponding
1.15
recirculation pump that has been selected to operate on stage 2.
Figure 15
1.16 At the control panel, locate the switch labeled “Scrubber No.2” (Figure
16) and turn the selector switch to the “Auto” position. Note: this switch
may already be in the “Auto” position.
Figure 16
10
1.17 Locate the fan switch on the main control panel (Figure 17). To start the
fan, turn the fan switch to the “Hand” position. The fan (Figure 17.1)
will immediately start and the “Fan Running” light will illuminate in
green. Simultaneously, stage 1 and 2 recirculation pumps (Figures 12
and 15) will also start; along with all three chemical feed pumps.
Figure 17
Figure 17.1
11
1.18 Check for flow at the recirculation flow meters on both stages 1 (Figure
18) and 2 (Figure 18.1) located on the output line above the recirculation
pumps. The flow should be in the range of 100 – 150 GPM.
Figure 18 Figure 18.1
Start up of The Odor Control System is complete.
12
2. “Monitoring the Odor Control System” (OCS).
There are a few operational parameters that need regular monitoring to ensure
efficient operation of the OCS. This operational data is recorded and logged
hourly into the “Hourly Log” for the corresponding day during plant operation.
2.1 The pH of stage one scrubber (Figure 19) must be recorded into the
“Hourly Log” every hour during plant operation. The PH will be
automatically maintained within the parameters of TBD and TBD pH.
Obtain the reading from the display screen labeled stage one pH on the
main control panel.
Figure 19
2.2 The pH of stage two scrubber (Figure 20) must be recorded every hour
into the “Hourly Log” during plant operation. The pH will be
automatically maintained within the parameters of TBD and TBD.
Obtain the reading from the display screen labeled stage two pH on the
main control panel.
Figure 20
13
2.3 The recirculation flow rates for scrubber one and must be recorded every
hour into the “Hourly Log” during plant operation. These flow rates
should be kept between TBD and TBD gpm. The flow meters (Figures
18 and 18.1) are located above the recirculation pumps on each
scrubber.
14
3. “Shutting Down the Odor Control System” Shut
down the OCS in the following sequence:
3.1 Locate the fan switch on the main control panel (Figure 23). Turn the
fan switch to the off position. The fan will shut down and the green light
labeled fan running (Figure 23) will turn off indicating that the power to
the fan is off. Simultaneously, stage 1 and 2 recirculation pumps will
also shutdown as well as all three chemical feed pumps.
Figure 23
3.2 Close the potable water ball valves (Figure 24) to scrubber stage one and
scrubber stage 2. There is one ball valve per scrubber. The valves are
located at the bottom right hand side of each scrubber.
Figure 24
15
3.3 Close all chemical feed ball valves. There are three valves total. They
include: Sulfuric Acid (H2SO4) (Figure 25), Sodium Hypochlorite
(NaCOL) (Figure 25.1), and Sodium Hydroxide (NaOH) (Figure 25.2).
The valves are located between the chemical storage tanks and the
chemical feed pumps.
Figure 25 Figure 25.1
Figure 25.2
Shut Down of the OCS complete.
16
Date: Doc Number:

Rev: 002
7/24/2019 CA - 012
TITLE SOP – n-Butanol Odor Intensity Field Kit Requirements

Page: 1 of 6
Purpose, stock solution, field kits, and practices
1.0 Purpose
 To ensure an accurate and consistent scale (correct solutions) is used when judging the odor
intensity at the property boundary during preventive monitoring and while responding to odor
complaint response
 Provide verified supplier of stock solutions and associated scale concentrations
 Provided storage requirements and useful life of stock solution and Field Kit
 Provide description of perceived odor according to field kit scale
2.0 Contents
1.0 Purpose
3.0 Risks & Hazards
6.0 Approved Vendors
7.0 Procedures
8.0 Concentration Scale and Perceived Odor
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards

o Exposure to 1-Butanol
 Not a listed carcinogen and does not case lasting damage in case of accidental
moderate overdose
 Irritant for eyes, skin, and respiratory tract. Prolonged inhalation or ingestion
causes dizziness and narcosis.
o OSHA workplace TLV (Threshold Limit Value) of 100 ppm (300 mg/m3). 8 hour time
weighted average.

Odor Intensity Scale: 8-point n—Butanol Odor Intensity static scale
Site Manager – Manager of the SBHRC project
Page 1 of 6
Date: Doc Number:

Rev: 002
7/24/2019 CA - 012

Page: 2 of 6
Site Manager is responsible for ensuring that stock solution is available for the replenishing the field kits
and stock solution is obtained from an approved vendor.
All odor trained staff are responsible for using and returning the field kit to the storage located after each
monitoring event.
All odor trained staff are responsible for returning the stock solution to refrigeration after replenishing
the field kit.
6.0 Approved Vendors
Odor Science and Engineering, Inc

105 Filley Street
Bloomfield, CT 06002
Phone: 860-243-9380
Fax: 860-243-9431
7.0 Procedures
7.1 Stock solution
7.1.1 Stock Solution 1 through 4 Prepared by OSE and provided to SBHRC
7.1.2 Requalification stock solution representative of 10 ppm of 1-butanol in air
7.1.3 Store refrigerated
7.1.4 3-months storage life
7.2 Field Kit
7.2.1 Portable butanol field kit thermal insulated bag includes
7.2.1.1 Odor Scale bottles 1 through 4
7.2.1.2 125 mL bottle made amber glass with teflon cap, stainless steel, or
equivalent
7.2.2 Carbon filter respirator
7.2.3 Store butanol field kit at room temperature, in thermal insulated bag
7.2.4 1-month storage life
7.2.5 To Replenish field kit bottle from stock solution
7.2.5.1 Use graduated cylinder to fill bottle 1 with 25 mL of stock solution 1,
tightly cap bottle
Page 2 of 6
Date: Doc Number:

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Page: 3 of 6
7.2.5.2 Repeat for bottles 2 through 4

7.2.5.3 Remaining volume is headspace for sniffing
7.3 Trained assessor requalification
7.3.1 Requires 1 trained assessor and 1 SBHRC staff test administer
7.3.2 Conduct inside in controlled environment
7.3.3 Test bottle preparation
7.3.3.1 All typical 125 mL bottles, matching without indication
7.3.3.2 One bottle to be identified as the “requalification bottle” - use graduated
cylinder to fill with 25 mL of requalification stock solution 1, tightly cap
bottle
7.3.3.3 Two bottles – use graduated cylinder to fill with 25 mL of de-ionized
water
7.3.4 Test administration, each round – Conduct three times
7.3.4.1 Blind test selection by potential assessor
7.3.4.2 Test administer presents three bottles in random order
7.3.4.3 Potential assessor identifies one bottle as the “requalification bottle”
7.3.4.4 Potential assessor must identify “requalification bottle” correctly three
times
7.3.5 Notify Site Manager if olfactory lacks sensitivity for the day
7.3.6 Repeat to identify requalified trained assessor
Page 3 of 6
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Page: 4 of 6
8.0 Concentration Scale and Perceived Odor
Page 4 of 6
Date: Doc Number:

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Page: 5 of 6
ASTM E544-18
Facility SBRHC Revision/Review History Log

# Date of
Description/Author
Revision/Review
7/24/2019 SBHRC NMCP
1
10
Page 5 of 6
Date: Doc Number:

Rev: 002
7/24/2019 CA - 012

Page: 6 of 6
11.0 Training Log
Name Date Signature
Page 6 of 6
Doc Number:
Date: 1/3/2019 Rev: 00
CA - 011
TITLE SOP – Backup Power Procedures Page: 1 of 6
1.0 Purpose
This procedure sets forth the expectations for Slate Belt Heat Recovery Center (SBHRC) and
their responsible employees. It is intended to provide reasonable guidance to meet Community,
Regulatory and Company requirements for operating during a utility power disruption and if
necessary on the backup power supply.
2.0 Scope
2.1 Scope Statement
This procedure covers the activities necessary to ensure operators understand how the facility is
programmed and configured to automatically respond to a utility power disruption. Manual
verification is required and intervention may be necessary to regain full supply to the system.
2.2 Contents:
1.0 Purpose/Summary
2.0 Scope/Contents
2.1 Scope Statement
3.0 Risks & Hazards
6.0 Qualifications
8.0 Procedures
8.1 Normal Backup Generator Exercise Inspection
8.2 System connected to backup and restart requirements
8.3 Control Panel UPS backup
8.4 Audio / Visual inspections after transfer to backup power
10.0 Revision Log
11.0 Training Log
3.0 Risks & Hazards
3.1 Failure to transfer to back up properly
3.1.1 Partially processed material in the dryer
3.1.2 odor concerns
3.1.3 fall hazards without lighting
3.2.1 Hard Hat
Page 1 of 6
Doc Number:
Date: 1/3/2019 Rev: 00
CA - 011

4.3 UPS: Uninterrupted Power Supply
4.4 ATS: Automatic Transfer Switch
5.1 SBHRC Operations is responsible for operating and maintaining the backup power systems
as prescribed in the [generator] O&M manual.
5.2 Each of the plant areas (heat recovery, receiving, drying, product storage, and process
wastewater) will have an operator identified to conduct audio visual inspection after transfer
to back up power systems.
5.3 SBHRC Site Manager is responsible for providing a safe work environment and the tools
necessary to ensure maintenance is completed on time and safely.
6.0 Qualifications
All operators should review these procedures as a part of standard annual training. A
generator manufacturers training will be held and attended by all operators during facility
commissioning.

7.1 Back up Generator [To be provided by generator manufacturer]
7.1.1
7.1.2
7.2 ATS Operating Parameters [to be provided by ATS manufacturer]
7.2.1 Maximum Transfer Delay – 20 seconds
7.2.2
7.3 TBD
7.3.1
7.3.2
Page 2 of 6
Doc Number:
Date: 1/3/2019 Rev: 00
CA - 011
8.0 Procedures
8.1 Backup Power Generator Exercise Inspection
8.1.1 Pre-programmed exercise in OEM panel, per manufacturers recommendations
8.1.2 Conduct Audio / Visual inspection during exercise routine
8.1.3 Report issues, if found, to site manager
8.1.4 Conduct under load, once per year, verifying:
8.1.4.1 Proper ATS operation
8.1.4.2 Proper load pickup sequence
8.1.4.3 Proper return to normal sequence
8.2 Back Up Power Response
8.2.1 Site manager places diversion notification to all inbound loads

8.2.2 Equipment restart sequence [TO BE COMPLETED WITH VENDOR INPUT
AND REQUIREMENTS]
Automatic Equipment Delay Manual Status

Sequence [TBD] Check
1 OCS ID Fan At CP and Local
1 OCS Recirc Pumps At CP and Local
1 OCS Dosing Pumps At CP and Local
1 OCS Instruments At CP and Local
2 Receiving Unit Exhaust Fan At CP and Local
3 Dust collector Fan At CP and Local
TBD Dryer Line 1 System At CP
TBD Dry Line 2 System At CP
TBD Thermal Oil Heating and Transfer At CP and Local
System
TBD Product Conveyance Systems At CP
TBD Product Storage Systems At CP
TBD Process Wastewater Storage At CP
Systems
TB Receiving Systems At CP
D
8.2.3 Site Manager checks with GCSL of scale house status

8.2.4 With GCSL approval, Site Manager lifts inbound diversion notification
8.3 Control Panel UPS Backup

8.3.1 Control panels have back up power supplies to ride through disruption
8.3.2 Notify Site Manager immediately if UPS fails to power field control panel
Page 3 of 6
Doc Number:
Date: 1/3/2019 Rev: 00
CA - 011
8.3.3 Do not bypass UPS supplies in field control panels for any reason
8.4 Audio / Visual inspetion after transfer to back up power

8.4.1 This is an all hands on deck situation
8.4.2 Control room operator will observe systems coming online as sequenced
8.4.3 Control room operator will notify field operator of system status
8.4.4 Field operator will conduct area audio / visual inspection when requested
8.4.5 Field operator will report back to Control room operator and Site Manager
Date of
Revision/Review
1 1/3/2019 SBHRC – draft NMCP
Page 4 of 6
Doc Number:
Date: 1/3/2019 Rev: 00
CA - 011
10
11.0 Training Log
Page 5 of 6
Doc Number:
Date: 1/3/2019 Rev: 00
CA - 011
Procedure Name
Name Date Signature
Page 6 of 6
Professional Odor Training Table of Contents
07/24/2019
Odor Monitoring and Complaint Odor Investigation Techniques
Course Outline
Introduction
1.0 The Properties of Odor
1.1 Odor Concentration

1.2 Odor Intensity
1.3 Odor Character
1.4 Hedonic Tone
2.0 Odor Measurement Methodology
2.1 Source Emission Sampling

2.2 Measurement of Odor Concentration by Dynamic Dilution
Olfactometry
2.4 Measurement of Odor Intensity
2.5 Instrumental Analysis
3.0 Meteorological Factors Affecting Odor Dispersion
3.1 Atmospheric Stability

3.2 Influence of Local Terrain
3.3 Source Characteristics
4.0 Odor Monitoring/Complaint Response
4.1 Preventative Monitoring Procedures and Forms

4.2 Odor Monitoring Procedures and Forms
4.3 Odor Complaint Investigation Procedures and Forms
4.4 Monitoring and Response Timeframe Commitments
5.0 Olfactory Screening of Course Participants
6.0 Training on the use of the n-butanol Odor Intensity Scale

6.1 Single Observer Valid Judgement Procedures
6.2 Use of Carbon Mask Filtration During Observations
7.0 Field Training
Odor Science & Engineering, Inc. 105 Filley Street Bloomfield, CT 06002
Phone:(860) 243-9380 Fax: (860) 243-9431 www.odorscience.com
Prevention, Preparedness, and Contingency Plan (PP&C Plan)
[THE PP&C PLAN SUBMITTED TO PA DEP ON MARCH 20, 2018 AS PART OF THE GENERAL
PERMIT APPLICATION HAS BEEN ATTACHED TO THE PREVIOUS DRAFT NMCP VERSIONS. THE
DOCUMENT HAS NOT BEEN UPDATED AT THE TIME OFTHIS DRAFT NMCP DEVELOPMENT, DUE
TO PENDING PA DEP COMMENTS. THEREFORE, THE ATTACHMENT IS WITHHELD AT THIS TIME.
THE FINAL PADEP APPROVED PPC PLAN WILL BE INCLUDED IN THE FINAL NMCP]
07/24/2019
Attachment C – Complaint Response
Community Response Program

[A COMPLAINT LOCATION LOG MAP WILL BE DEVELOPED AND INCLUDED TO SHOW THE AREA
WITHIN 1 MILE RADIUS OF THE SBHRC PROJECT SITE, WITH A SCALE AT LEAST 1” = 1000 FEET.
TO BE INCLUDED IN NMCP PRIOR TO SUBSTANTIAL COMPLETION]
07/24/2019
Slate Belt Heat Recovery Center
Community Response Program
The Community Response Program has been developed to understand, respond and follow up on
complaints received by the Slate Belt Heat Recovery Center (SBHRC) Facility. The program
utilizes an Employee/Community Response Training Program as well as a Facility Contact Sheet
and the Complaint Response Form.
The Facility Contact Sheet (attached) has been designed for distribution to the community to allow
for ease in answering questions about the facility as well as for reporting of complaints. The sheet
contains the names and phone numbers for a citizen to properly report an event to the facility. The
form also contains a list of information which will be recorded by the facility during the reporting of
a complaint, which will aid in the response efforts.
The Complaint and Response Form (attached) will be maintained at the SBHRC with copies
available at the facility for review. This form will be completed by a trained employee who receives
the phone call. The form will document information to accurately identify the caller, time of the
event, place of the event, duration of the event, weather conditions and facility operation at the time
of the event. The form will also contain information for the employee to properly report the event to
management for additional investigation.
The employee training program consists of training for new responsible employees and annual
refresher training for all responsible employees. Specifically, the training will involve a complete
understanding of the Community Response Program, identification of where the complaint log book
is maintained and the proper procedures for recording and responding to a complaint. Training will
also include the identification of facility operating conditions which may lead to a complaint.
The Site Manager will oversee the Community Response Program and ensure that the facility is
proactive in identifying the cause and providing a follow up to community complaints received at
the facility. The Senior Technical Services Manager will be involved in all community complaints
and the response thereof.
__________________________________
Site Manager
July 2019
CONTACT SHEET
For general information or to phone in a concern, please call Monday through Friday between the hours
of 8:00 am to 5:00 pm. EST.
SBHRC Facility (xxx) xxx-xxxx
If the call is related to a complaint, please ask for the Site Manager or the General Manager during normal
business hours. If you do not reach an employee, please leave your name and phone number on the
facility’s voicemail system. During off hours, you may contact the following individual’s 24-hours a day:
Site Manager xxx-xxx-xxxx (Primary)

Lead Operator xxx-xxx-xxxx (Back-up)
When reporting a complaint, providing the following information will assist the facility in conducting a
complete investigation:
 name, address and phone number of caller

 nature of event (odor, noise, dust...)
 location of event
 time/duration of event
 description/characteristics
The facility will investigate all complaints reported and notify the person reporting the event of the
results of the facility investigation.
If there is any trouble in reporting a complaint, please notify:
Sr. Technical Services Manager xxx-xxx-xxxx
July 2019
COMMUNITY COMPLAINT AND RESPONSE FORM
__________________________ ___________/___________
Employee Handling Call Date/Time
1. Ask the caller for the following information: Name: __________________________________________

Address: __________________________________________
Phone: __________________________________________
2. Ask the caller the following questions and fill in the space provided:
What is the complaint about? Odor ________ , Noise ________, Other (describe)______________________
Where did you first detect the (odor, noise, other)? _______________________________________________
At what time did you first notice the (odor, noise, other)? ____________ Is it still present? _______________
If complaint related to truck, provide the vehicle number? ___________ What direction of travel? _________
3. If the complaint concerns an odor, continue with the following, otherwise continue with step 4:
Ask the caller does the odor smell like any of the following? I will read a list, please answer yes or no.
Yes No Yes No Yes No

Sweet ___ ___ Garlic ___ ___ Ammonia ___ ___
Smoky ___ ___ Diesel Fuel ___ ___ Septic Tank ___ ___
Sharp ___ ___ Bleach ___ ___ Dead Animal ___ ___
Rotten Eggs ___ ___ Soap ___ ___ Manure ___ ___
Low Tide ___ ___ Perfume ___ ___ Burnt Rubber ___ ___
Fishy ___ ___ Kerosene ___ ___ Gasoline ___ ___
Damp Earth ___ ___ Paint Thinner ___ ___ Garbage ___ ___
Bacon Grease ___ ___ Other (describe)________________________________________
4. Conduct nuisance complaint response according to the NMCP outlined procedure.
5. Thank you for calling the Slate Belt Heat Recovery Center Facility. This complaint will be referred to management and a
trained staff member will, (state one)
Investigate the identified vehicle for association with

Begin the investigation from detected location OR
SBHRC activities and, if so, the potential condition
The management will contact you and the Managers of Plainfield Township and Penn Argyl Borough after the
investigation has been completed.
6. Notify the Site Manager and Grand Central Sanitary Landfill immediately of a complaint and provide this completed Form.
7. Notify Plainfield Township and Pen Argyl Borough by email immediately of a complaint and provide this completed Form.
manager@plainfieldtownship.org manager@penargylborough.com
8. Identify, by way of clear marking, compliant location on the Community Response Plan – Complaint Location Log Map
9. Site Manager to document investigation in accordance with the compliant response documentation, in addition to this
Completed Form, indicating actions taken in response to the complaint, verification of effectiveness of actions taken, as well
as any feedback from the complaint after corrective action was taken
July 2019
POINTS TO REMEMBER WHEN DEALING WITH A COMMUNITY COMPLAINT
1. The individual that is calling is concerned about an odor, dust, noise or other nuisance
which they have detected in their home/neighborhood.
2. If the caller is upset, remain calm and be professional at all times.
3. Inform the individual that in order to accurately assess the cause of the problem, you will
need to obtain some information.
4. Proceed to the Community Complaint and Response Form and fill out as accurately as
possible.
5. If the caller terminates the call, please complete the form as accurately as possible with
the information obtained.
**NOTES**
Handling of complaint calls should be performed in the order listed below, depending
upon who is available at the time of the call.
1. Site Manager
2. Lead Operator
In any event, the Site Manager must be immediately notified of a community complaint.
July 2019
Complaint Response Checklists
 Odor Complaint Response Procedure
 Noise Complaint Response Procedure
 Dust Complaint Response Procedure
The complaint response procedures provide the required actions and decisions factors that SBHRC will
make when responding to a complaint. Each step has been provided with a target time for the step to be
completed from either the time of the received complaint or an prior step initiating a continuation of effort
to identify the potential source.
07/24/2019
Community Response Instructions for investigations,
Community data collection, documentation, and
Program (CRP) Complaint and corrective actions must be completed
for any odor compliant made
Odor Response Form Referencing the SBHRC
Contact info
must be kept
Facility Contact
current Sheet
As per Weather and Odor

CRP Professional Odor
Check‐ Facility Data Investigations for
List
Support
Collection SOP Compliance
All odor complaints must be investigated
to a data‐supported conclusion that:
Identify Source &
• The SBHRC is not the cause, or Response Plan
• Std. SOP corrective actions will resolve, or Implement Plan
• Additional measures are necessary, and
• All corrective actions are completed
ODOR COMPLAINT RESPONSE PROCEDURE
Facility Equipment Requirement
Odor Intensity Quantification & Characterization

 8-point n-Butanol odor intensity quantification per ASTM Method E-544-18
 8-point n-Butanol field kit
 Carbon filter respirator (if necessary)
 Complaint Response Training: All employees at onboarding and annual refresher training
Handheld Hydrogen Sulfide meter with specification:

 Range: 0.01 -3 ppm H2S
 Accuracy: 0.001 ppm H2S, or 5% of measure
I. Facility Odor Complaint - Initial Responses Target time Status Date
from end of Completed
call
O-1 Receive odor complaint and document on Complaint 15 minutes
Form
O-2 Deploy trained staff to location of odor complaint: 30 minutes
o Conduct investigation beginning at step O-4
O-3 Provide notice of complaint and response status to: 30 minutes
o Managers of Plainfield Township and Pen Argyl
Borough
o GCSL Site Manager
II. Facility directed follow-up actions when a complaint Target Status Date
occurs completion Completed
time from O-1
O-4 Conduct investigation in the upwind direction from the 4 hours
complaint location to identify potential source.
o Record odor intensity and character at complaint
location
O-4a If odor source identified as other than SBHRC activity:
o Compile documentation listed in O-16 thru O-18 24 hours
o Communicate according to step O-28 2 days
O-4b If SBHRC identified as potential odor source:
o Conduct H2S monitoring in steps O-5a thru O-5c Per O-5a thru
o Add to Facility Complaint Log O-5c
o Initiate site investigation and actions beginning at
Step O-8 24 hours
o Compile documentation listed in O-16 thru O-23 3 days
o Communicate according to step O-29
O-5a Conduct monitoring and record instantaneous H2S reading 6 hours
on property boundary in direction of complaint PPM
o Record reading in status column
O-5b Conduct monitoring and record instantaneous H2S reading at 6 hours
upwind property boundary PPM
o Record reading in status column
O-5c Conduct 1-hour handheld automated H2S monitoring on 7 hours
property boundary in direction of complaint.
o Verify equipment data logging initiated
o Save output data table to complaint file
07/24/2019
O-5d Conduct 1-hour handheld automated H2S monitoring on 8 hours
property boundary on upwind property boundary
o Verify equipment data logging initiated
o Save output data table to complaint file
O-6a If all of the following conditions are met as a result of odor 5 days
complaints document in step O-1
o Received odor complaints for 3 consecutive days
originating from the downwind compass quadrant
o Investigation from steps O-4a and O-4b do not
verify a potential source, all complaints
Then:
o Site Manager notifies Regional Manager to initiate
trained offsite staff odor investigation according to
steps O-4, O-4a, and O-4b
O-6b If all of the following conditions are met as a result of odor 7- 10 days
complaints documented in step O-1:
o Received 7 verified complaints out of 10
consecutive days originating from the downwind
compass quadrant
o Investigation from steps O-4a, O-4b, and O-6a do
not verify a potential source, all complaints
Then: Execution
o Initiate Professional Odor Support beginning at schedule begins
Step O-9 at step O-9
III. Facility directed follow-up actions if staff verify SBHRC Target Status Date
is the source completion time Completed
from O-4b
O-7 Identify potential odor source through site investigation: 6 hours
o Review daily housekeeping log for potential source
identification, conduct housekeeping to correct
o Investigate Operational Nuisance Mitigation and
Control Focus Areas to confirm operational
indicator
o Verify all NMCP SOPs are being followed 24 hours
o Refresher train for identified deficiencies 3 days
O-8 Conduct root cause evaluation, develop Corrective Action 2 days
Plan (CAP), and list initial corrective actions taken
o Generate Maintenance Management System work As per schedule
order focused on CAP (if required) in CAP
o Complete CAP identified actions
07/24/2019
Professional Odor Support Activities
Services provided by prequalified Professional Odor Support specialist, such as Odor Science and Engineering, Inc:
o Measurement technique: Field dilution olfactometer measurement of odor concentration (D/T)
o 8-point n-Butanol odor intensity quantification per ASTM Method E-544-10
o Odor characterization
o Odor source determination
IV. Response and actions when Professional Odor Support Target Status Date
conditions are met completion time Completed
from O-6b
O-9 Notify prequalified Professional Odor Support that services -2 days
are required.
O-10 Notify Township and Borough that Professional Odor -1 days
Support has been put on notice of re-occurring condition
O-11 Notify Township and Borough of Professional Odor When confirmed
Support site investigation start, confirm O-9
O-12a Professional Odor Support conducts odor surveys during 7 days
one morning, one mid-day, and one evening time period.
If complaint location odor characteristic does not match
biosolids thermal drying facility odor characteristic, then:
o Odor surveys focus on source identification only
o Compile documentation listed in O-24
o Communicate according to step O-30
O-12b If complaint location odor characteristic matches biosolids 7 days
thermal drying facility then odor surveys focus on source
identification, then:
o Proceed to response actions listed in Step
O-13
o Compile documentation listed in O-24 Execution
thru O-27 schedule begins
o Communicate according to step O-31 in step O-13
V. Response Action if Professional Odor Support verifies Target Status Date

SBHRC to be the source: completion time Completed
from O-12b
O-13 Conduct root cause evaluation and develop Phase II 14 days
Corrective Action Plan (P2-CAP) and
o Generate Maintenance Management System work As per P2-CAP
order focused on corrective action (if required)
O-14 If no operational corrective action effective, then evaluate As per P2-CAP
solution alternatives, up to contracting services of State of
PA Registered PE
O-15 Identify and implement feasible alternative, potentially As per P2-CAP
including capital investment
VI. Minimum documentation Supporting an Odor Investigation Status Date

Completed
O-16 Community Response Plan complaint form and complaint map identification
O-17 Trained staff upwind path investigation findings from complaint location
O-18 Prior 12 hours weather station data table output
o Additional Documentation if staff verify SBHRC is the source Status Date
Completed
07/24/2019
O-19 Odor monitoring equipment data table output and property boundary
location/time/duration from step O-5c and O-5d
O-20 Prior 12 hours OCS Datalog including scrubber flow and pH and pressure drop
trend charts
O-21 Prior 12 hours SBHRC Truck Arrival / Departure Log
O-22 Facility history including tipper position, loadout valve position, recycle air
differential pressure
O-23 Root cause evaluation and CAP (i.e. Work orders for equipment related
corrective actions, evaluation report, etc)
o Minimum documentation from Professional Odor Support Status Date
Completed
O-24 Professional Odor Support analysis provided to SBHRC
o Additional Documentation if Professional Odor Support identifies SBHRC Status Date
to be the source Completed
O-25 Root cause deep dive and development of Corrective Action Plan (i.e. Work
Orders for equipment related corrective actions, evaluation report, etc)
O-26 Solution Alternatives Report Recommendation, if applicable
O-27 Solution Implementation Schedule, if applicable
VII. Communications Target Status Date

o When staff identify a source other than SBHRC completion Completed
time
O-28 Communicate complaint response findings to Managers at Per O-4a
Township and Borough, via email, to include the following
o Complaint Form
o Summarize findings of O-4a investigations
o Summarize findings of O-5a thru O-5d monitoring
o Summarize weather conditions for 12 hour period prior
to receipt of complaint
o List documentation identified in steps O-16 thru O-18
will be available onsite for review
o Conclude SBHRC activities are not found to be source
and complaint response actions are complete
o When staff identify and verify SBHRC as the source
O-29 Communicate complaint response findings to Managers at Per O-4b
o Complaint Form
o Summarize findings of O-4b investigations
o Summarize findings of O-5a thru O-5d monitoring
o Summarize results and CAP from step O-8
o List documentation identified in O-16 thru O-23 will be
available onsite for review
o Conclude the information pertaining to activities and
status of the CAP are available onsite for review.
07/24/2019
o When Professional Odor Support identify a source other Target Status Date
than SBHRC completion Completed
time
O-30 Communication Professional Odor Support findings to Managers Per O-12a

at Township and Borough, via email, to include the following:
o Summarize odor survey findings from step O-12a
o State the Professional Odor Analysis will be available
onsite for review per step O-24
o When Professional Odor Support verifies SBHRC as the source
O-31 Communication Professional Odor Support findings to Managers Per O-12b
at Township and Borough, via email, to include the following:
o Summarize odor survey findings from step O-12b
o State the Professional Odor Analysis will be available
onsite for review per step O-X
o Summarize results and CAP from step O-13
o List documentation identified in O-24 thru O-27 will be
07/24/2019
for any noise compliant made
Noise Response Form Referencing the SBHRC
Contact info
must be kept
Facility Contact
current Sheet
As per Weather and Noise

CRP Additional Testing
List
if Unresolved
All noise complaints must be investigated
Identify Source &
NOISE COMPLAINT RESPONSE PROCEDURE
Facility Equipment Requirement
Handheld decibel measurement device

 Range: 30 dBA – 130 dBA
 Accuracy: +/- 2 dBA
I. Noise Complaint – Initial Response Target time Status Date

call
N-1 Receive noise complaint and document on Complaint Form 15 minutes
N-2 Provide notice of complaint and response status to: 30 minutes
Borough
o GCSL Site Manager
II. Facility directed follow-up actions when noise complaint Target Measure
occurs completion
time from N-1
N-3 Handheld monitoring on property line in direction of complaint 4 hours
If measure equal to or less than 70 dBA then:
o Document maximum instant reading
o Monitoring complete file this as documentation
o Communicate according to Step N-12 2 days dBA
N-4 If property boundary measure greater than 70 dBA then: 4 hours dBA
o Proceed with Step N-5a/b dBA
o Coordinate with staff assistant for source investigation dBA
/ identification dBA
o Remain in place, continue monitoring; dBA
o Document noise level at location each 5 minutes, up to dBA
30 minutes dBA
o Communication according to step N-13 3 days
III. Facility directed follow-up actions if SBHRC verified to be Target Status Date
the source completion Completed
time from N-4
N-5a Identify if noise greater than 70 dBA measured from thermal 4 hours
drying process
o Contact Second Staff to identify source based on
location and operating equipment
o Verify all outside doors are closed
o Power off non-essential equipment loads
o Add to Facility Complaint Log
N-5b Identify if noise greater than 70 dBA measured and source is 4 hours
outdoor equipment
o Power off non-essential equipment, i.e. temporary
equipment
o Work with temporary equipment vendors to provide
solution
o Add to Facility Complaint Log
07/24/2019
N-6 Conduct root cause evaluation, develop corrective action plan 2 days
(CAP), and list initial corrective actions taken
o Generate Maintenance Management System work As per
order focused on corrective action (if required) schedule in
o Complete CAP identified actions CAP
IV. Minimum documentation supporting a noise complaint investigation Status Date
Completed
N-7 Community Response Plan complaint form and map identification
N-8 Prior 12 hour weather data (wind direction, speed, air temperature, and relative
humidity) from time of monitoring event
N-9 Prior 12 hours Facility History including hourly throughput, tipper position, and
heat source utilization
o Additional documentation if SBHRC verified to be the source Status Date
Completed
N-10 Noise monitoring equipment data table output and site location/time/duration
N-11 Root cause and CAP (i.e. Work orders for equipment related corrective actions,
evaluation report, etc
V. Communications Target Status Date

completion time Completed
N-12 Communicate complaint response findings to Managers at Per N-3
o Complaint Form
o Summarize findings of N-3 investigations
o Summarize weather conditions for 12 hour period
prior to receipt of complaint
o List documentation identified in steps N-7 thru N-9
o Conclude SBHRC activities are not found to be
source and complaint response actions are complete
N-13 Communicate complaint response findings to Managers at Per N-4
o Complaint Form and
o Summarize findings of N-4 investigations
o Summarize findings of N-5a and/or N-5b Per CAP
investigation
o Summarize results and CAP from step N-6
o List documentation identified in N-7 thru N-11 will
be available onsite for review
o Conclude the information pertaining to activities
and status of the CAP are available onsite for
review.
07/24/2019
for any dust compliant made
Dust Response Form Referencing the SBHRC
Contact info
must be kept
Facility Contact
current Sheet
As per Weather and Dust

CRP Additional Testing
List
if Unresolved
All dust complaints must be investigated
Identify Source &
DUST COMPLAINT RESPONSE PROCEDURE
Methodology
EPA Method 9 Visual Emissions (VE)

 Staff Certification: Per EPA Method 9 Requirements
 VE Observation Forms / Clipboard / Pen
 Stopwatch / Timer
I. Dust complaint – Initial Response Target time Status Date

call
D-1 Receive dust complaint and document on Complaint Form 15 minutes
D-2 Deploy trained staff to location of dust complaint. 30 minutes
o Conduct investigation beginning at step D-4
D-3 Provide notice of complaint and response status to: 30 minutes
Borough
o GCSL Site Manager
II. Facility directed follow-up actions when dust complaint Target Status Date
occurs completion Completed
time from D-1
D-4 Conduct investigation in the upwind direction from the 3 hours
complaint location to identify potential source
D-4a If dust source identified to be other than SBHRC activity:
o Compile documentation listed in D-7 thru D-9 24 hours
o Communicate according to step D-15 2 days
D-4b If SBHRC identified as potential dust source 6 hours
o Conduct visual emissions at stack and property
boundary
o Add to Facility Complaint Log 24 hours
o Compile documentation listed in D-7 thru D-14 3 days
o Communication according to step D-16
III. Facility directed follow-up if SBHRC verified to be the Target Status Date
source completion Completed
time from D-
4b
D-5 Identify source through site investigation 6 hours
o Review daily housekeeping log for potential source
identification, conduct housekeeping to correct
o Investigate Nuisance Mitigation and Control Focus
Areas to confirm operational indicators
D-6 Conduct root cause evaluation, develop corrective action plan 2 days
(CAP), and list initial corrective actions taken
o Generate Maintenance Management System work As per schedule
order focused on corrective action (if required) in CAP
o Complete CAP identified actions
IV. Minimum documentation supporting a dust complaint investigation Status Date

Completed
D-7 Community Response Plan complaint form and map identification
D-8 Compiled staff EPA Method 9 naked eye visual observations of property
boundary emissions
D-9 Prior 12 hour weather data (wind direction, speed, air temperature, and relative
07/24/2019
humidity) from time of monitoring event
- Additional documentation if staff verify SBHRC to be the source Status Date
Completed
D-10 Prior 4 weeks dust collector weekly pressure drop
D-11 Prior 12 hours Facility History including hourly throughput and loadout valve
position
D-12 Prior 12 hours SBHRC Truck Arrival / Departure Log
D-13 Prior 7 days Daily Housekeeping Log dust observations
D-14 Root cause evaluation and CAP (i.e. Work orders for equipment related
corrective actions, evaluation report, etc)
V. Communications Target Status Date

completion Completed
time
D-15 Communicate complaint response findings to Managers at Per D-4a
o Complaint Form
o Summarize findings of D-4a investigations
o Summarize weather conditions for 12 hour period prior
to receipt of complaint
o List documentation identified in steps D-7 thru D-9
D-16 Communicate complaint response findings to Managers at Per D-6
o Complaint Form
o Summarize findings of D-4b investigations
o Summarize findings of D-5 investigation
o Summarize results and CAP from step D-6
o List documentation identified in D-7 thru D-14 will be
07/24/2019
Professional Odor Support Methodology
07/24/2019
O
Odor Science & Engineering, Inc.
S&E 105 Filley Street, Bloomfield, CT 06002
(860) 243-9380 Fax: (860) 243-9431
www.odorscience.com
Professional Odor Support Activities

Slate Belt Heat Recovery Center (SBHRC)
Once notified by Synagro that Professional Odor Support is required to determine the source(s) of off-site
odors, Odor Science & Engineering, Inc. (OS&E) will schedule a site visit to conduct an odor investigation.
This will be accomplished by conducting a series of systematic odor surveys in the area surrounding the
Synagro site including the complaint location.
The surveys will be carried out an OS&E Odor Scientist with extensive experience in quantification and
characterization of ambient odors. During the surveys, the concentration, intensity, character, and the likely
source of any odor detected during these surveys will be documented along with the meteorological conditions.
Odor concentration, in terms of dilution-to-threshold (D/T) ratio, will be measured using a Scentometer. Odor
intensity will be measured by comparison with the 8-point butanol intensity reference scale in accordance
with ASTM Method E-544-18. The ambient odor measurement methods are described in Attachment A.
The surveys will be conducted by slowly driving or walking through the areas surrounding the site location.
The locations of all of the observed odors will be recorded on a detailed street map. The surveys will be
conducted over a two day period to allow for observations during daytime, evening and morning hours to
document the full range of diurnal meteorological patterns.
Specific routes traveled during the surveys will depend on meteorological conditions, primarily wind direction.
When odors are detected, the odor plume will be followed upwind to determine the source of the odor. The
odor plume will also be followed in the downwind direction until the odors can no longer be detected, to
document the aerial extent of the odor or its “footprint”. In addition to the alignment of the odor plume, odor
character will be used to correlate odors with their sources.
If the results of OS&E’s odor investigation has identified SBHRC as source of odor beyond its site
boundary further action is neccessary and will be detailed in the Phase 2 Corretive Action Plan.
ATTACHMENT A
Measurement of Ambient Odor Levels - Scentometer
Odor concentration will be measured with the aid of a Scentometer in terms of dilutions to threshold ratio, expressed
as D/T. A Scentometer is a hand-held instrument containing two beds of activated carbon. On its bottom panel the
instrument contains a series of holes of increasing diameters. These holes admit odorous ambient air into the
instrument where it is mixed with the odor-free air that has passed through the carbon filters. To make a
measurement, the observer closes the bottom panel holes and uses the nosepieces to breathe odor free air purified by
passing through the carbon into the central chamber. After having adjusted to breathing odor free air, the observer
opens the smallest hole thus allowing a small amount of odorous ambient air to mix with the carbon filtered air
within the instrument. The ratio of the area of this hole to the combined areas of the holes admitting air to the two
carbon beds is 1/350. Thus, the dilution factor at this smallest hole is 350:1. If the observer does not detect an odor
at that dilution level he closes the hole and opens the next larger hole and again attempts to detect an odor. The
dilution factor at this hole is 170:1. The dilution factors of the next four (4) holes are 31:1, 15:1, 7:1 and 2:1. The
observer continues this procedure until an odor is detected. The odor concentration is then reported as the range
between the dilution at which the odor was first detected and the next highest dilution. This recognized the fact that
the true odor concentration is somewhat higher than the highest dilution at which an odor is actually detected.
Although most regions’ odor regulations are covered under the general nuisance law, some thirteen states and/or air
pollution agencies have quantitative odor regulations which define some quantitative limit for ambient odor impacts.
Of these, most regulate odor based on concentration (D/T) with the majority limiting ambient odors to a maximum
of 7 D/T. The Scentometer is a device that can be used to monitor ambient odors and determine compliance with
this regulatory limit.
Measurement of Odor Intensity – Butanol Intensity Reference Scale
Odor intensity is the perceived strength of the odor sensation. More than any other property of odor, perceived
odor intensity is what triggers odor complaints. It is measured by comparing the intensity of the odor perceived
to that noted when sniffing standardized concentrations of a reference odorant. In this country, n-butanol is
used as the reference odorant as described in ASTM Method E544-18, “Recommended Standard Practices
for Referencing Suprathreshold Odor Intensity”. The now widely used n-butanol odor intensity scale is based
on n-butanol vapor as the odorant at eight concentrations. The concentration increases by a factor of 2 at
each intensity step starting with approximately 15 ppm at step 1 and ending with approximately 2000 ppm at
step 8. OS&E has developed a field kit which uses aqueous solutions of n-butanol to produce the
standard vapor concentrations in the head space of the eight individual containers. In comparing intensities
of various odors the differences in odor character are ignored as in comparing the intensities of lights of
different colors. Numerous field investigations, as well as laboratory evaluations, have established that odors
generally become objectionable when their intensity reaches 3 on the n-butanol scale. This has been verified in
many OS&E field studies conducted across the country and internationally has been found to be essentially a
universal standard except in areas where the population has become sensitized to odors becuase of very
frequent exposure to relatively high intensities of ambient odors. In these cases, such "sensitized individuals"
may complain about odors of much lower intensity than 3.0 on the n-butanol scale.
A common description of the perceived odor at increasing intensity levels is shown below:
n-butanol intensity description of perceived odor

level (0-8)
ASTM E544-10
Very Faint: An odor that would ordinarily not be noticed by the average
0.5 – 1
person, but could be detected by the experienced inspector or a hypersensitive
individual.
Faint: An odor so weak that the average person might detect if his attentions
are called to it, but that would not otherwise attract his attention.
1-2
Distinct, Easily Noticeable: An odor of moderate intensity that would be

readily detected and might be regarded with disfavor. (A possible nuisance in
3 inhabited areas.)
Strong, Decided: An odor that would force itself upon the attention and that
4 and higher
might make the air very unpleasant (a probable nuisance, if found in inhabited
areas.)
Odor Science & Engineering, Inc. 105 Filley Street Bloomfield, CT 06002
Phone (860) 243-9380 Fax (860) 243-9431 www.odorscience.com
Attachment D – Example Documentation
Example documentation that will be included in verified nuisance complaints will be accordance with the
nuisance specified documentation performance standards. Review of these example documents will be
part of the initial Staff training and part of all annual refresher training.
07/24/2019
Daily Housekeeping Electronic Log
07/24/2019
Example of daily housekeeping log documenting tasks and observations for each project area are
required to be completed each operating day. If visual inspections find location is not as stated (i.e.
clean and free of debris or hoses coiled on rack) then the operator will complete the task and only sign
off when complete. Operator initials are required for signoff.
Training Sign‐In Sheet
Date: Start Time: End Time:
Instructor: Location:
Program / Policy / Procedure
(Trainee shall read the policy and/or procedure and initial below)
Initial
Print Name (Policy/Procedure was
(First, Last) Signature provided and read)
*SBHRC Administrative Staff required to populate electronic Training Log, scan sign‐in sheet, and file
Example of electronic training log to be maintained onsite and available for review during business
hours. Populated based on training sign-in sheets.
Truck Arrival / Departure Electronic Log
07/24/2019
Notes:
1) Example electronic truck arrival and departure log availabe onsite for review during business hours for no
less than 3 years.
2) Arrival / Departure log records beginning 12 hours prior to a reported and verified nuisance concern are to
be included in odor and dust report documentation.
Training Electronic Log
07/24/2019
Training Sign‐In Sheet
Date: Start Time: End Time:
Instructor: Location:
Program / Policy / Procedure
(Trainee shall read the policy and/or procedure and initial below)
Initial
Print Name (Policy/Procedure was
(First, Last) Signature provided and read)
*SBHRC Administrative Staff required to populate electronic Training Log, scan sign‐in sheet, and file

Example Maintenance Management Work Order
[to be included prior to substantial completion], information will include:

o Work order open date
o Brief description of work to be completed
o Replacement part information, if necessary
o Work order completed / closed date
07/24/2019
Facility Complaint Log
07/24/2019
FACILITY RELATED COMPLAINT LOG
Complaint Call Complaint Call Complaint Type Location First Date and Time First Supporting Documention Required

Date Time (Odor, Noise, Other) Detected Detected per Complaint Response Procedure
Notes:
1. All facility related compliants have a Community Complaint and Response Form completed to document the call
2. Facility related complaint log includes only the complaints that SBHRC is verified to be the source.
Truck Complaint Log
07/24/2019
TRUCK RELATED COMPLAINT LOG
Complaint Call Complaint Call Location First Load Type (Biosolids,

Date Time Truck ID # Detected Travel Direction Origin Destination Product, or Wastewater)
Notes:
1. All truck related complaints have a Community Complaint and Response Form completed to document the call
2. Truck related complaint log includes only those trucks that are verified to be have association with SBHRC and complaints are verified.

Synagro Nuisance Mitigation and Control Plan For Plainfield Township Biosolids Plant Land Development Plan

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Synagro Nuisance Mitigation and Control Plan For Plainfield Township Biosolids Plant Land Development Plan

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SLATE BELT HEAT RECOVERY CENTER

NUISANCE MITIGATION AND CONTROL PLAN

[IMAGE TO BE REPLACED AT CONSTRUCTION]

1.0 Executive Summary ....................................................................................................................... 1-1

 Preventive Monitoring checklist

Example documentation is provided in Attachment D.

Supporting documentation for Complaint Response in Attachment C include:

Example documentation is provided in Attachment D.

[TO BE UPDATED UPON AVAILABILITY]

[SBHRC REQUESTS PLAINFIELD TOWNSHIP PROVIDE A LIST OF ADDITIONAL KNOWN

[SBHRC REQUESTS PEN ARGYL BOUROUGH PROVIDE A LIST OF ADDITIONAL KNOWN

[TO BE COMPILED AND PROVIDED PRIOR TO SUBSTANTIAL COMPLETION]

 Heat Recovery & Supplemental Heating

Phase Objective Results Schedule

Each model input will utilize data, such as,

 Odor Preventive Monitoring Procedure

Initials: Date: Time: AM PM

Standards and Equipment:

Handheld Hydrogen Sulfide meter with specification

O-2 Downwind quadrant monitored Circle one  NE NW SW SE

Observation direction Circle one  CW CCW

intensity and locate on quadrant map

Additional Action if peak odor intensity greater than 3 Status Date

Additional Documentation if peak odor intensity greater than 3 Status Date

Noise Monitoring Equipment

Monitoring Frequency: Once per month

Documentation if noise greater than 70 dBA Status Date

Initials: Date: Time: AM PM

 Heat Recovery & Supplemental Heating;

Checked during rounds through the facility:

System indicators mitigation is properly working:

 Equipment specific noise performance specification passed at startup

Actions to take if mitigation is not working properly:

 If noise performance specification not passed at startup

Checked during rounds through the facility:

System indicators mitigation is providing proper control:

Actions to take if mitigation not providing proper control:

 If OCS flow or pH operating outside regulated range

Checked during rounds through the facility:

System indicators mitigation is properly working:

Actions to take if mitigation is not properly working:

Checked during rounds through the facility:

System indicators mitigation is providing proper control:

Actions to take if mitigation not providing proper control:

 If OCS flow or pH operating outside regulated range

Checked during all rounds through the facility:

System indicators are providing proper control:

Actions to take if not providing proper control

Date: Doc Number:

TITLE SOP – Housekeeping

• General Housekeeping Requirements

Date: Doc Number:

TITLE SOP – Housekeeping

3.0 Risks & Hazards

4.0 Definitions and Abbreviations

7.0 Operating Parameters & Limits

Date: Doc Number:

TITLE SOP – Housekeeping

Date: Doc Number:

TITLE SOP – Housekeeping

9.0 Reference Documents:

10.0 Revision History

Facility SBRHC Revision/Review History Log