As industrial areas experience encroachment with residential and commercial areas, and regulators look to minimize the potential odour effects from industry on communities, facilities need to identify effective tools to measure and evaluate odours. When considering on-property odour releases, one important item to observe is the potential for fugitive odour emissions. Fugitive emissions differ from point source emissions in that point sources have one discernable emission point and can more easily be routed to ventilation and controlled, whereas fugitive emissions can have multiple sources and are difficult to route to ventilation and/or control devices. As such, methods to identify and assess potential fugitive emissions are of vital importance to understanding potential odour emissions from a facility. Most provinces in Canada regulate “odour”. In Ontario, “odour” is included in the definition of a ‘contaminant’ under the Environmental Protection Act, R.S.O 1990, C. E.19. Further, O. Reg. 1/17 stipulates requirements around “odour” management and control (including best management practices plan) for all Environmental Activity and Sector Registry (EASR) applications.
An effective tool to help better understand potential fugitive odour emissions from industrial facilities is through conducting Building Envelope Studies (BES). These studies look at the outside of the process buildings and determine the likelihood that fugitive emissions could emit from permanent openings in the envelope of the building. Some regulators, such as the Greater Vancouver Regional District (GRVD) have requirements for potentially odourous industrial facilities to conduct BES to help reduce the number of nuisance complaints received from surrounding neighborhoods. Regulators have begun to include requirements for BES and other best management practice plans into facility permits and authorizations.
When evaluating a BES for engineering purposes, it can be expensive and invasive to operations. When conducting a BES for odour evaluations, Trinity utilizes a less expensive and less invasive method of evaluating the integrity of a building envelope through the application of the procedures in US-EPA Method 204, Criteria for and Verification of a Permanent or Temporary Total Enclosure. Trinity is experienced in preparing a test plan utilizing this method, which does not require a facility to shut down or alter operations when the BES is conducted. No large fans and only small amounts of tracer smoke is required. No large equipment is required, and it can be carried out by two operators with handheld equipment, only access to roofs and the occasional use of a lift is required. This method has been accepted by regulators to test building envelopes for fugitive odour concerns in order to demonstrate compliance with permit requirements.
US-EPA Method 204 utilizes a combination of techniques to determine the potential for fugitive odour emissions from a process building. By surveying the site and determining if there are any Natural Draft Openings (NDOs), which are any permanent openings in the building excluding doorways or other designed openings, Trinity can determine if the airflow at these openings is inward or outward. Techniques for determining inward or outward airflow include collecting face velocity measurements and differential pressures from outside to inside of buildings. Smoke tests (via smoke candles, involving small amounts of smoke) can also be conducted as a visual test of airflow direction. Any permanent openings in the building envelope identified through this method which may contribute to fugitive odour emissions can be identified and fixed. Examples of recommended fixes could include closing holes in the building facade, sealing gaps in conveyance devices. A BES, in conjunction with other on-property or off-property odour measurement and management tools (e.g., odour source testing, best management practice plan, neighborhood odour monitoring) can assist facility operators in understanding the potential for odour emissions and help minimize the potential for neighborhood odour complaints.
The key to understanding the potential for fugitive odour emissions at your facility is to conduct a thorough assessment of your facility. Trinity Consultants can support your facility to remain compliant within any jurisdiction in Canada by outlining an odour assessment plan, implementing the plan, measuring odour at your facility, and determining the likelihood for fugitive emissions from your facility. Trinity can help design, implement, and maintain your facility’s Building Envelope Study as well as odour management program.
If you would like to discuss Building Envelope Studies or other odour monitoring or mitigation and how they may impact your facility, please email Steven Babaris in Trinity’s Toronto office or call 647.501.0358.
