TECH ENVIRONMENTAL PRESS RELEASES

2007-09-09: Massachusetts Dep Finalizes Landfill Odor Guidelines

After nearly a year of development, new Massachusetts landfill odor guidelines were signed by Assistant Commissioner James Colman on September 4, 2007. These guidelines will help shape the definition of "odor nuisances" in Massachusetts and in the northeast. The guidelines define action levels for both total odor and hydrogen sulfide, and require solid waste facilities to employ a Hydrogen Sulfide and Odorous Landfill Gas Response Plan if action levels are exceeded. Active landfills that are causing nuisance odors off-site, unlined landfill closure projects that accept construction and demolition debris (C&D) fines and/or residuals, and operating landfills that accept C&D residuals and/or fines for use as daily cover or disposal must have a response plan in place immediately.

A number of public comments to the draft guideline have been incorporated into the final guideline. Tech Environmental was particularly concerned that the draft document grouped odor and hydrogen sulfide together in a single Action Table, so that a single odor complaint could, in essence, trigger one or all of the "Action(s) to be Taken by Landfill Operators."  In other words, any single odor complaint could have immediately subjected a landfill to extensive odor monitoring, regardless of whether it was part of a pattern or an isolated incident.  In the final guideline, there are two tables: one for total odor and one for hydrogen sulfide.

In Table 1, which addresses total odor concerns, the "Frequency of Exceedances Triggering Action" was Swiss Roger Dubuis Replica Watches revised from "any event" to "Odors of Sufficient Frequency, Duration, Intensity and Offensiveness. This is an excellent improvement, since it acknowledges that a landfill (or any other facility or activity) does not exist in a vacuum; an infrequent or mild odor of short duration does not constitute a nuisance. Unfortunately, the final document stops short of specifically defining a threshold for odor nuisance for each of these parameters as total odor. A more refined definition would help both neighbors of facilities and the facilities themselves fully understand expectations from regulators.

Another significant improvement to the final document is the elimination of the "Fenceline Monitoring Program" Action Item. Although landfill operators may not be thrilled to learn that continuous monitoring is still an Action Item in Table 2, the coverage and locations of any monitoring program will not be arbitrarily assigned to the fenceline and can be made on a site-by-site basis to best address site-specific odor concerns.

The hydrogen sulfide Action Level thresholds remain unchanged from the draft: 15 ppb and 30 ppb, averaged over 8-hour (rolling average) or one-hour periods, respectively. It is important to note that the document acknowledges these levels are purposely set above the odor threshold, in order to define an odor nuisance and to alert individuals of increasing concentrations of hydrogen sulfide. This document is not intended to be a public health document, nor does it establish public health thresholds of concern, but it does provide a safety net for measurable data above the odor threshold to be reported to public health officials so they can monitor potential health concerns.

Taken as a whole, the new Massachusetts landfill odor guidelines have improved significantly from their draft form. Tech Environmental will continue to follow the development of similar guidelines across the Northeast, offering constructive comments when possible and keeping our clients apprised of the latest news. Michael T. Lannan, PE Vice President MLannan@TechEnv.com.

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