ENVIRONMENT AGENCY ODOUR GUIDANCE

Internal Guidance for the Regulation of Odour at Waste Management Facilities

July 2002 VERSION 3.0

(Amended following external consultation)
Not to be applied directly to any existing permit or registered application but may be used to identify issues and promote consistent resolution.

Note: This document constitutes guidance issued by the Environment Agency to its regulation officers.

This document has been produced in consultation with officers from different regions and it is issued with the approval of the National Waste Group. It will be subject to periodic review to reflect any developments in technical guidance which affect the advice herein. The Working Group consisted of:Keith Ashcroft Brian Bone Jan Gronow Mark Harvey Nigel Kendrick Jonathan Lees Chris Peters (Chair) Andrew Phillips Lorraine Powell Carol Romero Jim Scott Dave Young (Lead Author) William Edwards North West Region Midlands Region National Policy Southern Region Environment Agency Wales South West Region Thames Region Environment Agency Wales EPNS North West Region North East Region Anglian Region Thames Region

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CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................ 4 1.0 2.0 OBJECTIVE......................................................................................................................................... 6 INTRODUCTION................................................................................................................................. 6 PREAMBLE .......................................................................................................................................... 6 LEGAL BACKGROUND........................................................................................................................... 6 GENERAL CONSIDERATIONS ................................................................................................................. 9

2.1 2.2 2.3 3.0 4.0 5.0 6.0

INFORMATION REQUIRED IN SUPPORT OF AN APPLICATION ........................................... 10 LICENSING APPROACH ................................................................................................................. 11 INSPECTION AND MONITORING ................................................................................................. 13 ENFORCEMENT ............................................................................................................................... 16 FLOW DIAGRAM INDICATING THOUGHT PROCESSES FOR ENFORCEMENT ACTION ................... 19

FIGURE 6.1 7.0

HEALTH & SAFETY AND HEALTH.............................................................................................. 20

APPENDIX A - FACTORS CONTIBUTING TO ODOUR PROBLEMS FROM WASTE MANAGEMENT FACILITIES .................................................................................................................. 21 TABLE A.1............................................................................................................................................... 22 APPENDIX B - PROCEDURE FOR CARRYING OUT AN ASSESSMENT OF ODOUR AT WASTE MANAGEMENT FACILITIES .................................................................................................................. 27 B1 B2 OBJECTIVE....................................................................................................................................... 28 PROCEDURES................................................................................................................................... 28 GENERAL ..................................................................................................................................... 28 AT THE ASSESSMENT LOCATION .................................................................................................... 29 HOW TO REPORT THE RESULTS ....................................................................................................... 30 TRAINING AND CALIBRATION ......................................................................................................... 31

B2.1 B2.2 B2.3 B2.4 B3

ODOUR ASSESSMENT REPORT.................................................................................................... 32 REPORT PRO-FORMA ..................................................................................................................... 32 NOTES ON COMPLETING PROFORMA .............................................................................................. 32 CLASSIFICATION SYSTEM FOR ODOUR PARAMETERS ....................................................................... 32

B3.1 B3.2 B3.3

APPENDIX C - METEOROLOGICAL DATA.......................................................................................... 35 C1 C2 GENERAL .......................................................................................................................................... 36 ATMOSPHERIC STABILITY .......................................................................................................... 36

TABLE C2.1 ATMOSPHERIC STABILITY CATEGORIES .................................................................................... 37 TABLE C3 THE BEAUFORT WIND SCALE .................................................................................................... 38 APPENDIX D - ODOUR DESCRIPTORS.................................................................................................. 39 TABLE D1 “PLEASANT” ODOUR DESCRIPTORS AND “HEDONIC” SCORE ...................................................... 41 TABLE D2 “UNPLEASANT” ODOUR DESCRIPTORS AND “HEDONIC” SCORE .................................................. 42 TABLE D3 ODOUR DESCRIPTORS WITHOUT “HEDONIC” SCORE ................................................................... 43

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FIGURE D1 ODOUR WHEEL ......................................................................................................................... 44 APPENDIX E - UNDERSTANDING SMELL ............................................................................................ 45 E1 E2 REALISTIC EXPECTATIONS OF THE NOSE .............................................................................................. 46 ODOUR FATIGUE ................................................................................................................................ 47

INDEX.......................................................................................................................................................... 48

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EXECUTIVE SUMMARY

Wherever bulk quantities of waste are handled, kept, treated or disposed of there is potential for the generation of offensive odours. Geology, economics, logistics (e.g. transport systems) etc. often result in waste management facilities being situated close to residential, commercial, industrial or amenity areas. It is reasonable that members of the public, going about their normal living, working or leisure activities, should expect not to be offended by odours arising from these facilities. The EC Framework Directive on Waste makes it a relevant objective to ensure that waste is recovered or disposed of without harm to human health or pollution of the environment, including without nuisance through noise or odour. The Framework Directive is transposed into the UK’s national legislation mainly through the Environmental Protection Act 1990 and the Waste Management Licensing Regulations 1994. The control of odour from waste management facilities will be within the remit of the Environment Agency and the planning authority, where odour nuisance will be a material consideration in the determination of a planning application. Conditions in the waste management licence should complement the planning requirements for the site in order to avoid any unnecessary duplication of controls. This document uses, for convention, the format of “nuisance” to refer to nuisance in respect of relevant objectives under the EC Framework Directive and “Nuisance” to refer to Statutory Nuisance in respect of the powers of Environmental Health Authorities. The Agency has a duty to ensure that the deposit, recovery and disposal of controlled waste does not take place in a manner likely to cause pollution of the environment or harm to human health. As such, links must be maintained with other authorities such as local authorities (in their role as planning and environmental health authorities) and the Health and Safety Executive. Odour does present potential health issues, even if only in perception, and it is therefore important to remember that the Agency does have powers and duties to address human health issues in addition to pollution and amenity issues. The aim of this guidance is to provide Agency officers with the relevant background to this issue and to put forward a nationally consistent approach to the control of odour through the permitting system and the subsequent monitoring of any odours produced. It proposes that: • all new licence applications are assessed with regard to odours via a risk assessment provided by the applicant or operator, bearing in mind that some sites may have already provided odour assessments as part of their planning permission process. This risk assessment will be used to define the approach to odour control within the licence; the impact of odour on the surrounding environment is considered as part of routine site inspections; odour is primarily controlled at source by good operational practices, the correct use and maintenance of plant and operator training;

• •

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odour controls are considered in consultation with other relevant regulatory authorities.

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1.0

OBJECTIVE

1.1

The objective of this document is to provide guidance to Agency officers seeking to control odours originating from licensed and exempt waste management facilities; to suggest areas that need to be considered in setting licence conditions ; and to seek national consistency in the monitoring of odours. In respect of the last item, Appendix B describes a scheme for subjective monitoring of odours around waste management facilities. It is intended for use by EA officers, but could equally well be used by site operators. This guidance applies to landfill sites and other waste management activities that fall under PPC regulations, until such time as sectors specific guidance becomes available. For IPPC sites, reference must also be made to the Agency’s IPPC technical guidance on odour1.
INTRODUCTION Preamble

1.2

2.0 2.1

2.1.1 A dictionary definition of odour gives:odour a) that characteristic property of a substance which makes it perceptible to the sense of smell, a smell whether pleasant or unpleasant; fragrance or stench.

b)

2.1.2 The perceptibility of an odour depends on the concentration of that substance in the atmosphere. For each substance there is a limiting concentration in air below which its odour is not perceptible. This is generally referred to as the odour threshold of that substance. More information is available in the Agency’s IPPC technical guidance note on odour. 2.1.3 The subject of odour is a complex one. • An odour can arise from a single substance or from a combination of substances. • In combination with other substances, the characteristic odour of a single substance can be modified so as to be unrecognisable. • Odour from a combination of substances changes as the mixture becomes diluted and the concentration of each component falls below its odour threshold. • Odours from a substance or mixture of substances can be pleasant when dilute or offensive when concentrated. • Odours that are pleasant or acceptable to one nose can be offensive to another. (See Appendix D) • People have different odour thresholds, so odours that are detected by one person may not be detectable by another.
2.2 Legal background

1

EA, IPPC H4 Technical Guidance Note, Horizontal Guidance for Odour, Part 1 – Regulation and Permitting (draft), Part 2 – Odour Assessment and Control (draft)

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2.2.1 The following provides a brief overview of the legal background relating to the control of odours from waste management facilities. 2.2.2 Activities involving the recovery or disposal of waste are subject to the requirements of the Framework Directive on waste (Directive 75/442/EEC, as amended by Directive 91/156/EEC). Article 4 of the Directive requires that member states ensure that waste is recovered and disposed of without endangering human health and without using processes or methods which could harm the environment, and in particular: - without risk to water, air, soil and plants and animals - without causing a nuisance through noise or odours, - without adversely affecting the countryside or places of special interest. The waste management licensing system established under Part II of the Environmental Protection Act 1990, and the Waste Management Licensing Regulations 1994, is the main means by which the Directive’s requirements have been transposed into national law. The Environment Agency, under Section 35 of the Environmental Protection Act 1990 (EPA90), grants licences to waste management facilities on such terms and subject to such conditions as appear to be appropriate to the activities to which the licence relates. The purpose of the terms and conditions are to ensure that the activities authorised do not cause pollution of the environment, harm to human health or become seriously detrimental to the amenities of the locality. The Agency is required to discharge their functions, including licensing, with regard to the relevant objectives of the Framework Directive. 2.2.3 “Harm” is defined in Section 29 of EPA90 as including, in the case of man, offence to any of his senses or harm to his property. 2.2.4 The 1994 Regulations state, in Schedule 4 Paragraph 4, that the relevant objectives, transposed from the EC Framework Directive on Waste, in relation to the disposal and recovery of waste include, inter alia, that processes do not cause nuisances through odour. 2.2.5 Statutory guidance given in Waste Management Paper No. 4 (WMP4) indicates that the planning function and the licensing function should complement each other rather than duplicating controls. The planning system controls the development and use of land in the public interest, and WMP4 states that the prevention of nuisance is one of the important issues in determining the location of waste management facilities. 2.2.6 Many waste management facilities will be subject to an environmental impact assessment as part of this process. However, WMP4 states that planning controls are not an appropriate means for the detailed control of pollution from waste management facilities and that this should be done by the Agency, as Waste Regulation Authority, through the licensing system to ensure that the relevant objectives are met. Where planning permission (resulting from the taking of a specified action by a planning authority before 30 April 1994) was granted after 1 May 1994, the waste management licensing system should be used for imposing detailed controls to ensure the relevant objectives are taken into account. For example, by requiring impact assessments at the

2.2.7

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licence application stage and through the life of the site until surrender of the licence, routine monitoring frequencies and protocols, and remedial action to be taken in the event of the appropriate standard not being achieved. Although the planning permission may have been issued with regard to the relevant objectives, licence conditions should be imposed that complement, rather than duplicate or overstep, the framework set by the planning permission. 2.2.8 However, where the Agency is not satisfied that the relevant objectives are likely to be met within the framework of the planning conditions, a licence must still only be granted with such conditions that appear to the waste regulation authority to be appropriate (Section 35(3) of the 1990 Act), regardless of the date of the planning permission. It is, however, not permissible to reject an application for a licence on the grounds of serious detriment if planning permission (resulting from the taking of a specified action by a planning authority before 30 April 1994) was granted after 1 May 1994. There is therefore a need for the Agency, as a statutory consultee, to communicate any concerns to the planning authority; in particular on the basis of serious detriment to the amenities of the locality to ensure that amenity will be adequately protected (thus achieving the relevant objectives)

2.2.9

2.2.10 Where planning permission was granted before 1 May 1994 or where it is not required (Schedule 4, Section 9(7) of the 1994 Regulations), the Agency is under a duty to reject a licence application on the grounds of serious detriment to the amenities of the locality. Licence conditions need to be imposed to prevent serious detriment to the amenities of the locality affected by the activities controlled by the licence. 2.2.11 As with noise, the control of odour is the responsibility of a number of authorities. All proposed sites likely to produce odour areas should be discussed with and perhaps inspected in conjunction with the local Environmental Health and Planning Officers. 2.2.12 Part III of the Environmental Protection Act, 1990 enables Environmental Health Officers to control any odour that is prejudicial to health or a nuisance that a waste management facility might cause to a nearby community. In Scotland, however, nuisance is dealt with principally under the Public Health (Scotland) Act, 1897. 2.2.13 WMP4 advises that licence conditions relating in a general way to Nuisance should therefore be avoided. However, Section 29 of Environmental Protection Act, 1990 defines the “harm to human health” aspect of the EC Framework Directive on Waste’s relevant objective of nuisance to include offence to any of man’s senses. WMP4 further advises, therefore, that licence conditions that control harm in a specific way must be included where necessary. 2.2.14 Planning Policy Guidance Note PPG23, at paragraph 3.23, advises Local Planning Authorities that a lack of confidence in the effectiveness of controls which may be imposed under pollution control legislation is not a legitimate ground for the refusal of a planning permission or for the imposition of conditions on a planning permission which would merely duplicate such controls. PPG10, which replaces parts of PPG23, has not changed this guidance.

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2.2.15 If odour from a site constitutes a Statutory Nuisance, an Abatement Notice may be served by the Local Authority. This may require that the nuisance is stopped altogether or restricted. Where a licence has been issued and the site operated within the conditions of that licence, it does not mean that an Abatement Notice cannot be served. The fact that licence conditions are being met does not constitute a defence against odour Nuisance proceedings. Whether a Statutory Nuisance occurs will depend on the interpretations of an Environmental Health Officer or the court. 2.2.16 The decision as to whether an odour constitutes a Statutory Nuisance is likely to depend somewhat on it being persistent, but the odours that cause the majority of complaints are transitory. However, it follows that if Statutory Nuisance occurs, then insufficient control has been exercised through the licensing procedures by the Agency, since it has much greater scope under “offence to man’s senses.” 2.2.17 There are waste management facilities with planning permission that are exempt from waste management licensing. In such cases the relevant objectives must still be achieved, both through any planning permission and also by virtue of regulation 17(4) of the 1994 Regulations and the terms of the particular exemption. 2.2.18 Regulation 18 of the 1994 Regulations makes it an offence for an establishment or undertaking to carry on an exempt activity (as defined in Schedule 3 of the 1994 Regulations) without being registered with the appropriate registration authority, this being the Agency in most cases. The registration authority has a duty to maintain a register of such activities. 2.2.19 Although, the exempt activities form the “self-regulation” aspect of waste management, the Agency has a duty to carry out periodic inspections of these activities. Where an exempt activity is being carried out in a manner not consistent with the relevant objectives, it cannot continue to be exempt from licensing.
2.3 General considerations

2.3.1 Wherever waste is handled the potential for generation and escape of odour exists. 2.3.2 There is the view that waste management facilities should not cause odours. A recent Scottish High Court ruling gave that a condition, which required that “All emissions to air from the process shall be free from offensive odours as perceived by an authorised officer of the Agency, outside the process boundary”, was a valid condition. However, this related to an authorisation under Part I of EPA90 and it is currently not clear how relevant this decision would be under Part II of EPA90 in respect of the Waste Management Licensing Regulations under English law. 2.3.3 In an appeal decision relating to Waste Management Licence conditions, (Alco Waste Management Limited vs. Environment Agency, February 1997), the Planning Inspectorate gave a complementary (but not as absolute) view in that “... the operator cannot guarantee that the treatment of waste shall be free from offensive odours. All that can be required is that odours are controlled so as not to harm human health or amenity off the site”.

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2.3.4 The appeal decision reaches many other conclusions and the following is based on those conclusions:2.3.4.1 The purpose of licensing is “to ensure that the disposal of controlled waste does not give rise to pollution of the environment, harm to human health, or serious detriment to the amenities of the locality” (Paragraph B10, WMP26B). Section 29 of EPA90 defines harm as including offence to any of man’s senses and this must include the sense of smell. This can be safeguarded through the imposition of conditions on a waste management licence. 2.3.4.2 There may be the possibility that odours, and the causes of odours, from waste management facilities could be a risk to human health via chemical or microbiological toxicity, or by causing stress or precipitating asthma attacks. This guidance paper considers only amenity issues. The potential harm to human health aspect of landfill gas is being considered by the landfill gas Task and Finish Group but it must be accepted that there are potential health risks from sources other than landfill gas. 2.3.4.3 Amenity is a subjective issue. Amongst a group of individuals, not all will agree, but a consensus can emerge about what could reasonably be considered as offensive smells. The objective of this guidance is to achieve national consistency in the assessment of odours. 2.3.4.4 The identification and analysis of harm to an amenity is not something which can be wholly defined only by employing scientific methods; it must include a subjective assessment of prevailing conditions by those directly affected or by experienced observers. The directly affected group, or “target group”, are the people who live, work or use amenities outside the site boundaries.
3.0 INFORMATION REQUIRED IN SUPPORT OF AN APPLICATION

3.1

As mentioned above, wherever waste is handled, the potential for the generation and release of odour exists. Therefore, at all stages of the development of a waste management facility, from planning through to post closure, an assessment of the possible risks should be carried out by the operator. The assessment should take into consideration potential sources of odour, what actions can be taken or are planned to minimise or eliminate them, the proximity, direction and sensitivity of likely receptors, other factors such as prevailing winds and weather conditions and any other pathways which may exist. This may form part of an Environmental Impact Assessment produced as part of the planning application. Appendix A is intended as an aide memoire listing the potential sources of odour from different types of waste management facility and options available to effect minimisation or control where appropriate. At the pre-application stage, the method statement or working plan should be able to show that all aspects of potential odour generation and release have been considered by the operator and addressed or rejected as inappropriate.

3.2

3.3

3.4

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3.5

The Agency also has an opportunity to comment at the planning stage as a statutory consultee. For a waste management facility, the opportunity exists to comment on the appropriate use of the land in question, with respect to nearby housing and other developments. Where planning consent is given against advice, the Agency will have a difficult task in applying the appropriate pollution controls due to the location of the site. It is important to recognise that sites which fall within the licensing exemption criteria still need to comply with the relevant objectives, including not causing nuisance through odour. Therefore should an exempt site cause such a problem that means it does not comply with the relevant objectives, it will no longer meet the terms of the exemption and becomes a licensable activity. Equally, existing sites, where the licence exerts no odour controls need to be considered for modification in this respect where necessary. See 5.16.
LICENSING APPROACH

3.6

3.7

4.0

4.1

WMP4 makes it clear that licence conditions must leave the licence holder in no doubt about the standards to be met. The placing of a condition on a licence which, in itself, specifically seeks prescriptively to limit or eliminate odour from a waste management facility is not likely to be the most effective means of achieving such control. Proactive means are required to achieve adequate and effective control of odours at source by licence conditions which ensure good day-to-day site management of operational activities on the site. This aspect is not covered by this guidance paper but an idea of the scope of the issues which may be addressed can be obtained by reference to the tables contained in Appendix A. However, it may ultimately become necessary to take prescriptive action with respect to odours by the placement of licence conditions that specifically address such issues. Areas which might need to be considered are:§ The provision and maintenance of measures to secure the minimisation of release of offensive odours under everyday circumstances and particularly when specified operations are undertaken, which the operators risk assessment has shown are likely to increase the risk of odour release , e.g.:− excavation into waste; − removal of leachate monitoring chimney lids or leachate manhole covers; − extension of leachate monitoring chimneys; − removal of intermediate cover; − maintenance of gas abstraction system; − storage of wastes. Notification to the Agency when such actions are to be undertaken. The provision and maintenance of measures to contain or suppress any odours released or generated. The escape of offensive odours beyond the site boundary and the effect on sensitive receptors identified in the risk assessment. The provision of an effective and approved odour monitoring regime. 11

4.2

§ § § §

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The requirement to report to the Agency incidents of odour either reported to the operator or detected via a monitoring regime.

4.3

Licence conditions may specify what needs to be done or may require that proposed actions to meet a desired objective are detailed and approved via the working plan and guidance on this aspect should be sought by reference to the Agency’s Library of Licence Conditions.2 Some further discussion on what may need to be taken into consideration is given below. The provision and maintenance of measures to control odours may need to take into consideration:− how agreement on the provisions should be made - in accordance with conditions, in writing or via the working plan; − when the agreement should be reached - prior to the deposit of waste or by a set date; − the restriction of a waste or wastes either likely to give rise to or shown to give rise to odour problems; − methods of keeping, storing, handling, treating, placing, discharging such wastes; − method of sealing containers, chimneys, boreholes, chambers, tanks, pipes which contain wastes or derived materials likely to give rise to offensive odours; − methods of filtering, scrubbing emissions from chimneys, vents, extraction units likely to give rise to offensive odours. It is important that the agreed measures be maintained or available on site for use should an odour occur. It may be, should the agreed measures need to be used, that they do not prove to be entirely effective in which case revision of what is agreed is clearly necessary. If agreed measures are not maintained or available, this should be viewed as a clear breach of licence conditions and if odour problems occur under such circumstances this should be viewed as a serious breach of licence conditions. Conditions seeking to control the detection of odours beyond the site boundary should be dependent on the location of the nearest receptor of odours. It may be that a local amenity such as a much visited local beauty spot or much used footpath is immediately adjacent to the site boundary in which case a condition requiring no odours beyond the site boundary should be justified. It may be, however, that the nearest receptor is a residential development for example some 500 metres beyond the site boundary, in which case the condition should be tempered accordingly. Consideration should also be given to the significance of highways adjacent to the site particularly if they provide access to amenity, residential, commercial or industrial development. It must also be recognised that weather conditions and the topography of the area will affect the way in which odour is dispersed. For example, in certain circumstances, it is possible for an odour, arising from a site, to rise above ground level and be carried beyond the site boundary to become detectable again at some point beyond it. (See Appendix C)

4.4

4.5

4.6

4.7

2

Library of Licence Conditions and Working Plan Specifications – Volume 1: Waste Management Licences, Edition 2, Published 2 August 1999

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4.8

Any scheme designed to monitor for offensive odours should detail:− the method of assessment to be employed − identification of personnel specified to carry out monitoring, paying particular attention to the possibility that actual site staff may suffer from odour fatigue due to constant exposure to an odour. – See also 5.6 − details of guidance, instruction and training given to specified personnel − minimum frequency of monitoring − liaison with the Environment Agency − the period over which the monitoring shall take place − monitoring points on and off the site, and − record keeping. It must be remembered that some waste management facilities and activities, exempt from licensing, have the potential to cause odour. However, if such sites cannot meet the relevant objective relating to odour, they become licensable.
INSPECTION AND MONITORING

4.9

5.0

5.1

The Agency has a duty to carry out appropriate periodic inspections of waste management facilities. Statutory guidance on inspection frequency has been provided in an amendment to WMP4, which requires inspection frequency to be determined by a risk-based approach. Under Section 34 of EPA90 there is a ‘Duty of Care’ incumbent upon anyone who handles waste to ensure that all necessary actions are taken to protect the environment and human health. Bearing in mind the definition of harm in Section 29 of the Act which includes offence to any of man’s senses, it follows that the ‘Duty of Care’ must include protection from offensive odours. Paragraph 4.34 of WMP4 advises there is an expectation that the licensee of a waste management facility should carry out its own environmental monitoring which, again, in view of the definitions given in Section 29 of EPA90 should include monitoring the air for offensive smells. It should be part of the operator’s responsibility to carry out such monitoring. To deal with the problem effectively, it is necessary for the operator to have a number of things in place:• • • • sufficient day-to-day control to minimise or contain any problems via frequent and regular full inspections of the site carried out by the licensee or his staff; a scheme to monitor the extent of the odours and to detect when a problem has arisen or is likely to occur; techniques and equipment which are acknowledged as being effective need to be in place or available to deal with incidents as they occur; a requirement to take effective action in the event of offensive odours being detected.

5.2

5.3

5.4

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5.5

The level of action and monitoring required around a facility should be gauged in accordance with the risk from that site. For example, sites accepting potentially odorous wastes, some special waste streams or a high proportion of putrescible waste can present a high degree of risk of odours and are likely to receive a relatively high level of attention subject to their location relative to sensitive receptors. Conversely, sites accepting inert wastes3 present a low risk of odour problems. A scheme for the subjective monitoring of odours around waste management facilities is suggested in Appendix B. The scheme is designed for Agency officers but would easily be adaptable to the requirements placed on an operator and could therefore be suggested as a model. In any such scheme, operators, in particular, should recognise the possibility that staff associated with a site, which may have odour problems, could suffer from odour fatigue, i.e. the inability to detect relevant odours due to constant exposure to them. In such circumstances it may be prudent to use staff not directly associated with the site. As with other forms of environmental monitoring, Agency officers should also carry out audit monitoring to check the results reported by the operator, but again officers should be aware of the possibility of odour fatigue resulting from regular or constant exposure to such odours. The scheme suggests that monitoring should be followed by site inspections. In addition to monitoring of odours by the operator and Agency officers, complaints about odour voiced by the local community can, in themselves, be an effective form of monitoring where problems are known to exist. Complaints should be encouraged by providing or publicising a mechanism, such as the Agency’s Freefone emergency number, 0800 80 70 60, for the receipt of complaints. It should also be explained to complainants that is important for them to continue to complain rather than become apathetic if nothing seems to be happening, since that is often one of the only ways in which the Agency might be able to attach a scale to the problem. In this respect both the number of complaints and the number of complainants are important and need to be recorded and details passed to the operator. When a complaint is received the following information should be recorded. a) b) c) d) e) f) g) Name, address and telephone number of complainant(s) Time complaint received Location of odour if not at address above Date(s) and time(s) to which complaint relates Duration of odour(s) - when it started; is it there now? When did it cease? Any description of odour

5.6

5.7

5.8

Complaints received should also be checked out by Agency inspectors and site personnel whenever possible. Officers should note, however, that the temporal variance of odours may mean that the odour has subsided or changed from the time the complaint was received. It may be appropriate to leave a log or diary with the complainant so that they can record incidents of odour. Details noted should include: dates, times and duration that the odour was detected; where the odour was detected

3

Landfill directive definition – no risk, cannot by definition give off odourous gases unless not inert

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(inside/outside?); a description of the odour; weather conditions when the odour was detected. 5.9 Where a site is shown beyond all reasonable doubt to be the cause of odour problems in a locality in terms of harm or detriment to the amenity, all relevant potential sources of odours on the site should be identified and given attention. Not every potential source of odour on the site may be generating offensive odours at any one time, but all should be addressed in view of their potential detriment to amenity. It might be unacceptable to leave the installation of any necessary controls for a phased, longer term programme as any identified detriment to amenity might remain until all potential sources have been dealt with. There may be other sources of offensive odours in the locality which should be taken into account during any investigation and these too may need to be addressed by the relevant authority. In such circumstances, a liaison should be maintained with the Local Authority Environmental Health Officer, a request made to monitor these other sites and to record whether they are, or are not, causing odours. This is not an argument, however, to ignore or delay implementing any necessary control of odours from a waste management facility (WMF) once they have been positively identified. The officer should also be aware, however, of the possibility of an odour from a WMF being due to the disposal of an odorous waste arising from a nearby local source. The assessment of the WMF will need to take into account such a source, and it may need to be investigated separately. It is also important to encourage the operator to form a liaison with the local community and perhaps for the Agency to be involved in this liaison. This is likely to give operators a better understanding of the intensity, scale and emotive nature of any problems arising from their site. It is also likely to better motivate the operator to cure the problems and make them, perhaps, more accountable for the consequences of their development and the controls they exercise upon it. By inclusion of regular site visits within this liaison, it is possible also for the community to feel involved in the improvement of the amenity in the locality where problems are seen to be being overcome. A strategy to monitor odours should be devised in consultation with the Agency and the Local Authority EHO, such that evidence can be compared between the operator’s records, those of the Agency and those of the local authority in the event of complaints being raised about offensive odours in the area. As outlined in 5.6 above, it should be borne in mind that reliable complaints, in themselves, are a form of monitoring. Paragraph 2.5 of WMP4 advises that there should be no doubt about the standards to be met. Where an odour is consistent and due to known, specific chemical(s) which can readily be measured by instrumental means, e.g. hydrogen sulphide, limits can be set, perhaps at odour threshold limits at the site boundary or at the nearest sensitive receptor beyond the site boundary. However, under normal circumstances due to the variability and complexity of odours there are seemingly no readily available scientific measurable indicators or factors for odours which might be incorporated into any control standards or licence conditions.

5.10

5.11

5.12

5.13

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5.14

Where there is difference of opinion based on the interpretation of subjective monitoring and likely source of odour, but an obvious problem exists, recourse can then be made to other techniques such as olfactometry using odour panels or the application of more specific and scientific techniques such as gas chromatography and mass spectrometry to collect air samples to identify the offending source. It is not currently within the intentions of this guidance to discuss these techniques since they are more fully covered in other Agency documentation.4 Subsequently, once the source producing or likely to produce detriment to the amenities of the locality or harm to man’s senses has been identified, if generated by waste management activities, all that may be required is an agreement, via the working plan, changing inappropriate practices or stopping the acceptance of any offending waste stream(s). Alternatively, should this agreement not be reached, EPA90 allows for the modification of the conditions of a licence under Section 37 or the revocation or suspension of a licence under Section 38 or Section 42 by the issue of appropriate notices. The operator however has the right of appeal and under normal circumstances the requirements of such notices would be ineffective pending the outcome of such an appeal. If an appeal is considered likely it should not be unreasonable for the Agency to use the provisions of Section 43(6) of EPA90 to ensure that necessary works be carried out as soon as possible. Under these provisions, the requirements of such notices remain effective during any appeal, provided that the notice includes a statement to the effect that in the opinion of the Environment Agency the required action is necessary for the purpose of preventing or, where that is not practicable, minimising pollution of the environment or harm to human health, which includes offence to man’s senses.
ENFORCEMENT

5.15

5.16

6.0

6.1

Notwithstanding anything in the discussion below, reference should be made to the Agency’s Enforcement and Prosecution Policy document.5 It goes without saying that enforcement action comes into its own when discussion, negotiation and persuasion have failed. That does not mean to say that enforcement action should not be started until the above have reached their conclusion as often enforcement action can take time to proceed and in the meantime, amenity and human health can remain affected. However, this approach requires a careful balance to ensure that if prosecution is proceeding, there is compliance with all the requirements of both the Criminal Procedure and Investigation Act, 1996 and the Police and Criminal Evidence Act, 1984. The course of enforcement action taken depends of course on the particular problem. Figure 6.1 below attempts to set out some outline thought processes aimed at assisting officers in deciding which course of action to take. It makes an initial assumption that to Agency officers’ minds, it has been established that the Waste Management Facility

6.2

6.3

4 5

Odour assessment and control – Guidance for Regulators and Industry – In preparation Environment Agency – Enforcement and Prosecution Policy and Guidance – Version 2 published 30 September 1999

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(WMF) is the source of the problem and other, possible, nearby sources have been eliminated. It is not intended to form definitive enforcement guidelines. That is not within the intended scope of this paper. 6.4 Where the decision process has led to the conclusion that prosecution is the only available option, the importance of accurate, factual statements from officers and, if appropriate, those affected in the locality is essential. Paragraphs 6.7 and 6.8 below give guidance on the aspects and detail which may or need to be covered in such statements. It is important to remember that hearsay evidence cannot be included in statements. If an officer visits a site as a result of complaints from the locality, in reporting that visit as evidence his statement must state that he went to the site as a result of information received. It must not state that he received “N” complaints. It is acceptable, however, to state that “N” telephone calls were received from local residents and that statements from “n” residents are produced as evidence. An officer’s statement should cover the following points:• • • • • • • • • • • • • • • • Name Job Qualifications, if relevant, e.g. chemist Length of time doing job and/or related duties Other relevant experience e.g. member of this “expert” group Health, general and at the time to which the statement relates, e.g. cold, sinusitis etc. Smoker? Time and date of observations Location of observations with respect to the site in question Method of conducting observations, − Walking? Where? − Driving? Where? Windows, sunroof, vents open? Observations on weather conditions, particularly wind speed and direction, but also other relevant meteorological conditions (see assessment form in section B3). If possible, an indication of atmospheric stability (see C2). Strength of odours - observations could relate to guidance in this document provided that the guidance is produced as evidence in the form of an exhibit Was the site visited? Conditions on the site? Did observations on the site correlate to observations outside? In the officer’s opinion, are the odours the same.

6.5

6.6

6.7

If the statement is in relation to an odour assessment (as described in Appendix B), reference should be made to the odour assessment report number (see section B3). This report will then cover observations on meteorological conditions and strength of odour.

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6.8

A resident’s statement should cover the following points:• • • • • • • • • • Name Address Length of time at that address Occupation Health, general and at the time to which the statement relates, e.g. cold, sinusitis etc. Smoker? Statement of the date(s), time(s) and duration of periods when the resident has been affected by odours. If diary of odours kept, it should be produced in evidence Where were they affected by the odours? Inside (where, how) and/or outside (where, how) Description of smell Weather conditions.

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Does the licence include a "Boundary Condition"? YES

NO

Modify licence under S 43(6) + S 37 to include boundary condition with statement of why modification is needed

NO Compliance? YES

Issue notice under S 42(5) requiring compliance

NO Compliance? YES

Issue notice under S 42(5) requiring compliance

NO Compliance? YES

NO Can the source of odour from the site be identified? Is the problem covered by a licence condition? NO YES Is the licence condition sufficient? NO YES Issue notice under S 42(5) requiring compliance NO Compliance? YES

YES

What is scale of problem/ breach? Persistence, frequency, strength of odour, location and density of receptors

Consider Action Suspension or revocation of licence or prosecution under S 33(1)(b) or (c)

Can the licence be modified to address situation? YES

NO

Modify licence under S 43(6) + S 37 to include boundary condition with statement of why modification is needed

NO Compliance? YES

Issue notice under S 42(5) requiring compliance

NO Compliance? YES

Figure 6.1

Flow Diagram Indicating Thought Processes For Enforcement Action

Note:

Diagram assumes it has been established, in the Agency Officer’s mind, that the Waste Management Facility is the source of the odour problem off site. See section 6.3

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7.0

HEALTH & SAFETY AND HEALTH

7.1

While the above text draws attention to various health and Health and Safety issues, it is important to remind officers of these issues:• • The health effects of landfill sites are being studied and will be reported on elsewhere in due course. Officers should be aware of their own health and safety when carrying out odour monitoring around waste management facilities. Inhalations should not be made directly over, or even relatively close to unknown drums, leachate chimneys, gas wells etc. Before visiting a site, officers must also refer to the Agency’s Health & Safety Management Procedures Manual.

Where concerns are received from members of the public with respect to health or Health and Safety issues, in addition to noting and dealing with the concern as appropriate, the person should also be made aware of the other avenues open to them to address or mollify their concerns if necessary, e.g. The Health & Safety Executive, the Local Authority Environmental Health Department, their own GP.

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APPENDIX A - FACTORS CONTIBUTING TO ODOUR PROBLEMS FROM WASTE MANAGEMENT FACILITIES

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TABLE A.1

Type of Site

Factors that may contribute to odour problems

Comment / Options / Mitigating Actions

Disposal of Odorous Wastes

Sheeting of vehicles and speed of covering of wastes. Review Working Plan procedures for dealing with malodorous wastes. Ultimately review nature and range of waste permitted In co-disposal landfill sites, the deposit of bulk quantities of sulphur bearing wastes, such as gypsum and plaster board, such that large, discrete deposits of sulphates occur should be avoided due to risk of formation of large quantities of H2S by bacterial action and the resultant odour and health and safety problem. Small deposits at a controlled rate should not cause problems provided normal controls are in place. Dig out, isolate, damp down (care – may make matters worse), cover, call fire emergency services, etc. General presumption against; consider active extraction and/or scrubbing using carbon, peat etc. Consider upgrading Consider extending Effect repairs, planned maintenance, increase routine inspection by operator Effect repairs, increase inspection frequency, increase routine inspection by operator Automatic re-ignition or shutdown fitted?

Disposal of sulphur bearing wastes.

Landfill Sites

Fire on site:

Accidentally started Receipt of burning wastes Mixing of incompatible wastes

Landfill Gas:

Passive venting/ Vent trenches Ineffective collection system Inadequate collection system Failure of collection system: Pump failure Pipework failure Flare system: Failure of flame Poor flame / combustion: (Incorrect gas mixture Incorrect temperature Low residence time) Height of flare stack

For all factors - See guidance and recommendations in EA Landfill Gas guidance6

6

Technical Guidance for Landfill Gas Flaring in the UK Odour Guidance for Waste Sites, Version 3.0, July 2002

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TABLE A1 (contd.)
Leachate system: Septic leachate, high sulphide content Open leachate monitoring chimneys Odour release by aeration High surface area, uncovered

Landfill Sites (contd)

Treat empirically with H2O2, Ozone etc. Increased frequency of monitoring & reporting by operator Consider covering and attaching to scrubber or landfill gas flare system Consider alternative treatments Reduce area, cover Increase compaction rate Reduce size / area. Location of deposits – move tipping area Cover progressively See guidance and recommendations in EA Landfill Cover Task & Finish Group output
7

Operational activities / failures: Inadequate compaction Large working face / area Wastes not buried quickly enough Use of cover: Type/Depth/Maintenance of old Excavations into old wastes: Excavation of trenches Drilling of wells Slow burial of excavated wastes Open trenches Use of odour counteractants or neutralisers

Weather conditions Location of site with respect to receptors

Prior information to Agency? Proactive Informative around locality and cover quickly Prior information to Agency? Proactive informative around locality and cap quickly Bury immediately Consider covers & use of odour scrubbers Can be effective but often more offensive to people in the locality than waste odours due to “false” odour or unknown constituents (fear element). Should be used selectively and with caution Many atmospheric conditions e.g. high pressure, calm, foggy, or inversion can exacerbate, prolong or increase the range of any odour present as a result of operational conditions on any site. Consider phasing of tipping sequence in respect of prevailing wind and weather conditions Planning considerations - appropriate use of land? Effect of Topography

7

Review and Guidance on the Use of Landfill Cover Materials. Edition 1.0. May 2000 Odour Guidance for Waste Sites, Version 3.0, July 2002

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TABLE A1 (contd.)
Composting of Odorous Wastes Operational activities / failures: Monitoring of temperatures Waste turning anaerobic Turning compost at required intervals Height of windrows Review working plan procedures. Ultimately review nature and range of wastes accepted Needs careful attention, operator responsibility Needs careful attention, see below Fundamental principle, important to maintain aerobic state by turning or introduction of air by other means Maximum height - 2 metres See EA guidance on Composting Location of site in relation to proximity of receptors
8

Composting Facilities

Planning consideration - appropriate use of land. Consider requirement to enclose facility

Disposal of Odorous Wastes: Residual wastes Attention to end of day cleanliness required in case of putrescible wastes Household wastes already up to at least two / three weeks old on arrival. Process quickly Doors that open only to allow passage of vehicles probable recipe for trouble without roof level ventilation. Roof level ventilation also likely to require scrubbers or filters which in themselves will require regular inspection / maintenance

Transfer Stations

Age of wastes Ventilation

Opening of tankers, drums etc. for inspection, sampling etc. Transfer of wastes from drum to bulk Nature of wastes

Can cause severe odour problems in locality. Should be carried out under negative pressure situations with extraction and scrubbing

Consider review nature of wastes accepted See also EA guidance on clinical waste facilities9

8 9

Technical Guidance on Composting Operations. V3.0, for external consultation. Technical Guidance on Licensing Clinical Waste Facilities Odour Guidance for Waste Sites, Version 3.0, July 2002

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TABLE A1 (contd.)

Treatment Plants. Physical & Chemical

Blending:

Incompatible wastes

Control matter, need for attention to operational detail. Potential ‘Duty of Care’ issue if wrong information given Odour collecting / treatment hoods over tanks/vents. Control matter, correct information available? Wastes checking procedures? Potential ‘Duty of Care’ issue if wrong information given Odour collecting / treatment hoods over tanks/vents. Process control matter. Correct information about wastes available? Potential ‘Duty of Care’ issue if wrong information given. Wastes checking procedures? Planning consideration - appropriate use of land

Neutralisation, redox, precipitation: Odour from incompatible wastes, unexpected reactions

Overheating

Location of site with respect to proximity of receptors

Age of waste/Onset of anaerobic conditions

Minimise storage period Minimise quantity handled per load, minimise transit / storage time The transport of wastes is not a licensing issue but since this activity has significant potential for the creating of odour nuisance it is felt worthy of note that this is a potential ‘Duty of Care’ issue or ‘Harm to Human Health’ issue within the meaning of Section 29 EPA, but officers might be able to influence at source via liaison with the local authority in respect of odour at the source site or by giving advice in respect of the timing of transportation and the route taken to the disposal / recovery facility.

Storage & Transport

Waste is Food and food processing wastes, including brewery wastes

Transport of Wastes

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APPENDIX B - PROCEDURE FOR CARRYING OUT AN ASSESSMENT OF ODOUR AT WASTE MANAGEMENT FACILITIES

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PROCEDURE FOR CARRYING OUT AN ASSESSMENT OF ODOUR FROM WASTE MANAGEMENT FACILITIES BY AGENCY OFFICERS
B1 OBJECTIVE

B1.1

To provide a clearly written procedure for a consistent, albeit subjective, assessment of odours around licensed waste management facilities. It is intended that this guidance lays down a framework of principles which can be applied consistently. It is realised that there will be a need for local adaptation of monitoring procedures according to conditions at the site in question, its location and local surroundings, the nature of any complaints, and reporting procedures according to management arrangements and resource availability.
PROCEDURES General

B1.2

B2 B2.1

B2.1.1 To carry out the assessment, the inspector uses his own sense of smell to try and detect odours, which may arise from the site being assessed. Each inspector likely to be involved in carrying out odour assessments should initially accompany a more experienced inspector on an assessment to ensure that the nature and offensiveness of any odours detected are being perceived similarly. In addition, two or more officers should occasionally carry out assessments together to ensure that assessments continue to be carried out to the same perceptions. If an inspector has a cold, sore throat, sinus trouble etc. they should not carry out the assessment. B2.1.2 Assessments should be carried out both routinely and in response to specific complaints. In addition assessment should be carried out which are targeted to weather conditions likely to lead to adverse odour at identified receptors. To this end, each inspector involved in carrying out odour assessments must have regard to the weather forecasts for the area, including wind strength and direction, barometric pressure, rainfall, temperature and humidity. B2.1.3 Specific attention to the following points of detail should be noted:• • • • The inspector should not smoke or consume strongly flavoured food or drink, including coffee, for at least half an hour before the assessment is carried out. The consumption of confectionery or soft drinks should be avoided immediately before and during the assessment. Scented toiletries, such as perfume/aftershave should not be applied immediately before or during an assessment. The vehicle used during the assessment should not contain any deodorisers.

B2.1.4 Any complaint or contact regarding odour should be recorded in the appropriate manner, be it incident form, contact form, log book or diary and responded to in accordance with the targets set in the Agency’s Customer Charter. Section 5.7 indicates what, ideally, should be recorded when a complaint is received. The licence holder should be informed when a complaint has been received and should be aware, on a general basis, that an odour assessment is likely to be undertaken by an inspector on the day of receipt of the complaint, if practicable.

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B2.1.5 Where complaints are received on a regular basis, an odour assessment should be carried out on each site visit and statistics of complaints received and odour assessments carried out should be kept and maintained by those involved.
B2.2 At the Assessment Location

B2.2.1 The assessment involves the inspector walking, as far as access allows, from a point, at a distance from the site, towards the site boundary (or onto the site itself) and then continuing on away from the site again. Where the assessment is being carried out routinely, the starting point should be down wind of the site, progressing towards the site boundary and then away from the site in an up wind direction. Where the assessment is being carried out in response to a specific complaint, the starting point will be the location from which the complaint was made. When arriving to carry out an assessment, the inspector should not go straight to the site, but rather to the intended starting point. B2.2.2 In carrying out the assessment, the inspector should walk slowly and breathe normally. If odour cannot be detected in this way, the inspector should periodically stand still and inhale deeply. (Note: If odour but can only be detected by inhaling deeply, the intensity should be noted as 2 (faint). If odour is detected while walking, the intensity should be recorded as at least 3 – see B3.3.1) B2.2.3 At appropriate intervals, the intensity, extent, i.e. persistence, and a description of the odour, together with the location from site boundary, should be recorded. In addition the sensitivity of the location where the assessment is being made, with regard to receptors, should be noted (see B3.3), as well as any external activities such as agricultural practices that could be the source of the odour. The possibility that an odour may change with distance due to dilution effects should be taken into consideration. B2.2.4 Periodically, the odour assessment around sites considered to be sensitive should include fixed location assessments. The inspectors responsible for the site should determine a number of receptor-sensitive locations. These locations will be determined from analysis of existing data and of complaints received. B2.2.5 A fixed location assessment should incorporate measurements reported over a standard time period, say 5 minutes per location. The intensity and extent can then be evaluated over a time period. Either, the intensity and duration of odour should be measured each time odour is perceived, or measurements should be made at fixed time intervals, over a 5 minute period every 30 seconds would be the minimum requirement. For the latter method, a standard yes/no response would be required as well as indication of intensity, but extent measurements would not be necessary. B2.2.6 On eventual arrival at the site the atmospheric conditions prevalent at the time, See Appendix C, should be evaluated if possible and recorded against site-specific factors, such as the location and nature of site activities and location of sensitive receptors. A compass and hand-held anemometer would be useful but is not essential B2.2.7 The appropriate part of the site boundary relative to wind direction or complaints should first be walked to detect any odour. Once again the inspector should walk slowly and breath normally. When odour cannot be detected in this way, the inspector should again periodically stand still and inhale deeply facing upwind. In this respect, a common sense approach should be taken
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and the inspector should not inhale deeply over any boreholes. Particular care should be taken if any sulphidic (rotten eggs) odours are perceived. B2.2.8 In order to determine the extent of the odour "plume” in sensitive areas, it may become necessary to carry out assessments away from the site at points perpendicular to the plume axis and equidistant from the source. The results should be plotted onto an appropriate plan. In some circumstances it may be difficult to conduct such a survey because of the lack of access to land in the vicinity of the site. B2.2.9 Following an odour assessment a site inspection should be carried out seeking to trace any observed odour back to source and to evaluate any potential odour-producing activities or locations. Appendices A and C may prove useful in the respect.
B2.3 How to report the results

B2.3.1 All observations should be noted on the odour assessment report, following the classification system for odour parameters. Observations should be reported to a member of the site’s technically competent management following the inspection. A report form is suggested in Section B3 of this appendix. However, this paper does not seek to impose yet another form on Agency officers if there exists already adequate alternative means of recording necessary information. B2.3.2 The odour inspection report should be passed to the appropriate senior inspector for signing and recording what further action is required, e.g. letter to licence holder requiring odour control or enforcement of licence condition requiring no odours beyond site boundary. The result of the odour assessment, and any action required, should be confirmed on the completed assessment report and the impact of odour arising from the site should be discussed with the licence holder at regular liaison meetings. B2.3.3 Consideration should be given to carrying out periodic VOC surveys with the licence holder at sites where particular problems have been identified. The inspector should discuss this with his Line Manager before approaching the licence holder. Sampling for analysis of odorous trace gases should not be carried out routinely but may be considered if a significant odour problem is being disputed by the licence holder or proving difficult to resolve. B2.3.4 A spreadsheet file can be set up for storing odour assessments for identified sites and responsibility for inputting collected data should lie with the primary inspector. B2.3.5 Data should be input at least monthly, and sorted by date and location. Each inspector should be trained in the use of all applicable input and output functions. B2.3.6 A bar chart for intensity, extent and sensitivity can be set up for one location at each site. The chart should be revised monthly, by altering the range, and output for appropriate locations printed as required. Other graphical methods, including time-series XY plots, should be used as required, for example, for discussion at liaison meetings or to evaluate changes in operational practices. B2.3.7 A rose diagram can set up to display wind direction for each site. This should be updated daily and output printed on a monthly or quarterly basis, depending on the number of assessments carried out.
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B2.3.8 Output for each site should be assessed at a frequency dependent on conditions encountered and complaints received, but at no less than once per quarter. B2.3.9 Odour assessments should be carried out at a frequency determined by the potential for odour to cause a problem and number of complaints received, and this frequency should be reviewed by the line manager, in consultation with Licensing Officer and the responsible Area Functional Manager on a regular basis.
B2.4 Training and calibration

B2.4.1 All inspectors responsible for assessing odour should be trained in the use of this procedure. B2.4.2 For each sensitive and high risk site, and at a frequency no less than twice a year, two inspectors should carry out an odour assessment independently but simultaneously. The completed assessment reports should then be sent to the responsible officer, to evaluate for consistency. Such exercises can be used to confirm how representative the odour assessments are. B2.4.3 Consideration may also need to be given to evaluating the sensitivity of each inspector’s sense of smell using olfactometry methods.

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B3 B3.1

ODOUR ASSESSMENT REPORT Report Pro-forma

B3.1.1 A suggested pro-forma for reporting the results of the Odour Assessment is shown on the following pages.
B3.2 Notes on Completing Proforma

B3.2.1 To complete the entry on ‘General Air Stability’ reference should be made to appendix C. B3.2.2 The entry for ‘General Air Quality’ should include whether or not the air quality is good, average or poor as this may influence odour perception on the day. B3.2.3 The entry for ‘Ground Conditions’ should record whether the ground is wet as a result of recent rainfall as this may influence odour dispersion. B3.2.4 ‘External Sources of Odour’ refers to activities, not associated with the waste management facility being assessed, that could be a source of odour. B3.2.5 For entries on ‘Odour Intensity’, ‘Odour Extent’ and ‘Location Sensitivity’, the classification system presented in B3.3 below should be used.
B3.3 Classification System for odour Parameters

B3.3.1 Intensity 1 No detectable odour 2 Faint odour (barely detectable, need to stand still and inhale facing into the wind) 3 Moderate odour (odour easily detected while walking and breathing normally, possibly offensive) 4 Strong odour (bearable, but offensive odour - will my clothes/hair smell?) 5 Very strong odour (this is when you really wish you were somewhere else) B3.3.2 Extent (assuming odour detectable, if not then 0) 1 2 3 4 5 Local and impersistent (only detected during brief periods when wind drops or blows) Impersistent as above, but detected away from site boundary Persistent, but fairly localised Persistent and pervasive up to 50 m from site boundary Persistent and widespread (odour detected >50 m from site boundary)

B3.3.3 Sensitivity of Location where Odour Detected (assuming detectable, if not then 0) 1 2 3 4 5 Remote (no housing, commercial/industrial premises or public area within 500 m) Low sensitivity (no housing, etc. within 100 m of area affected by odour) Moderate sensitivity (housing, etc. within 100 m of area affected by odour) High sensitivity (housing, etc. within area affected by odour) Extra sensitive (complaints arising from residents within area affected by odour) 32

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ODOUR ASSESSMENT REPORT

FILE NO.

Site Assessment Start Time

Assessment Date Assessment Finish Time

Complaint Received Location of Complaint Area

Yes/No

Date Grid Reference (where location is not a property)

Weather Temperature (deg. C) % Cloud Cover General Air Quality

Wind (strength and direction) Bar Pressure (mbar) (rising/falling) General Air Stability (see appendix C) Ground Condition

Enter results of assessment overleaf

Plan attached showing location and extent of odour

Yes/No

Additional comments

Action required

Reported to on site : Signature :
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ODOUR ASSESSMENT REPORT contd.
Location Sensitivity Odour Intensity

Location

Odour Extent

Odour Description

External sources of odour

Waste sources of odour

Odour Intensity
1 2 3 4 5 -No detectable odour -Faint odour (barely detectable, need to stand still and inhale facing into the wind) -Moderate odour (odour easily detected while walking and breathing normally, possibly offensive) -Strong odour (bearable, but offensive odour - will my clothes/hair smell?) -Very strong odour (this is when you really wish you were somewhere else)

Odour Extent (assuming odour detectable, if not then 0)
1 2 3 4 5 -Local and impersistent (only detected during brief periods when wind drops or blows) -Impersistent as above, but detected away from site boundary -Persistent, but fairly localised -Persistent and pervasive up to 50 m from site boundary -Persistent and widespread (odour detected >50 m from site boundary)

Location Sensitivity (assuming detectable, if not then 0)
1 2 3 4 5 -Remote (no housing, commercial/industrial premises or public area within 500 m) -Low sensitivity (no housing, etc. within 100 m of area affected by odour) -Moderate sensitivity (housing, etc. within 100 m of area affected by odour) -High sensitivity (housing, etc. within area affected by odour) -Extra sensitive (complaints arising from residents within area affected by odour)

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APPENDIX C - METEOROLOGICAL DATA

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METEOROLOGICAL DATA
C1 GENERAL

C1.1

This appendix is included as general guidance since it is useful, and usually necessary, to take account of meteorological conditions in determining causes and patterns of odour problems, where they exist. The transport of pollutants from the source to receptor are affected by meteorological variables, or state of the atmosphere in terms of; wind speed and direction; insolation (amount of sunlight); lapse rate (temperature variation with height); mixing depth, and precipitation. The non-meteorological factors such as type and quantity of odorous substances, topography and individual susceptibility must also be considered. It is not intended that full meteorological monitoring should take place at every site.
ATMOSPHERIC STABILITY

C2

C2.1

When considering the dispersion of air pollution or odour plumes, it is convenient to classify the possible states of the atmosphere into stability categories originally defined by Pasquill10. An assessment of the stability category should be made when odour monitoring as this describes the potential for dispersion of odours from a source.

C2.2

Table C2.1 illustrates typical features of each category and the extent of dilution that may be expected under different atmospheric conditions.

C2.3

Stability Categories range from A, the most unstable, though to G, the most stable. •

Category A corresponds to the most unstable atmospheric conditions and results in the greatest amount of plume spreading. Surface heating effects caused by direct sunlight act as an extra source of turbulence over and above that caused by the wind. Category D, a “neutral” category is one where the turbulence is generated entirely by the wind and the degree of mixing will be less than Category A.

Category F/G are stable categories which result in the least spreading of a plume as the mechanical (wind induced) turbulence is suppressed in these conditions.

10

F Pasquill and F B Smith, “Atmospheric Diffusion”, Chichester, Ellis Horwood, 1983

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Table C2.1 Atmospheric Stability Categories

Category

Stability

Dispersion*

Occurrence (% time in year)
<1 5 to 10 20 45 to 60 5-10 10

Wind speed km/h

Time of day

Sunshine or cloud cover

A B C D E F/G

Very Unstable Unstable Slightly Unstable Neutral Stable Very Stable

Very good Good Moderate Moderate Poor Very poor <5 7 to 18 >7 7 to 29 7 to 18 <11

Day time only Day time only Mainly day time Day or night Night time only Night time only

Strong sunshine Most common in summer Slight to moderate sunshine Moderate sunshine Slight sunshine or overcast Clear or overcast Clear (inversion)

* These are generalisations – e.g. Category A, while on average it may result in good dispersion, fluctuations in plume rise may result in localised short-term plugs of odour in the vicinity of the site.

C2.4 The term stability refers to the tendency of the atmosphere to resist or enhance vertical motion and therefore turbulence. Stability is related to both the change of temperature with height, which is often dependent on wind speed and the amount of sunlight and will therefore differ between daytime and nighttime. The turbulence of the atmosphere is important determining the amount of dilution of odours. As a general rule, the more unstable the atmosphere, the greater the dilution and the lower the odour impact of the site. Odour problems are more likely to occur when wind speeds are low and skies are overcast, and at night when stable conditions are more common.

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Table C3

The Beaufort Wind Scale

Force 0

Description Calm

Observation Smoke rises vertically

km/hour <1

1

Light air

Direction of wind shown by smoke drift, but not wind vanes 1-5 Wind felt on face; leaves rustle, ordinary vane moved by wind Leaves and small twigs in constant motion 12 - 19

2

Light breeze

6 - 11

3

Gentle breeze

4

Moderate breeze Fresh breeze

Raises dust and loose paper; small branches are moved Small trees in leaf begin to sway, small branches are moved Large branches in motion; umbrellas used with difficulty Whole trees in motion; inconvenience felt when walking against wind Twigs break off trees; progress generally impeded Slight structural damage occurs (chimney pots and slates removed) Trees uprooted; considerable structural damage occurs

20 - 29

5

30 - 39

6

Strong breeze

40 - 50

7

Near gale

51 - 61

8

Gale

62 - 74

9

Strong gale

75 - 87

10

Storm

88 - 101

C3.1

The above table provides a rough approximation of wind speed in the absence of an anemometer. A rough idea of wind direction can be obtained by observation, e.g. of smoke plumes if appropriate, and reference to OS maps.

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APPENDIX D - ODOUR DESCRIPTORS

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ODOUR DESCRIPTORS

D1.1

The following information is included principally for background interest but also as an aid to officers in their own assessment of odours, particularly in establishing the source of odours other than those from waste management facilities. As indicated in section 5.7, it is useful, when recording information from a complainant, to seek their description of an odour that is offending them. Tables D1 and D2 are derived from American research work11 on odour descriptors which also concludes, as suggested at 2.1.3 in the main body of this document, that both pleasant and unpleasant odours may become offensive. Table D1 lists odour descriptors generally found as pleasant in decreasing order of pleasantness based on “Hedonic scores” allocated by 150 participants in the American research. Similarly, Table D2 lists unpleasant odours in increasing odour of unpleasantness. Table D3 presents the same odour descriptors in alphabetical order so that their pleasant or unpleasant rating is not indicated and would not therefore influence the use of a particular descriptor. Figure D1 presents an “Odour Wheel” which attempts to link recognised waste derived odours with possible sources on waste management facilities.

D1.2

D1.3

D1.4

D1.5

11 Dravnieks A, Masurat T, Lamm R A, “Hedonics of Odours and Odour Descriptors”:, in Journal of the Air Pollution Control Association, July 1984, Vol. 34 No. 7, pp 752-755

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Table D1

“Pleasant” Odour Descriptors and “Hedonic” Score

Description
Bakery (fresh bread) Rose Strawberry Orange Floral Chocolate Fruity, citrus Violets Peach Apple Pineapple Vanilla Cherry Cinnamon Fried chicken Fragrant Lemon Minty, peppermint Popcorn Melon Meaty (cooked, good) Coffee Caramel Pear Maple syrup Lavender Fruity, other than citrus Fresh green vegetables Cologne Herbal, green, cut grass Cedarwood Honey Grape juice Buttery, fresh butter Sweet Almond Banana

Hedonic Description Score
3.53 3.08 2.93 2.86 2.79 2.78 2.72 2.68 2.67 2.61 2.59 2.57 2.55 2.54 2.53 2.52 2.50 2.50 2.47 2.41 2.34 2.33 2.32 2.26 2.26 2.25 2.23 2.19 2.16 2.14 2.11 2.08 2.07 2.04 2.03 2.01 2.00 Spicy Peanut butter Perfumery Grapefruit Coconut Nutty Clove Cooked vegetables Raisins Cool, cooling Aromatic Tea leaves Green pepper Celery Crushed grass Hay Raw cucumber Leather Seasoning (for meat) Oak wood, cognac Anise (liquorice) Bark, birch bark Soupy Caraway Malty Incense Molasses

Hedonic Description Score
1.99 1.99 1.96 1.95 1.93 1.92 1.67 1.58 1.56 1.53 1.41 1.40 1.39 1.36 1.34 1.31 1.30 1.30 1.27 1.23 1.21 1.18 1.13 1.06 1.05 1.01 1.00 Eucalyptus Laurel leaves Soapy Woody, resinous Light Dill Warm Grainy (as grain) Geranium leaves Beany Mushroom Eggy (fresh eggs) Raw potato Musky Black pepper Cork

Hedonic Score
0.99 0.97 0.96 0.94 0.91 0.87 0.78 0.63 0.57 0.54 0.52 0.45 0.26 0.21 0.19 0.19

Note: The higher the positive “score”, the more pleasant the odour descriptor and similarly below, the greater the negative figure, the more unpleasant the odour descriptor.

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Table D2

“Unpleasant” Odour Descriptors and “Hedonic” Score

Description
Dry, powdery Yeasty Burnt candle Beery Rope Garlic, onion Crushed weeds Alcoholic Cardboard Camphor Sauerkraut Fresh tobacco smoke Kippery-smoked fish Turpentine (pine oil) Paint Heavy Nail polish remover Varnish Chalky Medicinal Wet paper Metallic New rubber

Hedonic Description Score
-0.07 -0.07 -0.08 -0.14 -0.16 -0.17 -0.21 -0.47 -0.54 -0.55 -0.60 -0.66 -0.69 -0.73 -0.75 -0.79 -0.81 -0.85 -0.85 -0.89 -0.94 -0.94 -0.96 Seminal, sperm-like Animal Gasoline, solvent Mothballs Sour, vinegar Creosote Bitter Oily, fatty Burnt paper Burn, smoky Etherish, anaesthetic Disinfectant, carbolic Tar Chemical Blood, raw meat Kerosene Cleaning fluid Sooty Musty, earthy, mouldy Fishy

Hedonic Description Score
-1.04 -1.13 -1.16 -1.25 -1.26 -1.35 -1.38 -1.41 -1.47 -1.53 -1.54 -1.60 -1.63 -1.64 -1.64 -1.67 -1.69 -1.69 -1.94 -1.98 Stale Burnt milk Mouse-like Wet wool, wet dog Household gas Sharp, pungent, acid Sulfidic Ammonia Sweaty Dirty linen Fermented (rotten) fruit Stale tobacco smoke Sour milk Burnt rubber Rancid Urine Sickening Faecal (like manure) Cat urine Sewer odour Putrid, foul, decayed Cadaverous (dead animal)

Hedonic Score
-2.04 -2.19 -2.20 -2.28 -2.30 -2.34 -2.45 -2.47 -2.53 -2.55 -2.76 -2.83 -2.91 -3.01 -3.15 -3.34 -3.34 -3.36 -3.64 -3.68 -3.74 -3.75

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Table D3
Alcoholic Almond Ammonia Animal Anise (liquorice) Apple Aromatic Bakery (fresh bread) Banana Bark, birch bark Beany Beery Bitter Black pepper Blood, raw meat Burn, smoky Burnt candle Burnt milk Burnt paper Burnt rubber Buttery, fresh butter Cadaverous (dead animal) Camphor Caramel Caraway Cardboard Cat urine Cedarwood Celery Chalky Chemical Cherry Chocolate Cinnamon Cleaning fluid Clove Coconut Coffee Cologne Cooked vegetables Cool, cooling Cork Creosote Crushed grass Crushed weeds Dill Dirty linen Disinfectant, carbolic Dry, powdery

Odour Descriptors without “Hedonic” Score
Oak wood, cognac Oily, fatty Orange Paint Peach Peanut butter Pear Perfumery Pineapple Popcorn Putrid, foul, decayed Raisins Rancid Raw cucumber Raw potato Rope Rose Sauerkraut Seasoning (for meat) Seminal, sperm-like Sewer odour Sharp, pungent, acid Sickening Soapy Sooty Soupy Sour milk Sour, vinegar Spicy Stale Stale tobacco smoke Strawberry Sulfidic Sweaty Sweet Tar Tea leaves Turpentine (pine oil) Urine Vanilla Varnish Violets Warm Wet paper Wet wool, wet dog Woody, resinous Yeasty

Eggy (fresh eggs) Etherish, anaesthetic Eucalyptus Faecal (like manure) Fermented (rotten) fruit Fishy Floral Fragrant Fresh green vegetables Fresh tobacco smoke Fried chicken Fruity, citrus Fruity, other than citrus Garlic, onion Gasoline, solvent Geranium leaves Grainy (as grain) Grape juice Grapefruit Green pepper Hay Heavy Herbal, green, cut grass Honey Household gas Incense Kerosene Kippery (smoked fish) Laurel leaves Lavender Leather Lemon Light Malty Maple syrup Meaty (cooked, good) Medicinal Melon Metallic Minty, peppermint Molasses Mothballs Mouse-like Mushroom Musky Musty, earthy, mouldy Nail polish remover New rubber Nutty

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Figure D1 Odour Wheel

The odour wheel above makes an attempt to link commonly used descriptors of odours around waste management facilities with the most likely chemical cause and/or origin(s). Note: Butyl mercaptan is listed in the original version of WMP26 as an identified likely constituent of landfill gas. Being a mercaptan, it is highly odorous but the Merck Index merely describes its odour as “Skunk like.” There are very few people who have experienced skunk odour but the author is indebted to the Head Keeper of Exeter Zoo for his colourful descriptions having had first hand experience of the odour. These simplify to “an intense clinging combination of rotting cabbages and rotting onions.”

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APPENDIX E - UNDERSTANDING SMELL

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UNDERSTANDING SMELL This document concentrates on subjective odour monitoring as the initial regulatory procedure for assessing the nature, strength and extent of any odour problems originating from waste management facilities. However, it is important to realise that the ability to detect, and often describe, smells varies from person to person in much the same way as the ability of other senses vary, e.g. sight and hearing. The following is therefore intended as background reading endeavouring to put the perception of smell into perspective and indicate how, at times, it can be misleading or even fail.
E1 Realistic expectations of the nose

Some facts 12 § The nose is considered to be the organ of the sense of smell for the body, but its main function is to adjust inhaled air to body temperature and to humidify it before it goes down into the delicate linings of the lungs. It does this by passing the air through its narrow vascular passages. The average person breathes about 8 litres of air (23,000,000 molecules) every minute and the weight of the daily intake of air has been calculated to be about 13.5 kg. The olfactory chambers, containing the smell receptors, are found at the top of the nose, behind the bridge. The area of the olfactory epithelia (smell cells) is about the size of a postage stamp with half at the top of each nostril. A sniff causes an eddy of air to pass into the upper chamber and any odorous molecules can then come into contact with the olfactory receptors and be detected as smell. In order to be odorous a compound must have a molecular mass of between 15 and 300. For example, alcohol (C2H5OH) with a molecular mass of 46 is odorous, whereas sucrose (C12H22O11), with a molecular mass of 342, is not. So in order to be smelt, molecules must lie within a certain size range, but in order to penetrate the mucous layer covering the smell cells, they must also be soluble in water and lipids. The average person can detect by smell 1 g (7 x 1012 molecules) of butanoic acid (a sweaty, cheesy smell) dispersed uniformly throughout a ten-storey building. The Guinness Book of Records lists vanilla aldehyde (4-hydroxy-3-methoxy benzaldehyde) as the most pungent smell, detectable at 2 x 10-8 mg/litre of air. About 1 drop (2.75 x 10-3 g) would be detectable in an enclosed space 13.7 m high and with the floor area of a football pitch. From the olfactory cells the nerve impulses pass into a complex circuit in the brain called the limbic system. This system is now known to be vital for emotion and motivation states as well as thought and memory processes. People can rapidly say how they feel about a particular smell. The limbic system, although crucial to behaviour, is a non-verbal part of the brain. This fact results in people having difficulty when asked to name a smell. The way the sense of smell links to our brain means that it is primarily controlled by the non-verbal, unconscious stages, and therefore it can affect our behaviour in ways of which we may not be consciously aware.

§ §

§

§ §

§

§

§

12

Source: What the Nose Knows, Steve Van Toller, Biological Sciences Review, May 1995, pp 2-5

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§

Perfumers, who are often chemists, and other professionals for whom the sense of smell is critical, learn to use smell classifications to communicate information about odours, but in general, people perform poorly when asked to name odours. To show just how difficult it is to describe and name smells, ask a person to name ten smells and time how long it takes them to produce their list. Then ask the same person to name ten colours, also against the clock. With another person, reverse the process asking them to name colours first and then smells. You will usually find a great discrepancy in the time it takes for people to list ten items in these two categories, with the smells taking longer to produce. One reason contributing to the difficulty in naming smells is that while colour names are taught to children at a very early age, it would be very unusual, apart from the rather basic “nice” and “nasty”, for a child to be taught smell names.
Odour fatigue

§

§

E2

Odour fatigue can take a number of different forms:§ At one extreme there is the action of gases such as hydrogen sulphide. In hazardous concentrations, the first action of hydrogen sulphide is to paralyse the olfactory nerves rendering the nose unable to detect its rotten egg odour, thus increasing the hazardous potential. At a different level, it is likely that if you wear perfume or aftershave you will quickly become unaware of the perfume given off by your own toiletry. However, you are still likely to be aware of the perfume given off by the toiletry being worn by someone passing close to you and vice versa. In the same way, people working in an odorous situation, such as a waste management facility, will quickly become unaware of their odorous surrounding possibly to the extent that they are unable to detect regular odours.

§

§

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INDEX

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A amenity.............................4, 7, 8, 9, 10, 12, 15, 16 local ..............................................................12 anemometer ................................................. 31, 42 atmospheric conditions ................................ 25, 31 B bar chart ............................................................33 C complainants .....................................................14 complaints ...... 9, 14, 15, 17, 30, 31, 32, 33, 35, 37 compliance ........................................................16 contact form.......................................................30 controlled waste.................................................10 cover...................................................... 11, 24, 25 Criminal Procedure and Investigation Act..........16 D detriment serious....................................................... 8, 10 detriment to amenity..........................................15 diary............................................................ 18, 30 Directive..............................................................4 Framework.............................................. 4, 7, 8 drums .......................................................... 20, 26 Duty of Care ................................................ 13, 27 E emissions....................................................... 9, 12 enforcement................................................. 16, 32 EPA90........................................... 7, 9, 10, 13, 16 exempt................................................. 6, 9, 11, 13 F fire ....................................................................24 flare system .......................................................24 G gas chromatography...........................................15 gas wells............................................................20 GP .....................................................................20 graphical methods..............................................33 H harm.......................................4, 7, 8, 9, 10, 13, 16 health human................................4, 7, 8, 9, 10, 13, 16 Health Environmental ................................ 4, 8, 15, 20 Public..............................................................8 health and safety.......................................... 20, 24 Health and Safety Executive.................................4 health effects......................................................20 hydrogen sulphide..............................................55 I incident form .....................................................30 Odour Guidance for Waste Sites, Version 3.0, July 2002

incompatible ................................................24, 27 inhale..................................................... 32, 34, 37 inspection(s) ...................................... 4, 13, 14, 15 L Landfill gas........................................................24 leachate.................................................. 11, 20, 25 liaison ........................................ 13, 15, 27, 32, 33 licence ........ 4, 6, 7, 8, 9, 10, 11, 12, 15, 16, 30, 32 conditions.............................. 6, 8, 9, 11, 12, 15 limbic system .....................................................54 Local Authority........................................ 9, 15, 20 log book .............................................................30 M mass spectrometry..............................................15 mercaptan ..........................................................50 monitor .................................................. 12, 13, 15 monitoring4, 6, 8, 11, 13, 14, 15, 20, 25, 30, 40, 54 audit..............................................................14 subjective .................................... 10, 14, 15, 30 N Nose expectations of...............................................54 notice.............................................................9, 16 nuisance............................................... 4, 8, 11, 27 Nuisance Statutory..................................................4, 8, 9 O observations.................................................17, 32 odour assessment........ 4, 10, 12, 30, 31, 32, 33, 40, 46 assessment.....................................................54 control............................................. 4, 5, 11, 32 controls ....................................... 4, 7, 8, 11, 15 counteractants ...............................................25 definition.........................................................6 duration.........................................................31 fatigue...........................................................14 location ................ 11, 12, 14, 30, 31, 32, 33, 36 offensive.............................. 4, 9, 11, 12, 13, 15 perception .......................................................4 persistence.....................................................31 plume............................................................32 release of .......................................................11 sources ........................................ 10, 14, 15, 46 strength .........................................................17 odour fatigue......................................................55 offence ....................................... 7, 8, 9, 10, 13, 16 olfactometry.................................................15, 33 olfactory epithelia ..............................................54 operational practices ................................ 4, 11, 33 other sources......................................................15 P Pasquill stability.................................................40 pathways ............................................................10

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planning......................................... 8, 9, 25, 26, 27 Police and Criminal Evidence Act .....................16 pollution ...................................7, 8, 10, 11, 16, 40 pollution of the environment.................... 7, 10, 16 PPG10 .................................................................8 PPG23 .................................................................8 prevailing winds ................................................10 prosecution .................................................. 16, 17 R receptors.......................................... 10, 14, 30, 31 recording ............................................... 14, 30, 31 relevant objective(s) ................................. 4, 7, 8, 9 remedial action ....................................................8 revocation ..........................................................16 risk .........................................4, 10, 11, 13, 24, 33 S samples air 15 scientific...................................................... 10, 15 Section 29...................................... 7, 8, 10, 13, 27 Section 33..........................................................13 Section 37..........................................................16 Section 38..........................................................16 Section 43..........................................................16 sense of smell ....................................................54 site boundary .................. 11, 12, 15, 31, 32, 34, 37 smell detection .......................................................54 most pungent.................................................54 sense of .........................................................54 sources nearby ...........................................................16 statement(s) ..................................... 10, 16, 17, 18 strategy..............................................................15 sulphidic............................................................32 suspension .........................................................16 T tankers...............................................................26 toiletries.............................................................30 trace gases .........................................................32 training.......................................................... 4, 13 transportation ................................................ 4, 27 trenches .................................................... 25, 26 W waste putrescible.....................................................13 special...........................................................13 waste management facility........... 8, 10, 11, 13, 15 Waste Management Paper....................................7 waste regulation authority....................................8 wastes brewery.........................................................27 burning.........................................................24 excavated ...................................................25 food......................................................... 27, 30 Odour Guidance for Waste Sites, Version 3.0, July 2002

odorous .........................................................13 weather conditions ........................... 10, 12, 17, 30 wells ..................................................................25 working face ......................................................25 working plan.................................... 10, 12, 16, 26

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