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SESD ENVIRONMENTAL TESTING Environmental Testing Service 95 Beaver Street Waltham, Mass, 02154 617-893-8339 February 21, 1980 Mr. Robert Blenkhorn Health Agent City of Salem Health Department Kaplan Public Health Center off Jefferson Avenue Salem, Massachusetts 01970 Dear Bob: Enclosed please find the reviesed copy of our report on "The Status of Air Pollution and other Environ- mentally Related Conditions at this South Essex Sewerage DistriWs Cat Cove Treatment Plant". I believe the report is as we discussed, how- ever if you have any questions please call. Very truly yours, Fre erick T. Boyle FTB/fb FEB 2 9 1930 CITY OF SALEM HEALTH oFpr. THE STATUS OF AIR POLLUTION AND OTHER ENVIRONMENTALLY RELATED CONDITIONS AT THE SOUTH ESSEX SEWERAGE DISTRICT'S CAT COVE TREATMENT PLANT REPORT FOR: City of Salem, Board of Health PREPARED BY: Environmental Testing Service 95 Beaver Street " Waltham, .Mass. February 1980 History In order to meet the needs of treating the increasing levels of saw- age produced by the Horth Shore communities of Beverly, Danvers, Peabody, Salem, and Marblehead, thereby complying with the Federal Water Pollution Control Act of 1972 (PL-92500) , the South Essex Sewerage District (SESD) selected the site at Cat Cove, Salem, for the construction of water pollution control facilities. These facilities, designed by the engineering firm of Metcalf & Eddy, Inc. were completed in 1977 and provide for the primary treat- ment, chlorination, sludge dewatering, and incineration for a design flow of 41.0 million gallons per day. At present the SESD has engaged its consultant, Metcalf & Eddy,Inc. , to prepare a facilities plan for providing secondary treatment. Upon initation of sludge incineration in 1975, odor complaints from the surrounding neighborhood were immediately voiced. These complaints continued and increased in number until finally on July 12, 1979 the SESD voted to halt the sludge incineration until effective steps had been taken towards the rec- tification of the odor problem. Until that time, the plant continued to dis- charge screened, partially chlorinated wastewater,;along with 200 tons per day of untreated sludge into Salem Harbor. The discharging of untreated sludge into the Harbor resulted in the imitation of legal action by the Massachusetts Department of Environmental Quality Engineering's Division of Water Pollution i Control from which a Superior Court Order was issued to the SESD ordering them to prohibit the discharging of untreated sludge into the Harbor and to operate I. their complete wastewater treatment plant facilities. During-this time, the .I, SESD was involved in a series of technical meetings with the facility's design engineers (Metcalf & Eddy, Inc.) . the Environmental Protection Agency (EPA), the DEQE, and the Research Corporation (TRC) , the purposes. of which were to determine the causes and solutions to the causes and solutions to the odor problems. The result of these meetings and discussions was that a longer period - 1 - of time was necessary for the proper shakedown of the recently redesigned after- burner mode of operation to improve odor control. During this period a series of equipment and operation procedure modifications were obtained for the minimal re- lease of contaminants into the atmosphere while maintaining peak energy efficiency of the incinerators. It was also decided that the consulting firm of Arthur D. Little Inc. , would be retained to perform extensive odor measurement studies both at the plant and throughout the neighborhood. The DEQE indicated that they too would assist the SESD in the monitoring and surveillance of the odor complaints in the neighborhood. In order to represent the City during this testing period, our firm, the Environmental Testing Service (ETS) was hired. These tests, and documented odor complaints, and other data are necessary for evidence to supp- ort the City's defense should the matter go back to the Superior Court. The incineration of sludge began again on September 17, 1979. Another problem facing the legal operation of the plant is the disposal of the incinerator fly ash. At current operation levels of 200 wet tons of sludge a day, approximately 20 tons of ash are produced a day. The ash is the end re- sult of the incineration of sludge, and is characterized by high levels of metals, of which chromium is the predominant species. Because this fly ash is considered to be toxic, and therefore a hazardous waste, the safe disposal of the ash is imperative. The plant currently disposes of the ash at an onsite concrete encased trench ( the foundation of a prevously used grease pit). The capacity of this trench is rapidily being approached and therefore an alternative disposal site must be selected as soon as possible. The safe disposal of hazardous wastes in Massachusetts is currently a dilema as there 'are no currently approved landfill sites in the State. At present, these wastes must be trucked out of the State which would be at a considerable expense to the SESD (if at all possible) . Alter- native to this would be to shut down the incinerator and by-pass -the sludge back into the Harbor , which would throw the plant back into violation of state and - 2 1 _ federal law. A meeting to specifically address this- issue vas held on November 16, 1979. Topics discussed at this meeting included the illegal dumping of sludge" into the ocean by both the direct ,by-pass of ,rlaw sludge into the ocean outfall, f' and the dumping of the sludge transported into deeper waters via �bsrge and/or d extended outfall. Odor Pollution Although odor quality is a highly subjective, most people can generally sense an odor when present, and relativily characterize it (or them) as being pleasant or obnoxious. Because many odorous compounds can be detected by the human nose in minute concentrations, they can evoke extreme emotional reactions i in people. Offensive odors are capable of producing nausea, vomiting, .and head- ache; curbing the appetite; imparing nutrition; curtailing water uptake; "dis- turbing sleep; hampering proper breathing; and in general, offending the senses and interfering with the enjoyment of property. They may also be indicative of other hidden health hazards which may be more severe or synergistic in their effects. Such as would be the case where a noxious odor was the only humanly detectable manifestation of an air pollution problem. It is for these reasons (in part) that extensive chemical analysis should be performed when an odor problem exists with a suspect source such as a chemical manufacturing or waste processing plant. These analysis also play a crucial part in detecting the source of the problem and setting the course for its elim- ination. However, no analysis or instrumentation has been developed with the sensitivity and versatility of the human nose for odor detection. Therefore, the methods currently used for odor measurement involve personal judgements by one or more people; results are expensive, and lack the desired precision. The mode of expressing observation results is strictly of a qualitative nature. It is based largely upon the olfactory sense without any guide beyond - 3 - the human ability to associate and describe persoal reaction. As a result, odors are often given such descriptive terms as dead-cat, wet-dog, manurial, rotten-egg, spoiled-fish, etc. In addtion, the intensity of the odor problem is often rated on an arbitrary scale of 1 to S. Such a system, ,of course, de- pends to a great extent upon the acuity of the observer's nose, his past ex- periences, and his ability to describe his reaction accurately. The most use- full observation from an engineering point of view is to measure the number of dilutions which are necessary to reduce the odorant to the odor threshold con- centration. This is precisely what the SESD's odor consultant, Arthur D. Little Inc. , was employed to do. Monitoring of Incineration Start-Up What follows is a condensed history of the monitoring and consulting efforts offered by ETS during the inital incinerator start-up and trial period of Sept- ember 17th through the 28th. Following a Board of Health meeting on September 9, 1979, ETS was hired by the City of Salem as air pollution consultants to the Salem Board of Health. ETS's observations during the incinerator start-up would be crucial to the City's legal action in preventing the incinerator's functioning should an air pollution/ odor problem exist. ETS would be responsible for directly reporting to both Mr. Robert Blenkhorn, City Health Agent, and to Mr. William Tinti, City Solicitor. Following this meeting, ETS's Fred Boyle and John Rufo met with David Phillips, the Executive Director of the SESD to review the technical aspects of the problem. ii It was their consensus that sufficient equipment and procedural modifications were in place to allow the start-up of the sludge incineration-at least for the purpose of evaluation. Amoung these modifications most importantly were the following: 1.) `The ad- dition of two sludge grinders to homogenise the flow of sludge from the blending tanks to centrifuges ( and ultimately to the incinerators ) . 2.) The installation - 4 - r of drag chains to the rabble arms of the hearth #3 of incinerator #1 to im- prove sludge distribution and drag out.3.) The raising of hearth incineration temperatures, including the functioning of an afterburner mode. 4.) The instal- lation of re-odorizing systems. 5.) The hiring of an independent consulint, Gregory Leonardos of Arthur D. Little, Inc. , to aid the State DEQE's personnel in monitoring and qualifying the odors in the neighborhood, and to measure and chemically characterize the odors as they are emitted from both the incinerators and process stacks. On September 14, .1979, a meeting was held by the SESD for the purposes of finalizing the monitoring/surveillance program and to bring all parties up to date. Present were representatives from the DEQE Air and Hazardous Waste Div- ision, Division of Water Pollution Control, Salem Board of Health, and Metcalf & Eddy, Inc. Although the State did not produce a formalized written plan to mon- itor the conditions, Bruce Maillet from Air and Hazardous Wastes described the monitoring program as consisting of the placement trained technicians in the neighborhood on a shift basis for twenty-four -hours a day, for two, possibly three.weeks. These technicians would both record all their observations and re- spond directly to compliants. Meterological conditions were to be recorded by instrumentation in place at the New England Power Company. It was also stated that in addition to these technicians, representatives from Arthur D. Little Inc. , and ETS would be on hand intermitently during this two week period. On September 17, 1979, the incineration of sludge was initated and all field personnel were in place. At 8:00 a.m. on this date, Fred Boyle and Ralph Tells of ETS met with Gregory Leonardos of Arthur D, Little Inc. , for the purposes of discussing the technical plans for measuring and evaluating the odor. Mr. Leonardos stated that as soon as the plant had been given a sufficient period of time to get underway, he would set up sampling apparatus which would be used to both chemically' - 5 - I and humanly characterize the odors. Mr. Leonardos employs:the technique of sampling the gases directly onto an adsorbent (chromosorb @) . This material is then transferred to a solvent (pentane) to be later volatilized for the gas chromatographic/mass spectro- graphic analysis of major organics and to determine the presence of EPA pri- ority pollutants. In addition, a sample of the collected gases was taken to be later exposed to an odor panel under the rigid control conditions present in a dynamic test room. Sampling of gases was tenativily slated for September 18. The rest of the day was spent with Mr. Leonardos and a representative of the Salem Board of Health, Jim Lubas, in monitoring the conditions in the neigh- borhood. Although a detailed transcript of the day's investigations is append- ixed in this report, a summary of those observations is included here. It is our conclusion that upon investigation, nearly all recorded complaints (at least to the odor's presence) had validity on this day. Indeed, a variety of odors emanated from within the plant: These odors were characterized as both "fecal, burnt hair, burnt paper, and perfume-lilac". The intensity of these odors varied from barely detectable to moderately unpleasant. It should be noted that throughout the day, oily odors (apparently from the adjacent tank farm) were observed at the intersection of Fort and Memorial Drive. It should also be noted that the "perfume-lilac" odors originating from the reodorizing system. does not mask the odors but was observed to simply add to them. In mid-afternoon, the plant experienced an I.D. fan shut-down which neces- sitated the shut-down of incinerator #1. Because of this shut-down, sampling for the following day was cancelled. 0n September 18, incinerator #2 was brought up to temperature while #1 was being repaired. Sampling of gases took place on September 28. Samples were taken at the primary tank ozonator exhaust, sludge ozonator exhaust, incinerator #1 scrubber exhaust, and on incinerator #1's pre- scrub. At the time incinerator #1 had been modified to have hearth #1 operate as an afterburner. During the rest of the day various odors were detected in the 6 neighborhood." 'On October 3, 1979, the I.D. fan quit again .on incinerator #1, and therefore #2 was fired up to take its place. On October 4, 1979 numerous complaints were received following incinerator #21s start-up. Add- �. itional odor measurements were carried out on October 23 during the operation of incinerator #2. As is was suspected that''some of the odors may have been I stripped out of the effluent water used in the scrubber exhaust, the addition of potassium permanganate (KMnO,4) was added',to enhance oxidation. Samples were taken on incinerator #2 both with and without the addition of KMn04. Testing Procedures & Evaluations I. Odor Evaluations - Arthur D. Little, Inc. The report prepared by Arthur D. Little, Inc. , entitled 'Odor Evaluations, Report to the South Essex Sewerage District Board", has concluded that "the Incin- erator #2 (no afterburner) scrubber exhaust is the major odor source at the SESD plant at the existing level of operation. Odors from this source are described as burnt meaty, burn.'.t fatty pungent, and have been observed at a moderate (2) level on Fort Avenue, and in the slight (1) intensity range on both Memorial Drive, and on Essex Street. These are at the complaint level. Odors from Incinerator #1 (no afterburn) are of different quality ( soapy phenolic, pungent) and have been observed in the community up to the alight (1) intensity as a maximum. This odor was observed leas frequently than that of the other sources. Taking into consideration, the frequency, ambient intensity and quality, we would consider this source to be at a boarderline complaint level. . ." "The addition of potassium permanganate, (KMn04) to the effluent water in J the Incinerator #'2 (no afterburner) scrubber was of virtually no benefit due to 13 the high odor load in the incinerator exhaust. I a Odors from the primary tank ozonator outlet (chlorinated sewage, solventy and occasionally fecal, animal sour type odors) , and the sludge process ozonator -7- f 4 outlet (chlorinated sewage, solventy and occasionally fecal, animal sour type � Q lig odors) , and the sludge process ozonator outlet (fecal, sulfide pungent) , were observed in the community, as in the past at complaint levels. The reodorant system that has been installed at the SESD plant has not one- ; ceeded in improving the odor situation. Both the odors of the perfume and of the sewage treatment plant can be recognized in the community. The reodorant material does not "mask" nor "counteract" the sewage odors. It should also be pointed outduring the course of our surveys, fuel oil re- lated odors described as asphalt tarry, oil, and mercaptan, have been observed in the neighborhood at up to moderate (2) intensity levels. These odors which appear to be from the tank farm off Fort Avenue are at complaint levels. GCMS analysis of the organic componedts present in the primary tank ozon- ator outlet, the sludge process ozonator outlet, and before and after the acub- her of Incinerator#1 (afterburner mode) were carried out to identify the major , chemical species that were present and to search for the presence of EPA pri- ority pollutants. The Incinerator #1 prescrub sample which had the lowest odor of the samples evaluated, also showed a low organic content. Allyl phenol, napthalene and methyl napthalene were found but in very small quantities. The two ozonator outlet samples and the Incinerator #1 scrubber exhaust were heavily loaded with hydro- carbon material, to the point of rendering analysis for other species rather difficult. The hydrocarbon material was primarily aliphatic, with a large second- ary component of alkylated benzenes. These and other components identified are consistent with fuel oil and/or petrochemical solvents. A total of eleven pri- mary pollutants were identified in the Incinerator #1 scrubber exhaust". Il Air Pollution Test Report_- Environmental Laboratories. Inc. The conclusion of the report entitled,"Air Pollution Test Report on the Sewage Sludge Incinerators, No. 's 1 & 2 at the South Essex Sewerage District", _ 8 . by Environmental Laboratories, Inc. , states that "both units (incinerators No.s l & 2) are performing within the visual and particulate emission limit- I , � ations of the Massachusetts Department of Environmental Quality Engineering, when used to bum waste as introduced during the testa." These testa were run on April 17, and 18, 1979. They do not indicate any compliance of the plant in conforming to State Air Pollution Control Regualtion No.9 in regards to odor control which states that " No person having control of any duet or .odor gen- erating operations such as, but not limited- to asphalt batching plants, asphalt roofing materials manufacturing plants, asphalt blowing plants, foundaries, chemical manufacturing planta, incinerators, fossil fuel utilization facilities, wood products plants, dry cleaning establishments, paint and varnish manufact- uring planta, paper manufacturing plants, leather manufacturing plants, concrete batching plants, metal coating and treatment plants, land clearing operations, construction work, dump operations, building demolition, and agricultural operations shall permit emissions therefrom which cause, or contribute to a condition of air pollution." Air pollution is defined as "the presence in the ambient air space of one or more air contaminants or combinations thereof in such concentra- tions and of such duration as to: a. cause a nuisance; b. be injurious, or be on the basis of current information, potentially injurious to human or animal life, to vegitation, or to property; or c. unreasonably interfere with the comfortable enjoyment of life and property or the conduct of business." It should be noted that this regulation was amended to its"'present form on September 1, 1972. Although the inital design of the plant began in 1968, con- struction was not initated until 1973, and the plant was not operational until 1977, so that this information was published and available. q I I 9 - _.., I I � Evaluation A review of the testing and analytical reports compiled to date relating u ' to the atmospheric impact of the burning of sludge at the SESD leads one to conclude that while there Are no violations of the visual and particulate emir- son limitations as promulgated by the Mass. Department of Environmental Quality Engineering, there are releases of odors, which at times, are justifyably at I complaint level and should therefore be in violation of State code. The impact of odors are far-reaching. Noxious and foul odors can ruin personal and community pride, interfere with human relations, discourage cap- itol investment, lower socioeconomic status, and devalue market and rental pro- perty values. Some of these problems are already evident in the Willows neigh- borhood area. It is for these reasons that a solution to the odor problem at the SESD plant should be considered a top priority. Just as important, however, is the prevention of continued pollution of our coastal waters. A solution to the odor problem is therefore not as simple as closing down the plant. There are solutions to these problems however difficult they may be to reveal at first. Corrective Course of Action Two major corrective methods being pursed by the SESD include: 1. The raising of the stacks in order to facilitate the lofting of the plume out of the neighborhood and increasing its vulnerability for dispersion. 2. The use of an afterburner mode on the incinerator in order to ensure complete combustion of odorous organic compounds. Because of the heavy energy requirements neces- sary to fuel an afterburner, the use of this mode is being considered only for use when the meterological conditions are such that the plume is pointed landward. Problems which should be considered in implementing these two methods are: 1. The effects of "downwash"of the plume from the adjacent New England Power Com- pany stack. 2. The mode of meterological monitoring for afterburner operation. 10 - a � I. 3. This corrective course of action does not respond to the "process odors", i.e. primary tank and sludge ozonator exhausts. Plume Downwash The influence of turbulance around a building or stack can significantly alter the stack's effective height. This is especially true with high winds, when the benifical effect of high stack gas velocity is at a minimum and the plume is emitted horizontally. The City of Salem must be given assurance that all meterological conditions of the local environs be taken into effect in the redesign of the effective stack height. Monitoring Meterolsgical Conditions For Afterburner Operation It has been propsed that because of the extreme expense involved in the operation of the afterburner mode of operation, that afterburning takes place only when the wind is blowing in the direction of the land. In order to assure that this procedure does not become a "haphazard throwing of switches" the SESD should seriously consider the automation of the afterburner's functioning. Process Odors The odors emitted by the primary tank and sludge ozonator exhausts have been described in the odor evaluation prepared by Arthur D. Little, Inc. , as the most significant aside from the operation of incinerator #2 with no after- burner. These odors are grouped together as "process odors" because they are con- sidered to be normally expected from these processes. As such, we 'should not� expeet to eliminate them to any greater extent then they already are via oxonization without a substantial capitol outlay. A variety of control strategies for reducing these "process odors" have been suggested by the Department of Environmental Quality Engineering and others. These include the raising of the stack height to 125 feet and/or the instal- lation of a charcoal filter scrubber system. - 11 - Additional Areas For Further Consideration The iattempt, at chemical control of the odors through the addition of 'an i1 oxidizing catalyst (KMnO4) was a worthwhile attempt. However, relative to the sampling performed by Arthur D. Little Inc. , on p.12, the report points out that "It is possible that treatment of the scrubber water with KMnO4 or other oxid- izing material may have benifit in reducing odors from the effluent water. How- ever, this appliea only to incinerator #1 which operates in the afterburner mode". R. Our question is this: Why then was testing with KMnO4 performed on incinerator #2 Y Should subsequent analysis prove that a substantial reduction in odor results, then carefull consideration should be given to weighing the economic effects of the addition of KMnO4 to the scrubber water against increasing the incineration temperature of the afterburner mode. Relative to the belief that "odors are being stripped from the effluent water and/or formed by the action of hot gas on the organics found in the effluent water", additional testing could be performed with the use of a freshwater supply for the duration of the test to prove this. However, this testing may only be a moot point, as the use of freshwater for the scrubber in the volume required supplied by the City would not be feasible at this point. The City should how- ever be aware of the ramifications of the need to supply the water should this become necessary. The consideration of a closed loop system of scrubber water with its own purification system versus the use of an afterburner mode could also be studied. In the future, the use of secondarily treated water maybe clean i enough to phase out the closed loop system and/or afterburner mode. i Finally, in the area of the disposal of fly ash, the City must be given adeguate assurance that this material is disposed of in an environmentally safe manner, with no risk of leaching into the water table or adjacent watercourses I' or otherwise transporting into the general environment. - 12 APPENDIX i I k Odorl lsurvey Observations Monday, September 17.1979 10:45 a.m. Leavy sewage odor by open grit chamber doors (subsequently closed) . t 11:00 a.m. Detected steady puffs of odor (chlorinated sewage) at entrance dto plant- #53-57 Fort St. i 11:15 a.m. Odor barely present at Oat Cove Marine Station fencelline. 11:30 a.m. Detected 'stong odor from #4 ozonator at north -corner of plant. 12:50 a.m. With plume directly over head, sewage odor present. as 2:45 p.m. High odor at #57 Fort Street. '' 3:00 p.m. Fuel oil mixed with sewage odor at corner of Memorial and Fort St. 3:15 p.m. Heavy perfume odor by #57 Fort Street. 3:17 p.m. Heavy asphalt/fuel oil odor at corner of Memorial and Fort St. 3:25 p.m. Fecal/tannery odor along fence line-just shy of grease pita. 3:27 p.m. Burnt paper odor in front of plant near turn-around in lot. 3:30 p.m. Heavy perfume odor in front of plant. 3:35 p.m. Chlorinated sewage odor in front of building. 4:45 p.m. Oil odor moderate corner of Columbus & Memorial. Friday, September 28.1979 8:30 a.m. Sludge incineration instated. 8:35 a.m. Reodorizers shut off. 9:30 a.m. Began gas sampling at #3 ozonator. Strong sewage odor noted in front of plant, atributed to grit truck spill. 10:00 a.m. ' Began gas sampling at #4 ozonator. While on roof the ,H2S alarm went off, although an odor was not detected. 10:10 a.m. Faint chlorinated sewage odor from #4 ozonator. 10:20 a.m. Faint chlorinated sewage odor at 77 Fort Ave. II r - - ---r� - *-�. 10:25 1a.m. Perfume odor by Electric towers on Fort Ave. 10:30 a.m. Faint burn't hair smell on top of hill. 10:45 a.m.' dight soapy pungent odor on hill. 11:00 a.m. Oil/Fuel odor along Memorial. F 11:151a.ml 'I On Larkin Lane #12 a Mrs Shaw noted that "there were no odors today". 1:35 p.m. q Started incinerator sampling at scrubber outlet on roof. I it 1:40 P.M. Still no complaints received on telephone. 2:47 p.m. Sampling started on prescrub. 3:45 p.m. Slight soapy pungent odor noted near administration building. I P u I i III I I a,li� r. I FMCEI VED JAN 141980 CITY of SALEM HEALTH DEPT, THE STATUS OF AIR POLLUTION AND OTHER ENVIRONMENTALLY RELATED CONDITIONS AT THE SOUTH ESSEX SEWERAGE DISTRICT'S CAT COVE TREATMENT PLANT DRAFT REPORT FOF: City of Salem, Board of Health PREPARED BY: Environmental ,Testing Service 95 Beaver Street Waltham, Mass. January 1980 History In order to meet the needs of treating the increasing levels of sew- age produced by the North Shore communities of Beverly, Danvers, Peabody, Salem, and Marblehead, thereby complying with the Federal Water Pollution Control Act of 1972 (PL-92500) , the South Essex Sewerage District (SESD) selected the site at Cat Cove, Salem for the construction of water pollution control facilities. These facilities, designed by the engineering firm of Metcalf & Eddy, Inc. were completed in 1977 and provide for the primary treat- ment, chlorination, sludge dewatering, and incineration for a design flow of 41.0 million gallons per day. At present the SESD has engaged its consultant, Metcalf & Eddy, Inc. , to prepare a facilities plan for providing secondary treatment. Upon initation of sludge incineration in 1978, odor complaints from the surrounding neighborhood were immediatley voiced. These complaints continued and increased in number until finally on July 12, 1979 the SESD voted to halt the sludge incineration until effective steps had been taken towards the rec- tification of the odor problem. Until that time, the plant continued to dia- charge screened, partially chlorinated wastewater, along with 200 tons per day of untreated sludge into Salem harbor. The discharging of untreated sludge into the harbor resulted in the initation-of legal action by the Maasachusettes Department of Environmental Quality Engineering's Division of Water Pollution Control from which a Superior Court order was issued to the SESD ordering them to prohibit the discharging of untreated sludge into the harbor and to operate their complete wastewater treatment plant facilities. During this time the SESD was involved in a series of technical meetings with the facility's design engineers (Metcalf & Eddy, Inc.) , the Environmental Protection Agency (EPA) , the DEQE, and the Reasearch Corporation (TRC) , the purpoies of which were to determine the causes and solutions to the odor problems. The result of ti,ese meetings and discussions was that a longer period of time was necessary for the proper shakedown of the recently redesigned afterburner mode of inciner- ation to improve odor control. During this period a series of equipment and operation procedure modifications were elated for evaluation so as to assure that optimum conditions were obtained for the minimal release of contaminants into the atmosphere while maintaining peak energy efficiency of the inciner- store. It was also decided that the consulting firm of Arthur D. Little Inc. , would be retained to perform extensive odor measurement studies both at the plant and throughout the neighborhood. The DEQE indicated that they too would assist the SESD in the monitoring and sureillance of the odor complaints in the neighborhood. In order to represent the City during this testing period, our firm, the Environmental Testing Service (ETS) was hired. These tests, and documented odor complaints, and other data are necessary for evidence to sup- port the Cit 1,s defense should the matter go back to the Superior Court. The incineration of sludge began,again, on September 17, 1979. Another problem facing the legal operation of the plant is the disposal of the incinerator fly ash. At current operation levels of 200 wet tons of sludge a day, approximately 20 tone of ash are produced a day. The ash is t'!e end result of the incineration of sludge, and is characterized by high levels of metals, of which chromium is the predominant species. Because this fly ash is considered to be toxic, and therefore a hazardous waste, the safe disposal of the ash is imperative. The plant currently disposes of the ash at an on- site concrete encased trench ( the foundation of a previously used grease pit) . The capacity of this trench is rapidily being approached and therefore an alter- native disposal site must be selected as soon as possible. The safe disposal of hazardous wastes in Massachusettes is currently a dilema as there are no cur- rently approved landfill sites in the State. At present these wastes must be trucked out of the State which would be at a considerable expense to the SESD (if at all possible) . Alternative to this would be to shut down the incinerator and by-pass the sludge back into the harbor, which would throw the plant back into violation of state and federal law. A meeting to specifically address this issue was held on November 16,1979. Topics discussed at this meeting included the illegal dumping of sludge into the ocean by both the direct by-pass of raw sludge into the ocean outfall, and the dumping of the sludge transported into deeper waters via barge and/or extended outfall. Odor Pollution Although odor quality is highly subjective, most people can generally sense an odor when present, and relativily characterize it (or them) as being plesant or obnoxious. Because many odorous compounds can be detected by the human nose in minute concentrations, they can evoke extreme emotional reactions in people. Offensive odors are capable of producing nausea, vomiting, and head- ache; curbing the appetite; imparing nutrition; curtailing water uptake;• dis- turbing eleep;* hampering proper breathing; and in general, ofending the senses and interfering with the enjoyment of property. They may also be indicative of other hidden health hazards which may be more severe or synergistic in their effects. Such as would be the case where a noxious odor was the only humanly detectable manifestation of an air pollution problem. It is for these reasons (in part) that extensive chemical analysis s'.ould be performed when an odor problem exists with a suspect source such as a chem- ical manufacturing or waste processing plant. These analysis also play a crucial part in detecting the source of the problem and setting. the course for its elim- ination. However, no analysis or instrumentation has been developed with tree sensitivity and versatility of the human nose for odor detection. Therefore, the methods currently used for odor measurement involve personal judgements by one or more people; results are expensive , and lack the desired precision. The mode of expressing observation results is strictly of a qualitative nature. It is based largely upon the olfactorry sense without any guide beyond the human ability to associate and describe personal reaction. As a re- sult, odors are often given such descriptive terms as dead-cat, wet-dog, manurial, rotten-egg, spoiled-fish, etc. In addition, the intensity of the odor problem is often rated on an arbitrary scale of 1 to 5. Such a system, of course , depends to a great extent upon the acuity of the observer's nose , his past experiences , and his ability to describe his reaction accurately. The most usefull observation from an engineering point of view is to measure the number of dilutions which are necessary to reduce the odorant to the odor thre- shold concentration. This is precisely what the SESD's odor consultant, Arthur D. Little Inc. , was employed. to do. Monitoring of Incineration Start-Un What follows is a condensed history of the monitoring and consulting ef- forts offered by ETS during the inital incinerator start-up and trial period of September 17th through the 28th. Following a Board of Health meeting on September 9, 1979, ETS was hired by the City of Salem as air pollution consultants to the Salem Board of Health. ETS 's observations during the incinerator start-up would be crucial to the City's legal action in preventing the incinerator's functioning should an air pollution/ odor problem exist. ETS would be responsible for directly reporting to both Mr. Robert Blenkhorn, City Health Agent, and to Mr. William Tinti, City Solicitor. Following this meeting, ETS 'e Fred Boyle and John Rufo met with David Phillips, the Executive Director of the SESD to review the technical aspects of the pro- blem. It was their consensus that sufficient equipment and procedural modific- ations were in place to allow the start-up of the sludge incineration at, least .for the purpose of evaluation. Amoung these modifications most importantly were the following: 1.) The addition of two sludge grinders to homogenize the flow of sludge from the blending tanks to centrifuges (and ultimately to the incinerators) . 2.) The installation of drag chains to the rabble arms of the hearth #3 of incin- erator #1 to improve sludge distribution and drag out. 3.) The raising of hearth incineration temperatures, including the functioning of an afterburner mode. 4.) The installation of re-odorizing systems. 5.) The hiring of an inde- pendent consultant, Gregory Leonardos of Arthur D. Little Inc. , to aid the State DEQE's personnel in monitoring and qualifying the odors in the neigh- borhood, and to measure and chemically characterize the odors as they are emit- ted from both the incinerators and process stacks._ On September 14, 1979 a meeting was held by the SESD for the purposes of finalizing the monitoring/surveillance program and to bring all parties up to date. Present were representatives from the DEQE Air and Hazardous Waste Division, Division of Water Pollution Control, Salem Board of Health, and Metcalf & Eddy. Although the state did not produce a formalized written plan to monitor the conditions, Bruce Maillet from Air and Hazardous Wastes describ- ed the monitoring program as consisting of the placement of trained technicians in the neighborhood on a shift basis for twenty-four hours a day, for two, possibly three weeks. These technicians would both record all their observa- tions and respond directly to complaints. Meterological conditions were to be recorded by instrumentation in place at the New England Power Company. It was also stated that in addition to these technicians, representatives from Arthur D. Little Inc. , and ETS would be on hand intermitently during this two week period. On September 17, 1979, the incineration of sludge was initated and all field personnel were in place. At 8:00 a.m. on this date , Fred Boyle and Ralph Tells of ETS met with Gregory Leonardos of Arthur D. Little Inc. , for the pur- poses of discussing the technical plans for measuring and evaluating the odor. Mr. Leonardos stated that as soon as the plant had been given a sufficient per- iod of time to get underway, he would set up,sampling apparatus which would be used to both chemically and humanly characterize the odors. Mr. Leonardos employs the technique of sampling the gases directly onto an adsorbent (chromosorb @) . This material is then transfered to a solvent (pentane) to be later volatilized for the gas chromatographic/mass spectro- photometric analysis of major organics and to determine the presence of EPA priority pollutants. In addition,a sample of the collected gases was taken to be later exposed to an odor panel under the rigid control conditions pre- sent in a dynamic test room. Sampling of gases was tenativily slated for Sept- ember 18. The rest of the day was spent with Mr. Leonardos and a representative of the Salem Board of Health, Jim Lubas, in monitoring the conditions in the neighborhood. Although a detailed transcript of the hay.'s investigations is appendixed in this report, a summary of those observations is included here. It is our conclusion that upon investigation nearly all recorded complaints (at least to the odor's presence) had validity on this day. Indeed, a variety of odors emanated from within the piant's boarders. These odors were charact- erized as both "fecal, burnt hair, burn't paper,and perfume-lilac". The inten- sity of these odors varied from barely detectable to moderately unpleasant. It should be noted that throughout the day, oily odors (apparently from the ad- jacent tank farm) were observed at the intersection of Fort and Memorial drive. It should also be noted that the "perfume-lilac" odors originating from the re- odorizing system,does not mask the odors but was observed to simply add to them. In mid-afternoon, the plant experienced an I.D. fan shut -down which nec- essitated the shut-down of incinerator #1. Because of this shut-down, sampling for the following day was cancelled. On September 18, incinerator #2 was brought up to temperature while #1 was being repaired. Sampling of gases took place on September 28. Samples were taken at the primary tank ozonator exhaust, sludge ozonator exhaust, incinerator #1 scrubber exhaust, and on incinerator i61 '3 pre-scrub. At the time incinerator #1 had been modified to have hearth #1 oper- ate as an afterburner. During the rest of the day various odors were detected in the neighborhood, although no complaints were received. On October 3, 1979 the I.D. fan quit again on incinerator #1, and therefore #2 was fired up to take its place. On October 4, 1979 numerous complaints were received following incinerator #2 's start-up. Additional odor measurements were carried out on October 23 during the operation of incinerator #2. As is was sus- pected that some of the odors may have been stripped out of the effluent water used in the scrubber exhaust, the addition of potassium permanganate (KMnO4) was added to enhance oxidation. Samples were taken on incinerator #2 both with and without the addition of KMnO4. Testing Procedures & Evaluations I. Odor Evaluations- Arthur D. Little Inc. The report prepared by Arthur D. Little Inc. , entitled "Odor Evaluations, Report to the South Essex Sewerage District Board", has concluded that "the Incinerator #2 *(no afterburner) scrubber exhaust is the major odor source at the SESD plant at the existing level of operation. Odors from this source are des- cribed as burnt meaty, burn't fatty pungent, and have been observed at a moder- ate (2) intensity level on Fort Avenue, and in the slight (1) intensity range on both Memorial Drive , and on Essex Street. These are at complaint level. ' Odors from Incinerator #1 (no afterburn) are of different quality (soapy phenolic, pungent) and have been observed in the community up to the slight (1) intensity as a maximum. This odor was observed less frequently than that of the other sources. Taking into consideration, the frequency, ambient intensity, and quality, we would consider this source to be at a boarderline complaint level and suspect the community would tolerate the odor. The addition of potassium permanganate (KMnO4) to the effluent water in the Incinerator #2 (no after burn) scrubber was of virtually no benefit due to the high odor load in the incinerator exhaust. Odors from the primary tank ozonator outlet (chlorinated sewage, solventy and occasionally fecal, animal sour type odors) and the sludge process ozon- ator outlet ( fecal, sulfide pungent) , were observed in the community, as in the past at complaint levels. The reodorant system that has been installed at the SESD plant has not succeeded in improving the odor situation. Both the odors of the perfume and of the sewage treatment plant can be recognized in the community. The reodor- ant material does not "mask" nor "counteract" the sewage odors. It should also be pointed out that during the course of our surveys, fuel oil related odors described as asphalt tarry, oil, and mercaptan, have been observed in the neighborhood at up to moderate (2) intensity levels. These odors which appear to be from the tank farm off Fort Avenue are at com- plaint levels. GGMS analysis of the organic components present in the primary tank ozon- ator outlet, the sludge process ozonator outlet, and before and after the scrubber of Incinerator #1 (afterburner mode) were carried out to identify the major chemical species that were present and to search for the presence of EPA priority pollutants. The Incinerator #1 prescrub sample which had the lowest odor of the samples evaluated also showed a low organic content. Allyl phenol, naphthalene and methyl naphthalene were found but in very small quantities. The two ozonator outlet samples and the Incinerator#1 scrubber exhaust were heavily loaded with hydrocarbon material, to the point of rendering analysis for other species rather difficult. The hydrocarbon material was primarily aliphatic, with a large sec- ondary component of alkylated benzenes. These and other components identified are consistent with fuel oil and/or petrochemical solvents. A total of eleven primary pollutants were identified in the Incinerator #1 scrubber exhaust." II. Air Pollution Teat Report - Environmental Laboratories Inc The conclusion of the report entitled, "Air Pollution Teat Report on the Sewage Sludge Incinerators, No. 's 1 &2 at the South Essex Sewerage District", 1 by Environmental Laboratories, Inc. , states that "both units (incinerators No.s 1 & 2) are performing within the visual and particulate emisson limit- ations of the Massachusetts Department of Environmental Quality Engineering, when used to burn waste as introduced during the tests'.' These tests were run on April 17, and 18, 1979. They do not indicate any compliance of the plant in conforming to State Air Pollution Control regulation No.9 in regards to odor control which states that "No person having control of any dust or odor generating operations such as, but not limited to asphalt batching plants, asphalt roofing materials manufacturing plants, asphalt blowing plants, found- cries, chemical manufacturing plants, incinerators, fossil fuel utilization facilities, wood products plants, dry cleaning establishments, paint and var- nish maunfacturing plants, paper manufacturing plants, leather manufacturing plants, concrete batching plants, metal coating and treating plants, land clearing operations, construction work, dump operations, building demoliton, and agricultural operations shall permit emissions therefrom which cause or contribute to a condition of air pollution." Air pollution is defined as " the presence in the ambient air space of one or more air contaminants or combinations thereof in such concentrations and of such duration as to: a. cause a nuisance; b. be injurious, or be on the basis of current information, pot- entially injurious to human or animal life, to vegitation, or to property; or c. unreasonably interfere with the comfortable enjoyment of life and property or the conduct of business." It should be noted that this regulation was amended to its present form on September 1, 1972. Although the inital design of the plant began in 1968, construction was not initated until 1973, and the plant was not operational until 1977, so that this information was published and available. Evaluation A review of the testing and analytical reports compiled to date re- lating to the atmospheric impact of the burning of sludge at the SESD leads one to conclude that while there are no violations of the visual and part- iculate emisson limitations as promulgated by the Mass. Dept. of Environ- mental Quality Engineering, there are releases of odors, which at times, are justifyably at complaint level and should therefore be in violation of State code. The impact of odors are far-reaching. Noxious and foul odors can ruin personal and community pride, interfere with human relations, discourage cap- itol investment, lower socioeconomic status, and devalue market and rental pro- perty values. Some of these problems are already evident in the Willows neigh- borhood area. tt is for these reasons that a solution to the odor problem at the SESD plant should be considered a top priority. Just as important, however, is the prevention of continued pollution of our coastal waters. A solution to the odor problem is therefore not as simple as closing down the plant. There are solutions to these problems however difficult they may be to reveal at first. It is our opiniorr that the SESD be given an extended period of time to test and evaluate these solutions. We believe that the present course of action being taken by the Board is worth pursing. Corrective Course of Action Two major corrective methods being pursued by the SESD include: 1. The raising of the stacks in order to facilitate the lofting of the plume out of the neighborhood and increasing its vulnerability for dispersion. 2. The use of an afterburner mode on the incinerator in order to ensure complete combust- ion of odorous organic compounds. Because of the heavy energy requirements necessary to fuel an afterburner, the use of' this mode is being considered only for use when the meterological conditions are such that the plume is pointed landward. Problems which should be considered in implementing these two methods are: 1. The effects of "downwash" of the plume from the adjacent New England Power Company stack. 2. The mode of meterological monitoring for afterburner operation. 3. This corrective course of action does not respond to the "process odors", i.e. primary tank and sludge ozonator exhausts. Plume Downwash The influence of turbulance around a building or stack can significantly alter the stack's effective height. This is especially true with high winds, when the benifical effect of-high stack gas velocity is at a minimum and the plume is emitted horizontally. The City of Salem must be given assurance that all meterological conditions of the local environs be taken into effect in the redesign of the effective stack height. Monitoring,Meterological Conditions for Afterburner Operation It has been proposed that because of the extreme expense involved in the operation of the afterburner mode of operation, that afterburning takes place only when the wind is blowing in the direction of the land: In order to assure that this procedure does not become a "haphazard throwing of switches" the SESD should seriosly consider the automation of the af4trburner's functioning. Process Odors The odors emitted by the primary tank and sludge ozonator exhausts have been described in the odor evaluation prepared by Arthur D. Little, Inc. , as the most significant aside from the operation of incinerator #2 with no after- burner. These odors are grouped together as "process odors" because they are con- sidered to be normally expected from these processes. As such we should not ex- pect to eliminate them to any greater extent then they already are via ozoniz- ation without a substatial capitol outlay. Additional Areas for Further Consideration The attempt at chemical control of the odors through the addition of an oxidizing catalyst (MnO 4) was a worthwhile attempt. However, relative to the sampling performed by Arthur D. Little Inc. , on p. 12 the report points out that "It is possible that treatment of the scrubber water with KMnO4 or other oxidizing material may have benifit in reducing odors from the effluent water. However, this applies only to incinerator #1 which operates in the afterburner mode." Our question is this: Why then was testing with KMnO4 performed on incin- erator #2? Should subsequent .analysis prove that a substantial reduction in odor results, then carefull consideration should be given to weighing the economic ef- fects of the addition of KMn04 to the scrubber water against increasing the incin- eration temperature of the afterburner mode. Relative to the belief that" odors are being stripped from the effluent water and/or formed by the action of hot gas on the organics found in the effluent water', additional testing could be performed with the use of a freshwater supply for the duration of the test to prove this. However, this testing may only prove a moot point, as the use of freshwater for the scrubber in the volume required supplied by the City would not be feasible at this point. The City should however be aware of the ramifications of the need to supply the water should this become neces- sary. The consideration of a closed loop system of scrubber water with its own purification system versus the use of an afterburner mode could also be siudied. In the future, the use of secondarily treated water may be clean enough to phase out the closed loop system and/or afterburner mode. Finally, in the area of the disposal of fly ash, the city must be given ade- quate assurance that this material is disposed of in an environmentally safe man- ner, with no risk of leaching into the water table or adjacent watercourses. APPENDIX Odor Survey Observations Monday, September 17,1979 10:45 a.m. Heavy sewage odor by open grit chamber doors (subsequently closed) . 11:00 a.m. Detected steady puffs of odor (chlorinated sewage) at entrance to plant- 953-57 Fort St. 11:15 a.m. Odor barely present at Cat Cove Marine Station fence line. 11:30 a.m. Detected stong odor from #4 ozonator at north corner of plant. 22:50 a.m. With plume directly over head, sewage odor present . 2:45 p.m. High odor at.i657 Fort Street. 3:00 p.m. Fuel oil mixed with sewage odor at corner of Memorial and Fort St. 3:15 p.m. Heavy perfume odor by #57 Fort Street. 3:17 p.m. Heavy asphalt/fuel ail odor at corner of Memorial and Fort St. 3:25 p.m. Fecal/tannery odor along fence line-just shy of grease pits. 3:27 p.m. Burnt paper odor in front of plant near turn-around in lot. 3:30 p.m. Heavy perfume odor in front of plant. 3:35 p.m. Chlorinated sewage odor in front of building. 4:45 p.m. Oil odor moderate corner of Columbus & Memorial. Friday, September 28,1979 8:30 a.m. Sludge incineration initated. 8:35 a.m. Reodorizers shut off. 9:30 a.m. Began gas sampling at #3 ozonator. Strong sewage odor noted in front of plant, atributed to grit truck spill. 10:00 a.m. Began gas sampling at X64 ozonator. While on roof the H2S alarm went off, although an odor was not detected. 10:10 a.m. Faint chlorinated sewage odor from #4 ozonator. 10:20 a.m. Faint chlorinated sewage odor at 77 Fort Ave. 10:25 a.m. Perfume odor by Electric towers on Fort Ave. 10:30 a.m. Faint burnt hair smell on top of hill. 10:45 a.m. Slight soapy pungent odor on hill. 11:00 a.m. Oil/Fuel odor along Memorial. 11:15 a.m. On Larkin Lane #12 a Mrs. Shaw noted that "there were no odors today". 1:35 p.m. Started incinerator sampling at scrubber outlet on roof. 1:40 p.m. Still no complaints received on telephone. 2:47 p.m. Sampling started on prescrub. 3:45 p.m. Slight soapy pungent odor noted near administration building.