Comment
Toronto Water Comments for ERO 019-2768 – Guideline to address odour mixtures in Ontario
Toronto Water (Contact person: Ru Bai at ru.bai@toronto.ca) has reviewed the proposed Guideline to address odour mixtures in Ontario and has the following comments:
Re: Guideline to Address Odour Mixtures in Ontario
3.0 Odour-based Requirements for ECA Applications
o For facilities that have already done an Odour assessment, we do not want to repeat odour source testing. We recommend a remodelling be done when there is a process improvement that would require an ECA update. Any new odour sampling should be restricted to the areas of the process where there was an upgrade/change.
o Does a new receptor (e.g. a new building in the neighbourhood) trigger a remodelling and/or source testing?
3.2 Results of Odour Screening …
Best Management Practices Plan (BMPP) for Odour… technical bulletin entitled "Best Management Practices for Industrial Sources of Odour"
o The requirement for an engineer sign off after a minor update to the BMPP seems to be an onerous task.
Odour Technology Benchmarking Report (OTBR)
o For facilities where there is an existing OTBR, it should be focused only on parts of the facility that was upgraded not facility wide.
3.3 Minimum Expectations for ECA Applications
o Does the MECP Design Guidelines for Sewage Works meet the minimum expectations for ECA applications?
3.4 Pre-Consultation with the Ministry
o Is the pre-consultation meeting a must?
o What are the consequences of not having this meeting or scheduling this meeting less than the 3 months window?
Re: Technical Bulletin - Methodology for Completing an Odour Assessment for Odour Mixtures
8.1 Existing Facilities Operating Over 1 OU
o Can a historical low number of confirmed odour events (complaints attributed to the facility) be added as another factor?
o 1OU is too low a limit for screening in as this is the detection limit for odours.
o What does "offensive" means? We suggest this should be replaced by hedonic tone.
Supporting documents
Submitted July 2, 2021 2:58 PM
Comment on
Guideline to address odour mixtures in Ontario
ERO number
019-2768
Comment ID
58080
Commenting on behalf of
Comment status