Nuisance Pollutants and the Megaphone of Social Media: New Challenges for Industry



The Lens of Social Media is on Industry, Who Must, More Than Ever, Manage Environmental Nuisance Pollutants

A nuisance is defined in law as something offensive or annoying to individuals, or to the community, especially in violation of their legal rights. In the environmental sector, some pollutants are uniquely nuisance-based resulting from operational activities that cause adverse effects to neighboring properties. Such adverse impacts often occur as the loss of enjoyment of property.

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Nuisance clauses in environmental approvals or permits are typically generic and do not always include specific numerical standards or compliance demonstration methods. Two of the most common environmental nuisances are odor and noise, and complaints regarding those pollutants are among the most common received by regulators.

While industrial facilities are constantly subject to scrutiny by regulators and the public, the public now has access to a very powerful tool for bringing issues to the forefront: social media. Through social media, environmental nuisances can essentially be amplified, particularly for niche concerns. Small interest groups can gain large audiences through online community-based platforms; a complaint against a facility can now be broadcast for thousands to see.

The Power of Social Media

Nearly one third of the world population is actively engaged in social media. A product of the 21st century, social media is an online network allowing the user to create and share content with friends, family members, and acquaintances. Some of the more popular social media platforms include Facebook, Twitter, Instagram, Google+, LinkedIn, and Pinterest.

Social media has evolved since its inception and has become much more sophisticated at connecting relevant issues to its user base and advertisers. Users are targeted through data mining, sophisticated algorithms, and machine-learning conventions which are being used to connect interest groups. Social media is fast becoming the go-to platform for activism, opinion, and daily news.

Some relevant aspects of social media are identified below.

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  • Originally created for interconnecting university students, Facebook and other social media networks have expanded to include adults. In the past seven years, all age groups have seen an increase in membership by at least 25%.
  • Social media introduces easy ways for "ordinary people" to get involved with a relatively technical or litigious issue.
  • Public opinion can be shared rapidly on social media, spreading awareness of an issue and eliciting feedback from other users by means of polarizing feedback mechanisms (thumbs up versus thumbs down, etc.). Information can become viral, being spread to the attention of many viewers over a relatively short period of time.
  • Companies turn to social media to share the latest, official update in times of crisis or for specific events. It has become an effective way to quickly distribute information by organizations (local government, universities, companies) on a temporary or long-term basis.
  • Companies that have a presence on social media may need a public relations plan for multiple scenarios (e.g., explaining accidents, responding to complaints, etc.). Social media can have a significant impact on brand reputation.

These realities of social media can be troublesome for companies that are struggling to manage odor and noise emissions. Historically only major environmental issues would be reported by the media (e.g., large spills, accidents, emergencies, etc.). Day-to-day nuisance concerns are now receiving more exposure partially because social media is bringing them to the forefront of public attention. Social media also makes it easier for the public to join forces on nuisance issues and to communicate with each other, with regulators, and with industry. Even citizens not local to the nuisance odor and noise pollution can become readily engaged on the issues. The public has greater awareness of its surroundings and is more empowered to take action through social media activism.

When #Odor is a #Nuisance

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Odor is inherently complex because it results from a mixture of chemical substances that are not perceived consistently by people. Most regulatory agencies do not define specific odor criteria, nor do they provide clear guidance with respect to odor measurement and monitoring methodology.

While odor restrictions are not well defined, it is possible to quantify and characterize odor. Odor is quantified using a relative-strength scale in terms of "odor units" (OUs). As a reference, 1 odor-unit (or simply 1-OU) represents the diluted level at which 50% of the population can begin to detect an odor. To better understand this relative scale, if an established odor were measured to be 7-OU, then the odors present in the air would be at a strength that would require 7 dilutions with "clean" air to meet the detection threshold. The detection threshold is defined as the point at which half the population can no longer sense the odor. Dilution-to-threshold (D/T) can be represented by the following equation:

S2017 Article 2 formula equation

Odor criteria can be established based on D/T values as measured in odor units. Typically odor measurements, whether in a laboratory setting or in the field using a hand-held odor monitoring device, are taken at both a level of Detection Threshold (DT) and Recognition Threshold (RT). DT is the level at which an odor can be perceived but not identified. At this level, it would not be clear what the source of the odor is—only that an odor is present and the concentration is sufficient to perceive it. The RT is the level at which a detectable odor can be recognized and identified, and is usually a more concentrated level compared to DT.

To further characterize odor observations and measurement, as well as the significance of nuisance caused by observed odors, assessments typically employ "FIDOL" qualifiers, as defined below.

Frequency - how often the odor impacts occur
Intensity - the relative odor strength (faint to overwhelming)
Duration - the length of time for a given odor event
Offensiveness - the character or description of the odor
Location - mapping impact and identifying other off-property contributing sources

wastewater treatment plant

Odor characterization, using the methods described above, is paramount to addressing nuisance odor concerns. Baseline odor studies, through monitoring and/or modeling, yield results in terms of odor units. Odor abatement measures can be evaluated through predictive modeling. Odor management plans should include routine facility property-line observations which allow for identification of odor sources and cyclical odor issues at a site. Self-identification of facility odors is preferable to public identification through odor complaints. Odor complaint response plans should be developed to specify the procedure for handling odor complaints. Odor abatement can include:

  • Modifying process or formulations to reduce odor creation
  • Modifying facility ventilation to minimize fugitive odor emission (includes add-on control considerations)
  • Modifying exhaust stack releases to improve odor dispersion

When #Noise is a #Nuisance

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Nuisance noise can be generally be defined as sound frequencies (pitches) that are unpleasant, or sound levels (volumes) that cause disturbance. Industrial noise can be generated by a multitude of source types: fans and stack exhausts; motorized vehicle operations and activities; baghouses and control equipment; rotating machinery and conveyors; material handling; motors, reciprocating engines, turbines, steam and gas venting; pressure drops in piping systems; and many more. Noise can also take many varying forms.

  • Steady noise – noise that is continuous and uniform, such as from intake / exhaust fans
  • Intermittent noise – noise that is sometimes on, sometimes off
  • Impulsive noise – noise containing sharp noise bursts, such as banging and popping
  • Low frequency noise – long wavelength sound levels that travel greater distance, such as wind turbines

The pitch or "frequency" of a given noise is just as important to understand as its total sound volume or "amplitude." Such impacts can efficiently be measured with sound-level meters. An important characteristic of noise is that it attenuates with distance; that is, it diminishes farther from the source. Therefore, when assessing noise it is important to note an associated distance with any given source measurement.

Mitigation of noise pollution is well understood and can be cost-effective when directly applied at the source. Examples of noise mitigation include physical controls such as silencers, acoustic enclosures, noise barrier walls, berms, and baffles. Regular equipment maintenance practices and strategic operating procedures sometimes effectively minimize noise without the need for further control. Examples of such operational measures might include proactive equipment maintenance, enforcing closed-door policies on large bay doors; minimizing nighttime operating hours of loud processes, etc. An effective noise management plan should address those aspects of plant operation with the potential to produce unwanted sound levels. A noise management plan should include prescriptive procedures and identify the responsible staff for plan implementation.

In terms of rules and regulations, noise and vibration are becoming increasingly regulated by federal, state, and local agencies. For example, certain natural gas projects under the jurisdiction of the Federal Energy Regulatory Commission (FERC) are required to conduct detailed ambient sound measurements and noise impact analyses at noise sensitive areas to demonstrate compliance with federal noise standards. An increasing number of municipalities are adopting local noise ordinances that set technical noise standards at plant fence lines and residential receptors. Typically, daytime and nighttime noise criteria differ such that nighttime periods tend to have much stricter noise limits. Failure to comply with these standards can lead to community relations issues and potential lawsuits.

#ProactiveManagementTips

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Undesirable outcomes can result for industry when nuisance concerns are not proactively addressed.  Regulatory authorities may refuse to issue a permit, thus disallowing a project. Alternatively, the project may be approved, but stringent compliance demonstration requirements may be imposed. A compliance schedule may be established with deliverable milestones, such as completing environmental studies, monitoring, modeling, developing management plans, meeting operating limitations, etc. In extreme cases, negative public relations could lead to possible shutdown of a process or an entire facility. Anticipating and managing nuisance concerns can help reduce the risk of these negative outcomes.

Proactive management of nuisance concerns can include a variety of methods:

  • Share information. Take charge of the public image by sharing information with government officials and neighbors early in the permitting process. Consider using social media, or developing a social media public relations plan. Openly sharing information can allow for relationship building with interested parties. Relationship building can lay the groundwork for a cooperative partnership that facilitates problem solving without negative publicity or litigation.
  • Conduct a baseline study. Quantify and qualify nuisance concerns and know what the issues are before you learn them from the public.
  • Research criteria. Using the baseline study results, know how the results compare to relevant criteria. Have a response ready if concerns are raised.
  • Develop nuisance management plan. Determine an approach for handling nuisance conditions and complaints. Train staff to follow the plan to ensure consistent results. Incorporate best management practices from similar industries.
  • Ensure effective complaint response. Pay attention to complaints; commit to an investigation procedure; and follow up with the complainant to ensure good lines of communication. Never leave a complainant in the dark on an issue—their next call could be directed to a regulator even if you adequately addressed the problem.

Learn more about this important environmental issue at Trinity's one-day training course:

Managing Environmental Nuisances: Odor and Noise
Minneapolis, MN - May 11
Toronto, ON - Jun 8
Denver, CO - Aug 24