Crematorium emissions monitoring and permit
Case reference EIR2019/00515
Published 2 July 2019
Request
1. Please can you let me know why the emissions monitoring shows that measured emission concentrations exceed the limits set out in the permit. For example, the limit in Table B for particulate matter is 20 mg/Nm3. The 2018 emissions monitoring report shows that the particulate matter emissions rate was an average of 100.86 g/hr and the flow rates was 1,528 Nm3/hr. This is an emission concentration of 66 mg/Nm3 (ie 100.6*1000/1528).
2. The emissions monitoring has been carried out assuming that the crematoria only needs to comply with unabated emissions limits as set out in PG5/2 (2012) and not those for new crematorium - as specified in the permit and which it should do as it is a new unit. Therefore, there is for example no emissions monitoring undertaken for mercury as required by the permit.
3. The permit specifies a minimum discharge velocity of 15 m/s (condition 50) but the D1 stack height calculation states the velocity is 10.3 m/s.
4. With regard to the new crematorium I understand that it is currently under construction and so presumably has planning permission, so I find it odd that you are not able to provide the basis for the stack height which presumably is integral to the design. The artists impressions on your web site do not show any stack.
5. Please note that if D1 is being used for there is a condition (para 6.1.2) which states 'In the case of discharge stacks with shrouds or casing around the stack the stack should extend above the shroud or casing. This extension should be at least 50% of the shroud or casing's greatest lateral dimension'
6. I see that on 26 March 2019 a Non-material amendment to the planning application for the crematorium to allow for changes to the flues was submitted. Given that this application was submitted before I received my FOI requested response (1 April) it looks like the reasons for refusing to provide the D1 calculation for the new crematorium are invalid given that they must have been completed before the non-material application was submitted. The FOI response states 'The D1 calculation for the permanent installation has not yet been submitted or approved by Environmental Health and is therefore not a matter of public record at present.' Please can you confirm if this statement was accurate when response was submitted (ie was the case on 1 April 2019). Please also provide the D1 calculations without delay.
7. Please can you confirm that you hold written consent from the occupies of all three residential properties that are within 200 yards of the crematorium as required by Section 5 of the 1902 Cremation Act. This Act requires both the Owners (Guildford Borough Council) and occupiers to provide written consent.
Response
This is not the current permit. It should be GD6/P2 which contains the emission limits for the unabated cremator.
There is no requirement for new units to be abated, the temporary cremator is unabated and the requirements of Table 3 in the guidance (see permit dated 22/03/17) applies.
The current permit states :-" 55.A minimum discharge velocity, during peak times, of 15ms-1 (10ms-1 normal operation) shall be maintained for the combustion gases in the stack/s serving the Cremator(s), as specified in Schedule A." and the monitoring was undertaken at normal operation.
The design is being reviewed as part of the overall issue of information release to the contractor. A revised D1 calculation and roof/stack detail is currently being prepared to meet the required standards.
See above.
The FOI response states 'The D1 calculation for the permanent installation has not yet been submitted or approved by Environmental Health and is therefore not a matter of public record at present.'
Please can you confirm if this statement was accurate when response was submitted (ie was the case on 1 April 2019). Please also provide the D1 calculations without delay.
We confirm that this statement was accurate at the time of submission.
Guildford Crematorium as a site includes three residential dwellings and was acquired by CPO (Compulsory Purchase Order). These dwellings are generally and have historically been occupied by employees of the Council. One is currently vacant and the other two are occupied. Those that are occupied are occupied by an existing employee and an ex-employee. The council obtained legal advice (Counsel's opinion) in 2016 relating to the Cremation Act 1902 ("The Act"); this advice includes reference to The Siting and Planning of Crematoria guidance . In summary it was advised that:
Section 5 is a provision which sits alone and deals with the siting of crematoria. The provision remains relevant and applicable to the construction of crematoria. The purpose behind Section 5 is to protect the privacy of cremation including the privacy of those attending cremations. Its purpose (at least primarily) is not to deal with air pollution issues which are dealt with under different legislation.The expression "crematorium" is defined in Section 2 of the Act; and the guidance advises that 'houses for staff' do not come within the definition of crematorium under Section 2 of the Act.
Documents
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