HomeMy WebLinkAboutSP-18-15 CU-18-06 - Supplemental - 0472 Meadowland DriveJ
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PLANNING & ZONio
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May 2, 2018 0
Re: #SP-18-15 & #CU-18-06 472 Meadowland Dr o
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Dear Applicant:
Enclosed, please find a copy of the Findings of Fact and Decision rendered by the
Development Review Board concerning your recent application. Please note the
conditions of approval including that a zoning permit must be obtained within six (6)
mnnths
If you have any questions, please contact me.
Sincerely,
Marla Keene
Development Review Planner
Encl.
CERTIFIED MAIL -Return Receipt Requested # 7018 0040 0000 1165 3048
575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101
www.sburi.com
tneOther Paper • otherpapervt.com • April 12, 2018 • 15
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PUBLIC HEARING
SOUTH BURLINGTON DEVELOPMENT REVIEW BOARD
The South Burlington Development ReviewBoardwill hold a public hearingin the South
Burlington,, City Hall Conference Room,: 575 Dorset Street, South Burlington, Vermont
on Tuesday May 1, `2018 at 7:00 PM. to consider the following:
Final plat application #SD-18-12 of Rivers Edge Building Development, LLC for re -ap-
proval of an amendment to a previously approved planned unit development consisting
of revising the footprint lots for eight (8) units, 1840 Spear Street.
Site plan application #SP-18-15 and conditional use application #CU-18-06 of Steve
Gregory to; amend a previous approved site plan for a 60,000 sq. ft. multi -tenant industrial
building, unit #7 of which is currently approved for use as a funeral home and mortuary
(crematorium). The amendment is to add one additional retort to the existing funeral
home and mortuary, 472 Meadowland Drive.
Bill Miller, Chair
South Burlington Development Review Board
A copy of the application is available for public inspection at the South Burlington
City Hall. Participation in the local proceeding is a prerequisite to the right to take any
subsequent appeal.
April 12, 2018
AUTO: Set of four Summer
tires 205/55 R16 on steel
rims, low mileage, switched
cars, $225. Text 802-355-
0043: (04/12)
COLLECTIBLES: Collection
of assorted colored glass
items and china tea cups. In-
dividually priced at $8 each,
OBO.802-859-0115. (4/12)
IRISH FAIRYDOLL: Redhead
fairy sprite dressed in green,
includes wings and authentic
accessories. 2 ft. tall. $50. 802-
859-0115.(4/12)
PRINTER: Canon MX922,
new, photo, scan, copy, print,
not in box, never used, comes
with new cartridges installed,
$90. 802-985-3421. (04/12)
W 3
used only once and washed,
perfect for party or wed-
ding, $60 OBO.914-337-4010.
(04/05)
WOODEN BOWLS: 8 Weston
bowls, made in Weston, Ver-
mont. $70. 802-985-3421.
(04 / 12)
PAID AD: O Holy St. Jude,
Apostle and Martyr, my re -
TABLECLOTHS: 12-round, quest has been granted. Pub -
white, polyester tablecloths, lication-promised. NH
NorthCountry is rurine!
Jain the team pup ranks in the top 4�'a worldde
for employee engagement.
Facilities Maintenance echni
We need a Mr. or Ms. Fix -It with a keen eye and a strong
back to tackle everything from installing cabinets and
it
southburl n ton
(77
PLANNING & ZONING
Permit # CU - ( $ - a(.o
(office use only)
CONDITIONAL USE / VARIANCE / MISCELLANEOUS
APPLICATION FOR THE DEVELOPMENT REVIEW BOARD
All information requested on this application must be completed in full. Failure to provide the requested
information either on this application form or on the site plan will result in your application being
rejected and a delay in the review before the Development Review Board.
I understand the presentation procedures required by State Law (Section 4468 of the Planning &
Development Act). Also that hearings are held twice a month. That a legal advertisement must appear a
minimum of fifteen (15) days prior to the hearing. I agree to pay a hearing fee which is to off -set the
cost of the hearing.
Type of application (check one):
✓❑ Request for a conditional use
❑ Request for a variance
❑ Other
1) OWNER(S) OF RECORD (Name(s) as shown on deed, mailing address, phone & fax #):
MBC Condominium Association
:fb•'>•Williston : Road, South7:iiiiRTgoiVIIO1.Zi113 f 3 (81 2lb•%4.1UIIlU fiiE:ii2l6.%A
2) LOCATION OF LAST RECORDED DEED (book & page #)
Book 758 Page 461
3) APPLICANT (name, mailing address, phone, fax #)
Steve Gregory
412 Meadowland Ur., buite 1, Southur ing on, pb/8-9943
4) CONTACT PERSON (person who will receive staff correspondence. Include name, mailing
address, phone & fax #, if different from above):
Steve Gregory
472 Meadowland Dr., Suite 7, Southur ing on, p -
a. Contact e-mail address: steve@gregorycremation.com
575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburl.com
5) PROJECT STREET ADDRESS: 472 Meadowland Dr., Suite 7, South Burlington, VT 05403
6) TAX PARCEL ID #• 1155-00472
7) PROJECT DESCRIPTION
a. General Pro'ect Description (describe what you are roposing):
Existing crematory to add 1 Matthews Power -Pak II'lus retort.
b. Existin Uses on Property including description and size of each separate use):
Crematory, 6ontractor or building trade facility, Light Manufacturing, Manufacturing
assembly from previously prepared materials and components, Frinting Hinding,
Research facility or laboratory, Process and Storage
c. Proposed Uses on Property (include description and size of each new use and existing uses to
remain): Existing crematory to add 1 Matthews Power -Pak II Plus retort.
d. Total buildin square footage on pro erty (proposed buildings & existing building to remain):
The existing building is 50,OO(Jsquare Teet.
e. Height of building & number of floors (proposed buildings and existing buildings to remain,
specify if basement & mezzanine : The building is a single story with mezzanine.10,000 s.f. of
mezzanine area. The height othe existing buil ing is approx. ;32.b Teet above pre -cons ruc ion
N/A Number of residential Units (if applicable, new units & existing units to remain):
g. Number of employees & company vehicles (exis
ting & proposed note office vs. non -office
employees): 30 office employees + 40 non -office employees= 70 total employees.
No more than 20 company vehicles.
h. Other (list any other information pertinent to this application not specifically requested above,
please note if overlay districts are applicable): N/A
Conditional Use/Variance/Miscellaneous Application Form. Rev. 12-2011
8) LOT COVERAGE
a. Total parcel size:
b. Buildings:
.i
Sq. Ft.
Existing 14.3 % / 50,000 Sq. Ft
Proposed 14.3% / 0,000—Sq. Ft.
c. Overall impervious coverage (building, parkin outside storage, etc)
Existing 98.5 % / '34,078 Sq. Ft.
Proposed— % / 134,078Sq. Ft.
d. Front yard impervious coverage %building, parking outside storage, etc)
Existing 29 % / 5,38b Sq. Ft.
Proposed % / Sq. Ft.
e. Total area to be disturbed during construction: N/A
Sq. Ft. *
* Projects disturbing more than one-half acre of land must follow the City's specifications for erosion
control in Article 16 of the Land Development Regulations. Projects disturbing more than one acre
require a permit from the Vermont Department of Environmental Conservation.
9) COST ESTIMATES
a. Building (including interior renovations): $ 0
b. Landscaping
$0
c. Other site improvements (please list with cost):
0
10) ESTIMATED TRAFFIC:
a. P.M. Peak hour for entire property (in and out): No additional
11) PEAK HOURS OF OPERATION
8:00 a.m. to 5:00 p.m.
12) PEAK DAYS OF OPERATION Monday through Friday
13) ESTIMATED PROJECT COMPLETION DATE Summer 2018
14) PLANS AND FEE
Plans shall be submitted which shows the information required by the City's Land Development
Regulations. Five (5) regular size copies, one reduced copy (I V x 17"), and one digital (PDF-format)
copy of the plans must be submitted. A subdivision application fee shall be paid to the City at the time
Conditional Use / Vanance /Miscellaneous Application Form. Rev. 12-2011
C
of submitting the application. See the City fee schedule for details.
NOTE: NOTIFICATION of ADJOINING PROPERTY OWNERS: Notification of adjoining
property owners, in accordance with 24 V. S.A. §4464(a) and Section 17.06(B) of the South Burlington
Land Development Regulations, is the responsibility of the applicant. After deeming an application
complete, the Administrative Officer will provide the applicant with a draft meeting agendas or public
hearing notice and sample certificate of service. The sworn certificate of service shall be returned to the
City prior to the start of any public hearing.
I hereby certify that all the information requested as part of this application has been submitted and is
accurate to the best of my knowledge.
A SIGNATURE OF APPLICANT
SIGNATU4<F-'OF PROPERTY OWNER
Do not write below this line.
DATE OF SUBMISSION:
I have reviewed this application and find it to be:
❑ COMPLETE ❑ Incomplete
Administrative Officer
Date
PRINT N
The applicant or permittee retains the obligation to identify, apply for, and obtain relevant state permits
for this project. Call (802) 879-5676 to speak with the regional Permit Specialist.
Conditional Use /Variance /Miscellaneous Application Form. Rev. 12-2011
it
southburligton
PLANNING & ZONING
Permit Number SP- I I - 15
(office use only)
APPLICATION FOR SITE PLAN REVIEW
❑Administrative ®Development Review Board
All information requested on this application must be completed in full. Failure to provide the requested
information either on this application form or on the site plan will result in your application being
rejected and a delay in the review before the Development Review Board.
1. OWNER(S) OF RECORD (N4me(s) as shown on deed, mailing address, phone and fax #):
MBC Condominium Association
Williston oa outh Burlington,
p - -
2. LOCATION OF LAST RECORDED DEED(S) (Book and page #): Book 758 Page 461
3. APPLICANT (Name, mailing address, hone and fax #): Steve Gregory
472 Meadowland Dr., Suite, South Burlington, VT 0
(p)(8U2) 578-9
4. CONTACT PERSON (person who will receive all correspondence from Staff. Include name,
address, phone & fax #): Steve Gregory
472 Meadowland Dr., Suite 7, Southur mg on,
(8-G2j 578---9943-- --
4a. CONTACT EMAIL ADDRESS:: steve@gregorycremation.com
5. PROJECT STREET ADDRESS: 472 Meadowland Dr., Suite 7, South Burlington, VT
6. TAX PARCEL ID # (can be obtained at Assessor's Office):
1155-00472
575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburl.com
7. PROJECT DESCRIPTION
a. General project description (explain what you want approval for):
Existing crematory to add 1 Matthews Power Pak II Plus retort.
b. Vxisting Use on Pro erty (includin descrition and size of each se agate u e):
Cremdory, ontrac�or or buildinTtrade facility, Light Manufact firing, N anufacturinc
assembly from previously prepared materials and components, Printing 0indip,
Hesearch facility or laboratory, Process and Storage
c. Proposed Uses on ro erty (include description and size of each new use and existin
uses to remain): Existing crematory to add 1 Matthews Power -Pak II Plus retoR.
d. Total building square footage on pro�pperrttyy (proposed buildings and existing buildings to
remain): The existing buiFding is 5D,000 square feet.
e. Height of building & number of floors (proposed buildings and existing buildings to remain,
specify if basement and mezzanine):
The building is a single story with mezzanine. sT of mezzanine area.
e height of the existing building is approx. 32.b feetabove pre -construction grs
f. Number of residential units (if applicable, new units and existing units to remain):
n/a
g. Number of employees (existing and roposed, note office versus non -office employees):
30 office employees + 40 non-otTice employees= 70 total employees.
h. Other (list any other information pertinent to this appliW;on not specifically requested
above, please note if Overlay Districts are applicable): IIVV
Site Plan Application Form. Rev. 12-2011
t
8. LOT COVERAGE
a. Building:
Total Parcel Size: 348,480
Existing 14.3 % /
Proposed 14.3— % /
Sq. Ft.
50,000 sq. ft.
50,000 sq. ft.
b. Overall impervious coverage (building, parking, outside storage etc)
34,078
Existing 38.5 % / sq. ft.
Proposed 38.% / � �78— —sq. ft.
c. Front yard (along each street) Existing 29.9 % / 5,380 sq. ft.
Proposed 29.9 --% / ,380 sq. ft.
d. Total area to be disturbed during construction (sq. ft.) N/A
* Projects disturbing more than one-half acre of land must follow the City's specifications for erosion
control in Article 16 of the Land Development Regulations. Projects disturbing more than one acre
require a permit from the Vermont Department of Environmental Conservation.
9. COST ESTIMATES
a. Building (including interior renovations):
b. Landscaping:
$0
c. Other site improvements (please list with cost): 0
10. ESTIMATED TRAFFIC
a. P.M. Peak hour for entire property (In and OL.it): No Additional
11. PEAK HOURS OF OPERATION: 8:00 a.m. to 5:00 p.m.
12. PEAK DAYS OF OPERATION: Monday through Friday
13. ESTIMATED PROJECT COMPLETION DATE: Summer 2018
14. SITE PLAN AND FEE A site plan shall be submitted which shows the information required by the
City's Land Development Regulations. Five (5)' regular size copies, one reduced copy (11" x 17"), and
one digital (PDF-format) copy of the site plan must be submitted A site plan application fee shall be
paid to the City at the time of submitting the site plan application in accordance with the city's fee
schedule.
' Administrative site plan applications require three (3) regular size copies, one reduced copy (11" x 17"), and one
digital (PDF-format) copy.
3 Site Plan Application Form_ Rev. 12-2011
NOTE: NOTIFICATION of ADJOINING PROPERTY OWNERS: Notification of adjoining
property owners, in accordance with 24 V.S.A. §4464(a) and Section 17.06(B) of the South Burlington
Land Development Regulations, is the responsibility of the applicant. After deeming an application
complete, the Administrative Officer will provide the applicant with a draft meeting agendas or public
hearing notice and sample certificate of service. The sworn certificate of service shall be returned to the
City prior to the start of any public hearing.
I hereby certify that all the information requested as part of this application has been submitted and is
accurate to the best of my knowledge.
SIGNATURE'017 PRO
DATE OF SUBMISSION:
ATURE1 OF APPLICANT
TY'4W N ER
Do not write below this line
NAME
REVIEW AUTHORITY: ❑Development Review Board ❑Administrative Officer
I have reviewed this site plan application and find it to be:
❑Complete ❑ Incomplete
Administrative Officer
Date
The applicant or permittee retains the obligation to identify, apply for, and obtain relevant state permits
for this project. Call (802) 879-5676 to speak with the regional Permit Specialist.
Site Plan Application Form. Rev. 12-2011
{
f
472 Meadowland Drive, Suitc 7
South Burlington, Vermont, 05403
!Gregory Cremation and Memorial Service, LLC Phone: (802) 399-2979 Fax: (802)399-2184
a
E-Mail: steve@gregorycremation.com
Web: www.gregorycremation.com
March 20, 2018
Ray Belair
City of South Burlington
Planning and Zoning
575 Dorset Street
South Burlington, VT 05403
RE: Meadowlands Business Complex, Unit 7
Dear Mr. Belair:
I am submitting an application to request a Conditional Use Permit for Gregory Cremation and Memorial Service, LLC,
located at 472 Meadowlands Drive, Unit 7, South Burlington, Vermont 05403. Enclosed you will find a check for $466.00 for
the applications, the last site plan, 3 paper copies and 1 reduced to 11 x 17.
I am proposing the addition of one Matthews Power -Pak II Plus cremation retort. The additional retort has been approved and
permitted from the State of Vermont, Department of Environmental Conservation, Air Pollution Division. I have attached the
Vermont Air Pollution Control Division Permit and Technical Supporting Data.
I have been operating since 2012 without a single complaint. The new proposal meets the performance standards in Appendix
A of the South Burlington Land Development Regulations. I provide a needed service to the community. The additional retort
will not have a negative impact on the community or abutting property owners.
Existing parking, lighting, sewer and water allocations will not be impacted.
Please contact me with any questions or comments. Thank you very much.
Sincerely,
Steve Gregory
Owner
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#AP-18-009
DEC" EJ11-0338
State of Vermont
Agency of Natural Resources
Department of Environmental Conservation
Air Quality & Climate Division
Montpelier, Vermont
AIR POLLUTION CONTROL PERMIT_
TO CONSTRUCT
Date DRAFT Permit Issued: March 1, 2018
Owner/Operator: Stephen Gregory
465 Sycamore Street
Shelburne, Vermont 05482
Source: Human Cremation Unit
Gregory Cremation and Memorial Service, LLC
472 Meadowland Drive, Unit #7
South Burlington, Vermont 05403
Gregory Cremation and Memorial Service, LLC #AP-18-009
FINDINGS OF FACT
(A) FACILITY DESCRIPTION
Gregory Cremation and Memorial Service, LLC (also referred to herein as "Permittee")
owns and operates a funeral service and crematory at 472 Meadowland Drive in the
town of South Burlington, Vermont (also referred to herein as "Facility"). The Permittee
has proposed to modify the existing Facility with the installation and operation of an
additional Matthews Power -Pak II Plus in addition to the existing Matthews Power -Pak II
cremation unit. The proposed unit is designed to fire charges at a maximum rate of 150
pounds per hour and uses two burners - a primary burner with a heat input capacity of
2,000,000 Btu/hr and a secondary burner with a heat input capacity of 500,000 Btu/hr.
The Permittee plans to fire natural gas exclusively in the retort burners. The operations
performed at the Facility are classified within the Standard Industrial Classification Code
- 7261 (Funeral Services and Crematories).
Upon issuance of this Permit, the approved operations at the Facility include the
following air pollution related operations, equipment and emission control devices:
Equipment Specifications
Equipment/make/model
Max charge
rate, Ib/hr
Heat input capacity,
primary/secondary/total
Fuel
type
Date of
installation
Matthews Power -Pak II
150
2.0/0.5/2.5
LPG
2011
Matthews Power -Pak II Plus
175
1.5/1.5/3.0
LPG
2018
Heat input capacities listed in million British thermal units per hour.
z LPG — liquified petroleum gas.
(B) FACILITY CLASSIFICATION
The Facility is classified as a source of air contaminants pursuant to Title 10 of the
Vermont Statutes Annotated ("10 VSA") §555 and §5-401(1) "Incinerators", of the
Vermont Air Pollution Control Regulations (hereinafter "Regulations"). In addition, §5-
101 of the Regulations defines a stationary source as any structure(s), equipment,
installation(s), or operation(s), or combination thereof, which emit or may emit any air
contaminant, which is located on one or more contiguous or adjacent properties and
which is owned or operated by the same person or persons under common control.
Based on this definition, all of the equipment, operations, and structures at the Facility
are grouped together by the Agency of Natural Resources, Department of Environmental
Conservation, Air Pollution Control Division (hereinafter "Agency") as one stationary air
contaminant source for purposes of review under the Regulations.
Page 2 of 15
Gregory Cremation and Memorial Service, LLC NOW #AP-18-009
(C) PRIOR AGENCY ACTIONS/APPROVALS
The Facility has been issued the following "Permit to Construct" approvals pursuant to
10 VSA §556 and §5-501 of the Regulations.
(D)
Prior Agency Approvals and Actions
Date of Action Description of Agency Approval/Action
November 15, 2011 4AP-11-033 — Original Agency "Permit to Construct" approval for installation and
operation of one (1) Matthews Power -Pak II cremation unit.
FACILITY PERMIT APPLICABILITY
As noted above, the Facility is classified as a source of air contaminants under §5-401 of
the Regulations. Pursuant to 10 VSA §556 and §5-501 of the Regulations a Permit to
Construct, or an amendment to any existing Permit to Construct, must be obtained
before commencing the construction, installation, modification or operation of an air
contaminant source.
Pursuant to 10 VSA §556a and Subchapter X of the Regulations a Permit to Operate is
required for any air contaminant source with allowable emissions of all air contaminants
combined of ten (10) tons per year ("tpy") or more or that is otherwise subject to Title 40
Code of Federal Regulations ("40 CFI?') Part 70. Allowable emissions from the Facility
are estimated to be less than ten (10) tpy combined and the Facility is not otherwise
required to obtain a Title V permit therefore the Facility is not required to obtain a Permit
to Operate consistent with the requirements of Subchapter X of the Regulations.
Future Allowable Air Contaminant Emissions (tons/year)'
PM/PMIdPM2.5
S02
NOx
CO
VOCs
Total
HAPs2
Cr feria
2.2
<1
3.8
0.2
<5
<10
<8/20
PM/PM10/PM2.5 — total particulate matter, total particulate matter of 10 micrometers in size or smaller and total
particulate matter of 2.5 micrometers in size or smaller, respectively. Uunless otherwise specified, all PM is assumed
to be PM2.5); S02 - sulfur dioxide; NO, - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs
- volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.
A stationary source with potential emissions of 10 tons per year or greater of any single HAP or 25 tons per year or
greater of all HAPs combined is considered a major source of HAPs under §112 of the federal Clean Air Act. Any
stationary source with potential emissions of 8 tons per year or greater of any single HAP or 20 tons per year or greater
of all HAPs combined is considered a synthetic minor source. The Facility is limited by the Permit herein to less than
thresholds for a synthetic minor source. Actual total combined HAPs from the Facility are estimated at <1 tpy. This
Permit does not explicitly authorize emissions up to this level since any increase in actual HAP emissions may be
subject to §5-261 and 5-501 of the Regulations as applicable.
Page 3 of 15
Gregory Cremation and Memorial Service, LLC #AP-18-009
(E) REVIEW OF CRITERIA EMISSIONS FOR THE PERMIT TO CONSTRUCT
(a) New Source Review Designation
The Facility, prior to the construction of the proposed modification, is designated
as a non -major stationary source of air contaminants since it does not have
allowable emissions of a single air contaminant of fifty (50) tons per year or
greater. Consequently, any modification of the source that would result in a
significant increase in emissions of any air contaminant, as defined in §5-101 of
the Regulations, is designated as a major modification and is subject to review
under §5-501 and §5-502 of the Regulations. The proposed project identified in
Findings of Fact (A) above, together with all previous minor modifications
constructed at the Facility since July 1, 1979, and which have not been
previously reviewed under §5-502 of the Regulations, will not result in a
significant increase in emissions. Consequently, the proposed modification is
designated as a non -major modification and is not subject to the requirements of
§5-502 of the Regulations.
(b) Most Stringent Emission Rate
Pursuant to §5-502 of the Regulations, the owner/operator of each new major
stationary source or major modification must apply control technology adequate
to achieve the Most Stringent Emission Rate ("MSER") with respect to those air
contaminants for which there would be a major or significant actual emissions
increase, respectively, but only for those currently proposed physical or
operational changes which would contribute to the increased emissions.
The proposed project is designated as a non -major modification of a stationary
source and therefore is not subject to review under the MSER requirements in
§5-502 of the Regulations. In addition, there have been no prior MSER
evaluations conducted for any of the previous modifications to the Facility.
(c) Ambient Air Quality Impact Evaluation
An ambient air quality impact evaluation is performed to demonstrate whether or
not a proposed project will cause or contribute to violations of the ambient air
quality standards and/or significantly deteriorate existing air quality.
Based on the level of emissions from this Facility, it is not expected to cause or
contribute to a violation of any ambient air quality standard or significantly
deteriorate air quality. Therefore, an air quality impact evaluation was not
required by the Agency for the proposed project. In addition, there has been no
prior ambient air quality impact evaluations conducted for any of the previous
modifications to the Facility.
Page 4 of 15
Gregory Cremation and Memorial Service, LLC #AP-18-009
(d) Applicable Requirements
The operations at the Facility are subject to the following state and federal laws
and regulations, the requirements of which are embodied in the conditions of this
Permit.
(i) Vermont Air Pollution Control Regulations:
Applicable Requirements from the
Vermont Air Pollution Control Regulations
Section 5-201 — Prohibition of Open Burning
Section 5-211(2) - Prohibition of Visible Air Contaminants, Installations Constructed
Subsequent to April 30, 1970.
Section 5-221(1) - Prohibition of Potentially Polluting Materials in Fuel, Sulfur Limitation
in Fuel.
Section 5-231(2) - Prohibition of Particulate Matter; Incinerator Emissions.
Section 5-241 — Prohibition of Nuisance and Odor.
Section 5-402 — Written Reports When Requested.
Section 5-403 — Circumvention.
Subchapter VI I — Registration of Air Contaminant Sources.
(ii) Existing Air Pollution Control Permit to Construct
The Facility currently operates under the confines of a Permit to Construct
issued on November 15, 2011 (#AP-11-033). The requirements of that
permit which are not being modified herein are incorporated into this new
Permit to Construct (#AP-18-009).
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Gregory Cremation and Memorial Service, LLC #AP-18-009
(iii) Federal Requirements:
Applicable Requirements from
Federal Regulations and the Clean Air Act
40 CFR Part 60, Subpart Ec—Standards of Performance for Hospital/Medical/
Infectious Waste Incinerators for Which Construction is Commenced After June
20, 1996. This rule applies to each hospital/medical/infectious waste incinerator.
Neither the definition of hospital waste or medical infectious waste include human or
animal remains intended for interment or cremation.
This rule does not apply to human or animal remains intended for interment
or cremation. Thus, cremation units used exclusively for this purpose are
not subject.
40 CFR Part 60, Subpart CCCC—Standards of Performance for Commercial and
Industrial Solid Waste Incineration Units for Which Construction Is Commenced
After November 30, 1999 or for Which Modification or Reconstruction Is
Commenced on or After June 1, 2001 (and Subpart DDDD for existing units). This
rule applies to each commercial and industrial solid waste incineration (CISWI) unit.
This rule does not apply to certain pathological waste incinerators that burn 90% or
more by weight pathological waste (must notify Administrator and keep records),
municipal waste combustion units, medical waste incineration units, small power
production facilities, cogeneration facilities, hazardous waste combustion units,
materials recovery units, air curtain incinerators, and sewage sludge incinerators. Burn
off ovens including rack reclamation units, cyclonic burn barrels and soil treatment units
are also not considered incinerators subject to this rule. Cellulosic biomass (virgin
wood) and specification used oil are considered traditional fuels and not considered
solid waste. Per 241.4 scrap tires, resinated wood, coal refuse and pulp and paper
sludge are categorically exempt as solid wastes. Per 241.3 other fuels meeting the
following legitimacy requirements of 241.3(d) are also exempt, by self-determination in
some instances or by petition to EPA in others : (1) must be managed as a valuable
commodity, (2) must have a meaningful heating value and be used as a fuel in a
combustion unit that recovers energy, (3) must contain contaminants or groups of
contaminants at levels comparable in concentration to or lower than those in traditional
fuel(s) which the combustion unit is designed to burn.
This rule does not apply to human or animal remains intended for interment
or cremation. Thus, cremation units used exclusively for this purpose are
not subject.
40 CFR Part 60, Subpart EEEE — Standards of Performance for Other Solid Waste
Incineration (OSWI) Units for Which Construction is Commenced After December
9, 2004, or for Which Modification or Reconstruction is Commenced on or After
June 16, 2006. This rule applies to two subcategories of incinerators: (1) very small
municipal waste combustion units (units that burn less than 35 tons per day of
municipal solid waste) and (2) institutional waste incineration units. It does include
cyclonic burn barrels at an institutional facility. This rule does not apply to certain
pathological waste incineration units that burn 90% or more by weight pathological
waste (must notify Administrator and keep records), units that combust contraband or
prohibited goods, or temporary -use incinerators and air curtain incinerators used in
disaster recovery.
This rule does not apply to human or animal remains intended for interment
or cremation. Thus, cremation units used exclusively for this purpose are
not subject.
Page 6 of 15
Gregory Cremation and Memorial Service, LLC DRAFT 4AP-18-009
(F) HAZARDOUS MOST STRINGENT EMISSION RATE
Pursuant to §5-261 of the Regulations, any stationary source subject to the rule' with
current or proposed actual emissions of a hazardous air contaminant (HAC) equal to or
greater than the respective Action Level (found in Appendix C of the Regulations) shall
be subject to the Regulation and shall achieve the Hazardous Most Stringent Emission
Rate (HMSER) for the respective HAC. HMSER is defined as a rate of emissions which
the Secretary, on a case -by -case basis, determines is achievable for a stationary source
based on the lowest emission rate achieved in practice by such a category of source and
considering economic impact and cost. HMSER may be achieved through application of
pollution control equipment, production processes or techniques, equipment design,
work practices, chemical substitution, or innovative pollution control techniques.
Based on information provided by the Permittee, the Agency does not anticipate the
Facility to have regulated emissions of any HAC in excess of an Action Level. While
mercury emissions are of potential concern with human crematories due mainly to
mercury in amalgam fillings, individual crematories are not expected to exceed the
respective mercury Action Level. Therefore, the Facility is not being reviewed pursuant
to §5-261 of the Regulations at this time.
APCR §5-261(1)(c)(ii) provides that solid fuel burning equipment (not including incinerators)
installed or constructed prior to January 1, 1993, and all fuel burning equipment which combust
virgin liquid or gaseous fuel shall not be subjects to the requirements of §5-261.
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Gregory Cremation and Memorial Service, LLC DRAFT #AP-18-009
Based on the Agency's review of the Facility's application and the above Findings of Fact, the
Agency concludes that the Facility, subject to the following Permit conditions, complies with all
applicable state and federal air pollution control laws and regulations. Therefore, pursuant to 10
VSA §556, as amended, the Agency hereby issues a Permit approving the Facility, as described
in the above Findings of Fact, subject to the following:
PERMIT CONDITIONS
- Construction and Equipment Specifications -
(1) The Permittee shall construct and operate the Facility in accordance with the plans and
specifications submitted to the Agency and in accordance with the conditions set forth
herein, including the equipment specifications as listed in Findings of Fact (A) or their
equivalent as approved by the Agency. [10 V.s.A. §556(c)] [§5-501(1) of the Regulations]
(2) Each crematory unit shall be designed and operated with a secondary combustion
chamber or zone that ensures complete combustion of the exhaust gases in compliance
with the particulate matter and visible emission limits of this Permit. [10 V.S.A. §556(c)] [§5-
231(2)(c) of the Regulations] [application for #AP-11-033 and "AP-18-009]
(3) Stack heights: The exhaust gases from the following emission sources shall be vented
vertically through a stack(s) of the configuration noted below. Where stack heights are
noted in Findings of Fact A such stacks shall be configured accordingly. The stack(s)
shall not be equipped with any device that may obstruct the upward discharge of the
exhaust gases such as a fixed rain cap of a type that has not been approved by the
Agency.
Stack Height and Configuration
Maximum stack diameter Minimum stack height (ft)
Emission source (inches)' Above grade
Matthews Power -Pak II 29 28
Matthews Power -Pak II Plus 29 28
' Stack diameter refers to internal diameter. Where stack diameter is not specified, it shall be based on the most recent
respective permit application.
For all other non -fugitive emission points at the Facility, the Agency recommends that
they each be exhausted vertically through a stack(s) which extend a minimum of four (4)
feet above the roof where the stack penetrates the roof and that they not be equipped
with any device that may obstruct the upward discharge of the exhaust gases such as a
fixed rain cap of a type that has not been approved by the Agency. The Agency may
require the Permittee to increase the stack height, remove a rain cap, or conduct a
dispersion analysis to verify compliance with ambient air quality standards for any stack
Page 8 of 15
Gregory Cremation and Memorial Service, LLC #AP-18-009
at the Facility if, in the judgment of the Agency, adequate dispersion cannot be
maintained at the current stack configuration. Adequacy may in part be based on the
actual emission rate of air contaminants, the characteristics of the current stack
configuration, or inspections of the Facility that indicate poor dispersion or that confirm
significant visible emissions or nuisance or odor beyond the property line. 110 V.S.A.
§§556(c) and 556a(d)] [§5-406 of the Regulations] [application for'AP-11-033 and `AP-18-009]
- Operational Limitations -
(4) The Permittee shall only burn human and/or animal remains in the crematory unit. A
bag or container for holding the remains may also be burned with the remains provided
the bag or container is designed and intended for cremation and contains no PVC
plastics. No other materials may be burned in the crematory unit without the prior written
approval of the Agency. The combustion of any other materials including pathological
wastes, hospital wastes, medical/infectious wastes, commercial or industrial wastes,
municipal wastes or institutional wastes may result in the unit being subject to federal
incinerator regulations. [10 V.S.A. §556(c)] [5-261 of the Regulations] (40 CFR Part 60 Subparts Ec, CCCC and
EEEE]
(5) Notwithstanding Condition (4) above, the Permittee shall under no circumstances fire
wooden caskets in the crematory unit without prior written approval of the Agency.
Approval shall be contingent on the Permittee submitting valid stack emission test data
that demonstrates the respective crematory unit make and model complies with the
particulate matter emission limit of this Permit while burning a standard charge that
includes a wooden casket. Failure to comply with this condition shall be grounds for
revocation of this Permit. [10 V.S.A. §556(c)] [§5-404 of the Regulations]
(6) The Permittee shall ensure that the last combustion chamber or zone of the cremation
unit is preheated to a temperature of at least 1,600°F prior to introduction of the charge
and shall maintain said temperature throughout the remainder of the cremation unit's
operation cycle. All elements of the cremation unit shall be maintained in good working
order at all times. The cremation unit shall be operated and maintained in accordance
with the manufacturer's operation and maintenance recommendations. [10 V.S.A. §556(c)]
[§5-231(2)(c) of the Regulations]
(7) The Permittee shall fire only fire natural gas or liquefied petroleum gas (LPG) in the
crematory unit's burners unless the Permittee obtains prior written approval from the
Agency to use another type of fuel. [10 V.S.A. §556(c)]
(8) The Permittee shall insure that all operators of the cremation unit receive training on the
proper operation of the unit from the manufacturer, vendor or another qualified source.
The Permittee shall display, near the unit, certification of that training and a certified
operator shall be on -site and available during all periods of operation. [10 V.S.A. §556(c)] [§5-
402(1) of the Regulations]
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Gregory Cremation and Memorial Service, LLC DRAFT #AP-18-009
(9) The Permittee shall have the crematory unit inspected and maintained by the
manufacturer or a qualified service representative annually or after every twenty-five (25)
operational cycles, whichever occurs later. [10 V S A §556(c)] [§5-405(1) ofthe Regulations]
- Emission Limitations -
(10) The Permittee shall not emit, from the cremation unit, any gases that contain particulate
matter in excess of 0.06 grains per dry standard cubic foot, corrected to seven (7)
percent oxygen. All sampling runs conducted as part of emission tests intended to
demonstrate compliance with the emission limits specified above shall begin when waste
material is first introduced into the cremation unit.
Any emission testing conducted to demonstrate compliance with the above emission
limit shall be performed in accordance with Title 40 Code of Federal Regulations Part 60,
Appendix A, Reference Method 5 or an equivalent method approved in writing by the
Agency. [§§5-231(2)(c) and 5-404 of the Regulations]
(11) Visible Emissions [Facility Wide]: Emissions of visible air contaminants from any
installation at the Facility, except where otherwise noted in this Permit, shall not exceed
twenty (20) percent opacity for more than a period or periods aggregating six (6) minutes
in any hour and at no time shall visible emissions exceed sixty (60) percent opacity.
Any emission testing conducted to demonstrate compliance with the above emission
limits shall be performed in accordance with 40 CFR Part 51, Appendix M, Methods
203B and 203C, respectively, or equivalent methods approved in writing by the Agency.
[§§5-21 1(2), 5-211(3) and 5-404 of the Regulations]
(12) Nuisance and Odor: The Permittee shall not discharge, cause, suffer, allow, or permit
from any source whatsoever such quantities of air contaminants or other material which
will cause injury, detriment, nuisance or annoyance to any considerable number of
people or to the public or which endangers the comfort, repose, health or safety of any
such persons or the public or which causes or has a natural tendency to cause injury or
damage to business or property. The Permittee shall not discharge, cause, suffer, allow,
or permit any emissions of objectionable odors beyond the property line of the premises.
[§5-241(1) and (2) of the Regulations]
(13) Hazardous Air Pollutants: Emission of federally regulated hazardous air pollutants
(HAPs) from the Facility shall not equal or exceed eight (8) tons per year of any single
HAP or twenty (20) tons per year of all HAPs combined per calendar. This condition
does not explicitly authorize emissions up to this level since any increase in actual HAP
emissions may be subject to §5-261 and 5-501 of the Regulations as applicable. [10
V.S.A. §§556(c) and 556a(d)] [§§5-261 and 5-501 of the Regulations] [40 CFR Part 631
Page 10 of 15
Gregory Cremation and Memorial Service, LLC 10M #AP-18-009
(14) Hazardous Air Contaminants: Emissions of state hazardous air contaminants (HACs)
from the applicable operations at the Facility shall not equal or exceed their respective
Action Level (found in Appendix C of the Regulations) unless the Agency has reviewed
and approved such HAC emission under §5-261(2) of the Regulations. [10 V.S.A. §§556(c)
and 556a(d)] [§5-261 of the Regulations]
(15) Operation and Maintenance Plan: The Permittee shall develop and implement an
operation and maintenance plan (O&M Plan) for the crematory unit within thirty (30) days
following commencement of operation of the unit. The purpose of said O&M Plan shall
be to ensure the proper operation and maintenance of the unit in order to ensure
continuous compliance with the respective conditions and emission limits of this Permit.
The O&M Plan shall include, but not be limited to, a detailed description of proper
operating procedures, provisions for maintaining records of daily and routine
maintenance inspections, findings of those inspections, and any corrective actions
taken. Said O&M Plan shall be present at the facility at all times and shall be made
available to representatives of the Agency upon request. The Permittee shall revise said
O&M Plan at the Agency's request or on its own motion based on operating experience
or to reflect equipment or operational changes. [10 V.S.A. §556(c)] [§5-405(1) of the Regulations]
- Record Keeping and Reporting -
(16) Records of Fuel Usage: The Permittee shall maintain records of the total quantity of
natural gas and/or LPG consumed in the combustion equipment, in cubic feet and/or
gallons, respectively, each calendar year. At the beginning of each calendar year, the
Permittee shall calculate the total quantity of fuel consumed in the combustion
equipment, in cubic feet, during the previous calendar year. [10 v.s.a. §556(c)] [§5-405(1) of the
Regulations]
(17) Records of Usage: The Permittee shall maintain an operator's log book to record the
following information: operators' name, date, start and stop time of each charge,
approximate weight of each charge including casket if present, casket description if
present (wood, cardboard, crematory friendly casket designed for cremation use,
approximate weight) and initial temperature of last combustion zone before charging. A
separate section of the log book will also be maintained containing records of material
safety data sheets (MSDSs) on any plastics fired within the cremation units. Said log
book shall be present at the Facility at all times and shall be made available to
representatives of the Agency upon request. [§5-402(1) of the Regulations]
(18) All records shall be retained for a minimum period of five (5) years from the date of
record and shall be made available to the Agency upon request. [§§5-402(1), 5-405(1) of the
Regulations]
(19) The Permittee shall notify the Agency in writing within ten (10) days of any violation, of
which it is aware, of any requirements of this Permit. This notification shall include, at a
minimum, the cause for the violation and corrective action or preventative maintenance
taken to correct the violation. [§5-402(1) of the Regulations]
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Gregory Cremation and Memorial Service, LLC #AP-18-009
(20) If requested by the Agency, the Permittee shall notify the Agency at least one (1) day in
advance of all scheduled cremations for a specified period of time. [§5-402(1) of the
Regulations]
(21) The Permittee shall notify the Agency in writing of the date of initial start-up of the
crematory within fifteen (15) days after such date. [§5-402(1) of the Regulations]
(22) The Permittee shall notify the Agency in writing of any proposed physical or operational
change at the Facility which may increase the emission rate of any air contaminant to
the ambient air regardless of any concurrent emission reductions that may be achieved.
This notification requirement includes, but is not limited to, the proposed installation of
any new equipment that is a source of air pollution, including the replacement of an
existing permitted air pollution source. If the Agency determines that a permit
amendment is required, a new application and the appropriate application fee shall be
submitted. The permit amendment shall be obtained prior to commencing any such
change except as may otherwise be allowed by the Regulations. [10 V.S.A. §556(c)] [§§5-402(1)
and 5-501 of the Regulations]
(23) Annual Registration: Each operator of a human or animal crematoria regardless of
whether such source emits five (5) tons or more of any and all air contaminants per year,
shall register the source with the Secretary of the Agency (hereinafter "Secretary") and
shall renew such registration annually. Each day of operating a source which is subject
to registration without a valid, current registration shall constitute a separate violation
and subject the Permittee to civil penalties. The registration process shall follow the
procedures set forth in Subchapter VIII of the Regulations, including the payment of the
annual registration fee on or before May 15 of each year. [subchapter vill §§5-802, 5-803, 5-807,
5-808 of the Regulations]
(24) All records, reports, and notifications that are required to be submitted to the Agency by
this Permit shall be submitted to:
Agency of Natural Resources
Department of Environmental Conservation
Air Quality & Climate Division
One National Life Drive, Davis Building, Second Floor
Montpelier, Vermont 05620-3802
[§5-402 of the Regulations]
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Gregory Cremation and Memorial Service, LLC OW #AP-18-009
- Standard Permit Conditions -
(25) Approval to construct or modify under this Permit shall become invalid if construction or
modification is not commenced within eighteen (18) months after issuance of this Permit,
if construction or modification is discontinued for a period of eighteen (18) months or
more, or if construction is not substantially completed within a reasonable time. The
Agency may extend any one of these periods upon a satisfactory showing that an
extension is justified. The term "commence" as applied to the proposed construction or
modification of a source means that the Permittee either has:
(a) Begun, or caused to begin, a continuous program of actual on -site construction
or modification of the source, to be completed within a reasonable time; or
(b) Entered into binding agreements or contractual obligations, which cannot be
cancelled or modified without substantial loss to the Permittee, to undertake a
continuous program of actual on -site construction or modification of the source to
be completed within a reasonable time.
[10 V.S.A. §556(c)] [§5-501 of the Regulations]
(26) These Permit conditions may be suspended, terminated, modified, or revoked for cause
and reissued upon the filing of a written request with the Secretary of the Agency
(hereinafter "Secretary") or upon the Secretary's own motion. Any modification shall be
granted only with the written approval of the Secretary. If the Secretary finds that
modification is appropriate, only the conditions subject to modification shall be re-
opened. The filing of a request for modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated non-compliance does
not stay any terms or conditions of this Permit. The Secretary may provide opportunity
for public comment on any proposed modification of these conditions. If public
comments are solicited, the Secretary shall follow the procedures set forth in 10 V.S.A.
§556 and §556a, as amended. [10 V.S.A. §556(c)]
(27) The Permittee shall furnish to the Agency, within a reasonable time, any information that
the Agency may request in writing to determine whether cause exists to modify, revoke,
reissue, or terminate the Permit or to determine compliance with this Permit. Upon
request, the Permittee shall also furnish to the Agency copies of records required to be
kept by this Permit. [10 V.S.A. §556(c)] [§5-402(1) of the Regulations]
(28) By acceptance of this Permit, the Permittee agrees to allow representatives of the State
of Vermont access to the properties covered by the Permit, at reasonable times, to
ascertain compliance with Vermont environmental and health statutes and regulations
and with this Permit. The Permittee also agrees to give the Agency access to review
and copy any records required to be maintained by this Permit, and to sample or monitor
at reasonable times to ascertain compliance with this Permit. [10 V.S.A. §556(c)] [ §§5-402(1) and
5-404 of the Regulations]
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Gregory Cremation and Memorial Service, LLC #AP-18-009
(29) All data, plans, specifications, analyses and other information submitted or caused to be
submitted to the Agency as part of the application for this Permit or an amendment to
this Permit shall be complete and truthful and, for Title V permit applications, certified by
a responsible official whose designation has been approved by the Secretary. Any such
submission which is false or misleading shall be sufficient grounds for denial or
revocation of this Permit, and may result in a fine and/or imprisonment under the
authority of Vermont statutes. [10 V.S.A. §556(c)] [§5-505 of the Regulations]
(30) For the purpose of establishing whether or not a person has violated or is in violation of
any condition of this Permit, nothing in this Permit shall preclude the use, including the
exclusive use, of any credible evidence or information relevant to whether a source
would have been in compliance with applicable requirements if the appropriate
performance or compliance test or procedure had been performed. [10 V.S.A. §556(c)]
(31) Any permit noncompliance could constitute a violation of the federal Clean Air Act and is
grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or for denial of a permit renewal application. 110 V.S.A. §556(c)]
(32) It shall not be a defense for the Permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity to maintain compliance with the
conditions of this Permit. [10 V.S.A. §556(c)]
(33) No person shall build, erect, install or use any article, machine, equipment or other
contrivances, the use of which, without resulting in a reduction in the total release of air
contaminants to the atmosphere, reduces or conceals an emission which otherwise
would constitute a violation of these Regulations. [§5-403 of the Regulations]
(34) The provisions of this Permit are severable. If any provision of this Permit, or its
application to any person or circumstances is held invalid, illegal, or unenforceable by a
court of competent jurisdiction, the invalidity shall not apply to any other portion of this
Permit which can be given effect without the invalid provision or application thereof. po
V.S.A. §556(c)]
(35) This Permit does not convey any property rights of any sort or any exclusive privilege,
nor does it authorize any injury to private property or any invasion of personal rights. [10
V.S.A. §556(c)]
(36) All subsequent owners and/or operators of this Facility must request an amendment and
transfer of this Permit prior to commencing any operations covered by this Permit. All
subsequent owners and/or operators shall submit to the Agency as part of the request
for amendment all such information the Agency deems necessary to establish legal
ownership and/or interest in the property and all such information the Agency deems
necessary to ensure the new owners and/or operators will construct and operate the
Facility in compliance with the Regulations and this Permit. The terms and conditions of
this Permit shall remain in full force and effect after submittal of the request for
amendment and until the issuance of an amended Permit or denial. Should the
Secretary deny the request, the new owner and/or operator must take whatever action is
necessary to comply with the denial. [10 V.S.A. §556(c)] [§§5-501 of the Regulations]
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Gregory Cremation and Memorial Service, LLC DRAFT
#AP-18-009
(37) Pursuant to 10 V.S.A. Chapter 220, any appeal of this decision must be filed with the
clerk of the Environmental Court within 30 days of the date of the decision. The Notice
of Appeal must specify the parties taking the appeal and the statutory provision under
which each party claims party status; must designate the act or decision appealed from;
must name the Environmental Court; and must be signed by the appellant or their
attorney. In addition, the appeal must give the address or location and description of the
property, project or facility with which the appeal is concerned and the name of the
applicant or any permit involved in the appeal. The appellant must also serve a copy of
the Notice of Appeal in accordance with the Rule 5(b)(4)(B) of the Vermont Rules for
Environmental Court Proceedings. For further information, see the Vermont Rules for
Environmental Court Proceedings, available on-line at www.vermontjudiciary.org. The
address for the Environmental Court is 2418 Airport Road, Suite 1, Barre, Vermont
05641 (Tel. #802-828-1660).
(38) The conditions of this Permit as set forth above supercede all conditions contained in all
prior Permits issued by the Agency to the Permittee for this Facility. [10 V.S.A. §556(c)]
The Agency's issuance of this Air Pollution Control Permit relies upon the data, judgment, and
other information supplied by the Permittee. The Agency makes no assurances that the air
contaminant source approved herein will meet performance objectives or vendor guarantees
supplied to the source Permittee. It is the sole responsibility of the Permittee to operate the
source in accordance with the conditions herein and with all applicable state and federal
standards and regulations.
Permit issued and effective this day of , 2018.
Permit issuance authorized by:
Agency of Natural Resources
Emily Boedecker, Commissioner
Department of Environmental Conservation
13
Heidi C. Hales, Director
Air Quality & Climate Division
Date Signed
jh
A2 Gregory Cremation and Memorial Service, LLC — South Burlington
Page 15 of 15
VERMONT AGENCY OF NATURAL RESOURCES
Department of Environmental Conservation
Air Quality and Climate Division
TECHNICAL SUPPORT DOCUMENT FOR
PERMIT TO CONSTRUCT #AP-18-009
February xx, 2018
Applicant: Stephen Gregory
465 Sycamore Street
Shelburne, Vermont 05482
Source: Two (2) Human Cremation Units
Gregory Cremation and Memorial Service, LLC
472 Meadowland Drive, Unit #7
South Burlington, Vermont 05403
This Technical Support Document details the Agency of Natural Resources, Department of
Environmental Conservation, Air Quality and Climate Division (hereinafter "Agency') review forthe
Air Pollution Control Permit to Construct and is intended to provide additional technical information,
discussion and clarification in support of the Permit. It is not intended to provide a comprehensive
review of the Facility or permit process or duplicate the information contained in the Permit.
Gregory Cremation and Memorial Service, LLC #AP-18-009
I. INTRODUCTION
Gregory Cremation and Memorial Service, LLC (also referred to herein as "Permittee") owns and
operates a funeral service and crematory at 472 Meadowland Drive in the town of South Burlington,
Vermont (also referred to herein as "Facility"). The Permittee has proposed to modify the existing
Facility with the installation and operation of an additional Matthews Power -Pak II Plus in addition to the
existing Matthews Power -Pak II cremation unit. The proposed unit is designed to fire charges at a
maximum rate of 150 pounds per No'& and uses two burners - a primary burner with a heat input
capacity of 2,000,000 Btu/hr and a secondary burner with a heat input capacity of 500,000 Btu/hr. The
Permittee plans to fire natural gas exclusively in the retort burners. The operations performed at the
Facility are classified within the Standard Industrial Classification Code - 7261 (Funeral Services and
Crematories).
Table 1-1 below outlines the equipment approved to operate at the Facility.
Table 1-1: Equipment Specifications
Equipment/make/model
Max charge
Heat input capacity,
Fuel
Date of
____[
rate, Ib/hr
primary/secondary/total'
type2
installation
Matthews Power -Pak II
150
2.0/0.5/2.5
LPG 1
2011
Matthews Power -Pak II Plus
175
1.5/1.5/3.0
LPG
2018
Heat input capacities listed in million British thermal units per hour.
z LPG — liquified petroleum gas.
II. FACILITY DESCRIPTION
The regulated sources of air contaminant emissions at the Facility are the human cremation units
with the equipment specifications as described above.
To begin cremation, the operator fires the secondary burner (afterburner) to preheat the cremation
unit. Once the retort achieves the minimum temperature, the operator places a batch of deceased
remains into the primary chamber and closes the chamber door. After the door is closed, the
primary burner fires and promotes initial and supplementary combustion. Once material
combustion is initiated, the primary chamber produces a mixture of highly combustible gases. This
mixture is subsequently vented to the secondary chamber and fully oxidized by the afterburner. At
the completion of the cremation process, the operator removes the ash from the primary chamber.
To ensure proper operating conditions, the retort is equipped with a thermocouple (located
downstream of the secondary chamber flame tip) that sends real time temperature measurements
to the main control panel where it is received by a temperature controller. The temperature
controller adjusts a motorized butterfly valve located on the afterburner inlet gas assembly to
regulate the heat input to the afterburner and maintain a constant temperature. The temperature
controller is also interlocked with the primary burner and prevents it from firing until the set point is
reached. As specified by the Regulations, the set point for installations installed subsequent to
June 1, 1995 is 1,600°F. In addition, should the retort exceed the maximum temperature, the
temperature controller will modulate down the primary and secondary burners.
Page 2 of 4
Gregory Cremation and Memorial Service, LLC
Ill. EMISSION CALCULATIONS
#AP-18-009
Emissions from the two Matthews units including the Power -Pak II and the Power -Pak II Plus
cremation retorts were estimated firing at maximum rates of 2.5 and 3.0 million British thermal units
per hour ("MMBtu/hr") for both primary and secondary burners combined, respectively. This was
the heat input specifications supplied by the manufacturer of the units. Emissions from these units
were estimated assuming that the combined use of the two units is unrestricted (8,760 hours, each)
per year.
The calculations made to determine allowable emissions of particulate matter ("PM/PM10"), oxides
of nitrogen ("NO,"), volatile organic compounds ("VOCs"), carbon monoxide ("CO"), and sulfur
dioxide CS02") from the cremation units are presented below. Emissions of hazardous air
pollutants are assumed to be less than one ton per year from both units, combined. Emissions of
mercury are estimated to be below the Action Level.
Particulate Emissions — Matthew Units
The average flue gas flow rate (632 dscfm) and average oxygen content (9.8% 02) was taken
from the submitted stack test (Blue Hill Cemetery, Braintree, MA August 26, 2015) and adjusted
to 7% 02. The retort tested was fueled with natural gas.
63 2 dscf ' 21 — 9. 8 _ 506dscf
( min )( 21 — 7 ) min
Allowable particulate matter emissions were then calculated using the regulatory limit of 0.06
grains per dry standard cubic foot (gr/dscf) at 7% oxygen (§5-231(2)(c) of the Regulations) and
formula outlined below.
506ds4' 0.06grain 1/h 8,760hr lion L1 ton
min )dscf' 7,000grains ��60min�
hr yr 2,0001h yr
The stack test data provided indicates that the average particulate emissions rate from the unit at
7% 02 is 0.03 grains/dscf, which is less then the regulatory limit of 0.06 grains/dscf.
Page 3 of 4
Gregory Cremation and Memorial Service, LLC #AP-18-009
Criteria Pollutant Allowable Emission Calculations for both Matthews units are shown below. The
two units have a maximum charge rate of 325 pounds per hour, combined. This maximum charge
rate was used estimate emissions from both units assuming each unit operates 4,000 hours per
year. The applicant has stated that the Facility anticipates performing 700-750 cremations per year
therefore, 4,000 hours per year is a very conservative estimate. Allowable emission estimates are
shown below in Table 3-1:
j
Table 3-1: Criteria Pollutant Allowable Emissions, Matthews Units
Calculations based on 4,000 hrs per year operation and charge rate of 325 Ibs per hr
Emission Factor
Allowable
Emissions
Charge Rate, Ib/hr
Factor
Source
tpy
I b/to n
SO2
325
2.5
AP-42 Table 2.1-12
0.8
Uncontrolled
emission factors for
CO
325
10.0
industrial/commercial
3.3
refuse combustors,
VOC
325
3.0
other than municipal
waste, multiple
1.0
NOX
325
3.0
chambers. 10/96
1.0
Mercury Emissions — Matthew Units
Mercury emissions were estimated using an emission factorfrom a June 2007 study titled Colorado
Mercury Report. This report states an emission factor of 3.2 grams of mercury per adult body. An
estimate of 730 cremations per unit per year in both units combined, was used to estimate mercury
emissions. This results in estimated actual emissions of 0.0026 tons of mercury per year, or 0.005
pounds of mercury per 8 hours. The Action Level for mercury is currently established at 0.02
pounds per 8 hours. Consequently, the Facility's emissions of mercury are below the Action Level
and no hazardous most stringent emission rate determination was made.
Page 4 of 4