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Lane Regional Air Protection Agency



Lane Regional Air Protection Agency


Minimal Source Air Contaminant Discharge Permit




REVIEW REPORT



Musgrove Crematorium
Permit No. 204732

PERMITTING

Permitting Action


1.
The action is a renew al for an existing Air Contaminant Discharge Permit (ACDP), w hich
w as re-issued on June 1, 2001, w ith an expiration date of May 31, 2006. There have been
no permitting actions since last renew al.

Location Area Attainment Status


2.
The facility is located in an attainment area for all pollutants except PM
10
(particulate matter
less than 10 microns in size). The Eugene/ Springfield Air Quality Management Area is a
non-attainment area for PM
10
. The Eugene/ Springfield Air Quality Management Area is an
attainment area for the criteria pollutants PM, CO, VOC, NO
X
, and SO
X.


SOURCE DESCRIPTION


Overview


3.
The facility operates a crematory unit for purposes of human and animal remains
incineration. Installation w as completed on or about May of 1984. LRAPA approved
construction on May 10, 1984. The crematory unit is defined as an existing unit since it
w as constructed or modified prior to March 13, 1990, (OAR 340 -0255-0855(13)), and
must meet a 1600
E
F final combustion chamber (after-burner) temperature during the
course of cremation rather than the 1800
E
F final combustion chamber temperature
required of new units. The facility conducted up to about 420 cremations per year for the
period of time since last renew al. The facility normally operates during w hat may be
considered a typical 8 hours-per-day, 5 days-per-w eek, w ork w eek.

4.
There have been no changes to the source since initially permitted.


Process and Control Devices


5.
The facility operates an All Crematory unit model No. L
-1701. The crematory, fueled by
natural gas, w as put in service in 1984. Emissions are controlled, as required by regulation,
by an after-burner and exhaust gases from the after-burner are vented to the atmosphere.


EMISSIONS


6.
Emissions for this source are expected to be minimal and consist mainly of particulate
matter (PM) and products of combustion from the auxiliary fuel. A source performance PM
stack test, as required by regulation, w as performed by Horizon Engineering on February 23,
1993. The result of the PM stack test w as 0.021 gr/dscf corrected to 7% O
2
. The PM
limit, as stated in LRAPA 30-045(1), is 0.08 gr/dscf. The average pound-per-hour PM
emission rate w as 0.078. Typical cremation duration is at w orst case tw o (2) hours. At
420 cremations, PM emissions w ould be approximately less than 100 pounds per year.


MINIMAL PERMIT DETERMINATION



7.
The Authority has determined that the source qualifies as a minimal source for the follow ing
reasons:

a.

Emissions from this source are less than 5 tons per year of PM and less than 10
tons per year for the criteria gaseous pollutants.


b.

The facility w as inspected on July 12, 2006 and found to be in compliance w ith
permit conditions.


SPECIAL CONDITIONS (Optional)


8.
Permittee requested that the burning of clean w ood be allow ed on a periodic basis to
prevent and/or eliminate odors associated w ith operation of the crematory unit. The
procedure is addressed in Additional Conditions, item 11. The burning of the w ood
volatilizes and incinerates oils that may have become entrained w ithin refractory voids. The
process w as recommended by engineering firm. LRAPA had received periodic odor
complaints that have subsided concurrent w ith the burning of the w ood practice.


NESHAPS APPLICABILITY


9.
There are no sources at this facility for w hich NESHAPS standards have been promulgated.


NSPS APPLICABILITY


10.
There are no sources at this facility for w hich NSPS standards have been promulgated.


REPORTS


11.
As directed by the Authority.


ENFORCEMENT HISTORY


12.
Notice of Non-Compliance (NON) 1088 w as issued to Musgrove on June 15, 1995 for an
opacity violation that occurred on June 14, 1995. Visible emissions reached 30% opacity.
Permit limit is 10% opacity. NON 1088 required that Musgrove submit a corrective action
plan. The plan w as submitt ed in a timely manner and during the course of a follow -up
inspection on July 19, 1995 the facility w as found to be in compliance and NON file 1088
w as closed.



NON 1466 w as issued to Musgrove on January 29, 1999 for failure to notif y LRAPA of
breakdow n of equipment or air pollution control equipment w hich may result in exceeding
emission limitations. The equipment breakdow n occurred on January 27, 1999 and LRAPA
received a citizen complaint regarding smoke from the crematory stack. M usgrove
acknow ledged the equipment breakdow n and LRAPA proceeded w ith Notice of Violation
and Civil Penalty (NCP) 99-1466 for the violation. NCP 99-1466 included a civil penalty in
the amount of $600. Musgrove admitted the violation and requested reduction in civil
penalty. The penalty w as reduced to $250. On June 2, 1999 NCP file 99 -1466 w as closed
upon LRAPA receiving payment of the $250 civil penalty.

NON 2187 w as issued to Musgrove on January 29, 2001 for failure to maintain during the
course of a cremation a final combustion chamber temperature of 1400
E
F. NON 2187
required that Musgrove submit a w ritten account. Musgrove submitted the account in a
timely manner and acknow ledged that operator error w as responsible. LRAPA proceeded
w ith NCP 01-2187 for the violation. NCP 01-2187 included a civil penalty in the amount of
$1300. On April 18, 2001 NCP file 01-2187 w as closed upon LRAPA receiving payment of
the $1300 civil penalty.


NON 2275 w as issued to Musgrove on June 22, 2001 for a visible emissions and opacity
violation that occurred on May 10, 2001. For a period of 8.75 minutes visible emissions
w ere observed from crematory stack. Permit limit is less than 3 minutes in any one hour.
Highest level of visible emissions observed w as 30% opacity. Permit limit is 10% opacity.
LRAPA proceeded w ith Notice of Violation and Civil Penalty (NCP) 01 -2275 for the
violation. NCP 01-2275 included a civil penalty in the amount of $3,600. Musgrove
admitted the violation and requested reduction in civil penalty. The penalty w as reduced to
$1800 of w hich $600 w as suspended. On August 14, 2001 NCP file 2275 w as closed
upon LRAPA receiving payment of the $1200 civil penalty.



PUBLIC NOTICE


Renewal


13.
The draft permit w as on public notice from December 11, 2006 to January 9, 2007. No
comments w ere submitted during the 30-day comment period.


JM/cw
01/18/07