permit with introductory notes - ashford
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PERMIT WITH INTRODUCTORY NOTES
Local Authority Pollution Prevention and Control Pollution Prevention and Control Act 1999 Environmental Permitting (England & Wales) Regulations 2010
08/05/2015 LAPPC 04
Contact Details at Ashford Borough Council:
Christopher Davis (Environmental Health Officer)
Ashford Borough Council
Environmental Services,
Tannery Lane, Ashford,
Kent, TN23 1PL
Email: [email protected]
Tel: (01233) 330323
Permitted Installation Address:
The KENT County Crematorium
Newcourt Wood,
Charing, Ashford,
Kent, TN27 0EB
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PERMIT WITH INTRODUCTORY NOTES LAPPC04
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PERMIT WITH INTRODUCTORY NOTES L A P P C 0 4
INTRODUCTORY NOTES
These introductory notes do not form part of the Permit
The following Permit is issued under Regulations 12 and 13 of the Environmental Permitting
(England and Wales) Regulations 2010 (henceforth referred to as the EP Regulations)
The Permit includes conditions that have to be complied with. The conditions contained within this
Permit are based upon Guidance Note PG 5/2 (12) for crematoria and is referred to for compliance
under the above EP Regulations.
BRIEF DESCRIPTION OF THE INSTALLATION REGULATED BY THIS PERMIT
The process installation is transcribed into the EP Regulations under Schedule 1 Section 5.1 Part
B (b) for crematoria.
“Best Available Techniques” (BAT), Condition 34 of this permit, includes a requirement for the
permit holder to use the best available techniques for preventing or, where that is not practical,
reducing emissions to air from the installation. Techniques include both the technology used and
the manner in which the installation is designed, constructed, operated, maintained and
decommissioned.
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DESCRIPTION OF INSTALLATION
The operation of a crematoria for the cremation of human remains.
PERMIT HOLDER:
CURRENT PERMIT ISSUED:
The KENT County Crematorium,
Newcourt Wood,
Charing,
Ashford, Kent,
TN27 0EB.
8th May 2015
CONFIDENTIALITY
The Permit requires the operator to provide information to Ashford Borough Council. Ashford
Borough Council will place the information onto the public registers in accordance with the
requirements of the EP Regulations. If the operator considers that any information provided is
commercially confidential, it may apply to Ashford Borough Council to have such information
withheld from the register as provided in the Regulations. To enable Ashford Borough Council to
determine whether the information is commercially confidential, the operator should clearly identify
the information in question and should specify clear and precise reasons.
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VARIATIONS TO THE PERMIT
This Permit may be varied in the future. If at any time the activity or any aspect of the activity
regulated by the following conditions changes such that the conditions no longer reflect the activity
and require alteration, Ashford Borough Council should be contacted. Additionally Ashford Borough
Council may vary the permit in line with alterations to regulations.
SURRENDER OF THE PERMIT
Where an operator intends to cease the operation of an installation (in whole or in part) Ashford
Borough Council should be informed in writing. Such notifications must include the information
specified in Regulation 24 of the EP Regulations.
TRANSFER OF THE PERMIT OR PART OF THE PERMIT
Before the Permit can be wholly or partially transferred to another person, a joint application to
transfer the Permit has to be made by both the existing and proposed holders, in accordance with
Regulation 21 of the EP Regulations. A transfer will be allowed unless Ashford Borough Council
considers that the proposed holder will not be the person who will have control over the operation
of the installation or will not ensure compliance with the conditions of the transferred Permit.
RESPONSIBILITY UNDER WORKPLACE HEALTH AND SAFETY LEGISLATION
This Permit is given in relation to the requirements of the EP Regulations. It must not be taken to
replace any responsibilities you may have under workplace Health and Safety legislation.
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APPEAL AGAINST PERMIT CONDITIONS
There is a right of appeal against permit conditions and Regulation 31 and Schedule 6 of the
Environmental Permitting (England and Wales) Regulations 2010 will apply.
Appeals should be addressed to the Secretary of State for Environment, Food and Rural Affairs at
the following address:
The Planning Inspectorate
Environmental Appeals Administration,
Room 4 / 19 Eagle Wing,
Temple Quay House,
2 The Square,
Temple Quay,
BRISTOL,
BS1 6PN.
Please Note
An appeal brought under paragraph (1) (c) or (d) in relation to the conditions in a permit will not
suspend the effect of the conditions appealed against; the conditions must still be complied with.
In determining an appeal against one or more conditions, the Act allows the Secretary of State in
addition to quash any of the other conditions not subject to the appeal and to direct Ashford
Borough Council either to vary any of these other conditions or to add new conditions.
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Further guidance relating to the procedure for regulating installations and issuing permits is
contained in a manual on the DEFRA website at:
https://www.gov.uk/government/publications/environmental-permitting-general-guidance-manual-on-
policy-and-procedures-for-a2-and-b-installations
END OF INTRODUCTORY NOTES
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ASHFORD BOROUGH COUNCIL
POLLUTION PREVENTION AND CONTROL ACT 1999
THE ENVIRONMENTAL PERMITTING (ENGLAND AND WALES) REGULATIONS 2010
Permit Reference No: LAPPC04
The KENT County Crematorium Ltd. (permit holder) of Newcourt Wood, Charing, Ashford,
Kent, TN27 0EB is hereby permitted to carry on the cremation of human remains as described
below, within the boundary as marked orange on the attached plan ref. LAPPC04 / P1
[Appendix 1].
Address of permitted installation: The KENT County Crematorium
Newcourt Wood
Charing
Ashford
Kent
TN27 0EB
DESCRIPTION OF PERMITTED INSTALLATION
Cremation of human remains using 2 no. gas fired series 300 cremators by Facultatieve
Technologies. Each cremator comprises a primary chamber into which the coffin is inserted and
within which the primary combustion takes place.
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The hearth comprises flat sillimanite tiles so as to keep the primary chamber entirely separate from
the secondary chamber and avoid by-passing of the flue gases. The primary chamber is equipped
with a single burner located in the end wall and two independently controlled sets of air jets.
The waste gases produced from this phase of the cremation exit the primary chamber via a
transfer port in the chamber sidewall and descend below the solid hearth into the first section of the
secondary combustion zone in which the gas phase combustion takes place. Before the gases
enter this zone they are heated by the first of the two secondary zone burners. The gases make a
series of passes above, below and to one side of the primary chamber.
The gas temperature is maintained by the second of the two secondary zone burners. The total
volume of the secondary combustion zone is sufficient to ensure that a residence time of two
seconds is maintained under all operating conditions.
This is a permitted installation by virtue of Regulation 12 and 13 and Schedule 1, Section 5.1
Part B (b) of the Environmental Permitting (England and Wales) Regulations 2010.
CONDITIONS
The following conditions shall apply:
Emission Limits and Controls
1. All releases to air, other than steam or condensed water vapour, shall be free from
persistent visible emissions and free from droplets.
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2. Emissions from each cremator shall, in normal operation (including start up and shutdown)
be free from visible smoke and no emissions from either cremator shall exceed the
equivalent of Ringelmann Shade 1 as described in BS 2742:2009.
3. Emissions from each cremator shall not cause offensive odour outside the boundary of the
installation as marked in orange on the attached plan ref. LAPPC04 / P1 [Appendix 1].
4. The following table contains the specific emission limits that shall apply during normal
operation of each cremator:
Table A : Specific Emission Limits
SUBSTANCE CONCENTRATION LIMITS
Hydrogen chloride
(excluding particulate matter) 200 mg / m
3 averaged over an hour
Total particulate matter
(from cremator)
80 mg / m3 averaged over an hour for 95% of
cremations and 160 mg / m3 averaged over an
hour for all cremations
Carbon monoxide
100 mg / m3 averaged over the first hour for 95%
of cremations and 200 mg / m3 averaged over
the first hour for all cremations
Organic compounds
(excluding particulate matter) expressed
as carbon
20 mg / m3 averaged over an hour of cremation
Particulate matter from cremated remains
reduction plant that vents externally
50 mg / m3 with no correction for oxygen
concentration or water vapour
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The sampling protocol for each particular substance identified in Table A above shall be
in accordance with Table 3 of PG Note 5/2 (12) [Appendix 3], unless otherwise agreed in
writing by an authorised person of Ashford Borough Council.
The annual emission testing required by Condition 11 of this permit shall encompass at least two
individual cremations on each cremator.
All pollutant concentrations shall be expressed at reference conditions:
273K, 101.3 KPa and 11% oxygen v/v, dry gas unless otherwise stated.
Monitoring, Sampling and Measurement of Emissions
5. As part of proper supervision the permit holder shall monitor emissions to air and make
tests and inspections of the installation. All sampling and tests required by conditions
attached to this permit shall be carried out during operation of each cremator at its usual
operating capacity.
Where compliance monitoring is undertaken no result shall exceed the emission
concentration limits specified, except where either:
(a) Data is obtained over at least 5 sampling hours in increments of 15 minutes or less; or
(b) At least 20 results are obtained where sampling time increments of more than 15
minutes are involved; AND in the case of (a) or (b)
(c) No daily mean of all 15-minute mean emission concentrations shall exceed the
specified emission concentration limits during normal operation (excluding start-up
and shut-down); and
(d) No 15-minute mean emission concentration shall exceed twice the specified emission
concentration limits during normal operation (excluding start-up and shut-down).
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An authorised person of Ashford Borough Council shall be advised at least seven days in
advance of any periodic monitoring exercise to determine compliance with emission limit
values of the provisional time and date of monitoring, pollutants to be tested and the
methods to be used.
6. Emissions from each cremator shall be continuously indicatively monitored for total
particulate matter using a dedicated analyser and the results shall be continuously
recorded. The instruments shall be fitted with audible or visual alarms that activate at a
reference level. Emission events that activate the alarms shall be electronically recorded.
7. Emissions from each cremator shall be continuously indicatively monitored for carbon
monoxide and the instrument shall be capable of recording data at less than 10 second
intervals.
8. The oxygen concentration at the outlet of the secondary combustion zone of each cremator
shall be continuously monitored and continuously recorded using a dedicated analyser.
The oxygen concentration at the point of discontinuous measurement of the controlled
pollutants contained in Table A of Condition 4 shall also be measured to enable the results
to be reported in accordance with the reference conditions.
9. All continuous monitoring instruments provided in accordance with Conditions 7 and 8 shall
be checked for correct functioning and calibrated in accordance with the manufacturer’s
instructions.
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10. All continuous monitor readings shall be continuously recorded and the readings shall be on
immediate display to operating staff. The instruments shall be fitted with a visual alarm
which shall activate whenever a 60 minute mean value exceeds the emission limit in
Table A of Condition 4. Emission events that activate the alarms shall be electronically
recorded.
11. Emissions from each cremator shall be tested at least once a year for organic compounds
(excluding particulate matter) and for hydrogen chloride (excluding particulate matter).
Emissions shall also be tested at least once a year for total particulate matter and carbon
monoxide.
12. Visual and olfactory assessments of emissions to air shall be made regularly and at least
once a day, in particular to confirm continued operation of the particulate matter continuous
monitoring instrument provided in accordance with Condition 6. Remedial action shall be
taken immediately in the case of abnormal emissions.
13. The results of all monitoring and inspections (including continuous monitor charts and
records) shall be recorded in a logbook, retained at the crematorium for a minimum of two
years. Records of visual and olfactory assessments carried out in accordance with
Condition 12 shall include the date, time, result of assessment and name of person
undertaking the assessment.
The permit holder shall investigate any adverse monitoring results and take any corrective
action immediately. The corrective action shall be recorded in the logbook. The permit
holder shall ensure the logbook is available for inspection by an authorised person of
Ashford Borough Council.
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14. The permit holder shall provide at monthly intervals a written summary of the continuous
monitoring data from each cremator to an authorised person of Ashford Borough Council.
The permit holder shall also supply one set of results for each cremator during the course of
the first cremation of the week, in one week of the month.
15. In any case where the emission measurement exceeds the concentration limit value
contained in Table A of Condition 4, the results shall be forwarded to an authorised person
of Ashford Borough Council. Where any emission level is more than twice the concentration
limit value an authorised person of Ashford Borough Council shall be advised immediately
by telephone or facsimile.
16. The results of all non-continuous emission testing carried out in accordance with Condition
11 shall be forwarded to an authorised person of Ashford Borough Council within 8 weeks
of the completion of the sampling.
17. The permit holder shall have regard to BS ISO 9096:2003 when providing facilities for
sampling on vents or ducts associated with the permitted installation. In particular, attention
shall be given to the design and location of sampling systems to ensure that representative
samples are obtained.
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Materials Handling and Storage
18. The coffin, fittings and lining to be used in respect of the deceased person shall conform to
the requirements of the Federation of British Cremation Authorities (FBCA) Instructions for
Funeral Directors. In particular:
Poly vinyl chloride and melamine shall not be used in coffin construction or
furnishings;
Cardboard coffins shall not contain chlorine in the wet strength agent;
Packaging for stillbirth, neonatal and foetal remains shall not include any chlorinated
plastics;
Coffins containing lead or zinc shall not be cremated
19. Each cremator shall be designed and operated in order to prevent the discharge of smoke,
fumes or other substances during charging. In the event of mechanical failure during the
cremation cycle that is likely to adversely affect emissions to air, the cremator shall be shut
down at the end of the cremation cycle and not recharged until all necessary repairs have
been completed.
20. Each cremator and all ductwork shall be made and maintained gas tight if under positive
pressure, to prevent the escape of gases from the ductwork or cremator to the air.
21. At the end of a cremation the deceased remains shall only be removed when calcination
has been completed.
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Flue Gas Treatment
22. Each cremator shall be designed to ensure complete combustion and shall be fitted with a
secondary combustion zone.
The temperature of gases after the last admission of secondary air and at the exit from the
secondary combustion zone shall be continuously monitored and continuously recorded.
Audible or visual alarms shall be triggered when the temperature in the secondary
combustion zone falls below that specified in Condition 23.
Each cremator shall be designed so that there is adequate secondary air in the primary
combustion zone to ensure good turbulence.
23. The gases shall be held at 1123K (850°C) for a minimum (at all times) of two seconds in the
secondary combustion zone. The residence time shall be determined by direct
measurement of the volume flow rate of the flue gases throughout the cremation cycle at
the cremator exit with appropriate corrections made for changes in temperature and
oxygen.
The concentration of oxygen at the outlet of the secondary combustion zone, measured wet
or dry, shall have a minimum average 6% and a minimum 3%.
The charging system shall be interlocked to prevent the introduction of a coffin to the
primary combustion zone unless the secondary combustion zone temperature exceeds
1123K (850°C).
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Disposal of Residues
24. The removal of ash and non-combustible residues shall be undertaken carefully so as to
prevent dust emissions via the flue.
Cremated remains shall be moved and stored in a covered container.
Chimney
25. Waste gases emitted from each cremator shall be discharged to atmosphere at not less
than 15 m/s-1
during peak operating conditions to achieve adequate dispersion.
The minimum height at which the waste gases shall be discharged shall be not less than
14 metres above ground level.
26. Chimney flues and the ductwork leading to the chimney shall be adequately insulated to
minimise the cooling of waste gases and prevent liquid condensation on internal surfaces.
Waste gases from each cremator shall be discharged vertically to the atmosphere and the
chimney shall not be fitted with any restriction at the final opening.
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General Operations
27. Any malfunction or breakdown leading to abnormal emissions to air shall be dealt with
promptly and operations adjusted until the malfunction or breakdown has been restored.
The malfunction or breakdown shall be recorded in the logbook provided in accordance with
Condition 13. If there is likely to be an effect upon the local community an officer of Ashford
Borough Council shall be informed without delay.
28. The person having operational control of the cremators shall be identified in writing to
Ashford Borough Council.
29. All operational staff shall hold appropriate certification from a suitable organisation to
demonstrate their proficiency in operating cremators or, in the case of unqualified staff, shall
be under the direct supervision of an experienced certified technician.
The permit holder shall maintain a statement of training requirement for each operational
post and keep a record of the training received by each person whose actions may have an
impact on the environment. These documents shall be available upon request to an
authorised person of Ashford Borough Council.
30. The operator is required to keep a record of gas consumption for the installation, which the
regulator may request in the course of the annual inspection.
31. The operator is required to draw up a simple plan for dealing with emergencies which give
rise to mass fatalities, which should mainly address the holding of additional spares and
consumables and the training of suitable members of staff.
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Mercury Abatement
32. The KENT County Crematorium (Charing) is paired with Barham Crematorium (Canterbury)
for the purposes of Mercury Abatement. By the 1st
April each year, the operator shall
submit a certificate to an Authorised Officer of Ashford Borough Council, from the
Crematoria Abatement of Mercury Emission Organisation (CAMEO) or appropriate
evidence from a comparable audited burden sharing arrangement or scheme which
specifies;
a) the total number of cremations in the preceding calendar year for the paired
installations;
b) of those, the number of cremations undertaken in cremators fitted with
operational mercury abatement equipment in the same period;
c) the number of cremations undertaken in the previous 12 months and the
proportion of those subject to burden sharing arrangements under which
money is paid for the benefit of abated crematoria; or
33. If the operator proposes to make a change in operation of the installation, they must, at
least 14 days before making the change, notify an Authorised Person of Ashford Borough
Council, in writing.
The notification must contain a description of the proposed change(s) in operation. It is not
necessary to make such a notification if an application to vary this permit has been made
and the application contains a description of the proposed change. In this condition ‘change
in operation’ means a change in the nature or functioning, or an extension of the installation,
which may have consequences for the environment.
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34. The Best Available Techniques (BAT) shall be used to prevent or, where that is not
practicable, reduce emissions from the installation in relation to any aspect of the operation
of the installation which is not regulated by any other condition of this permit.
Signed:
Officer: Christopher Davis
Designation: Environmental Health Officer
Dated: 8th May 2015
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LIST OF APPENDICES
Appendix 1 : LAPPC04 / P1 [Site Location Plan]
Appendix 2 : LAPPC04 / P2 [Site Boundary]
Appendix 3 : LAPPC04 / P3 [Table 3 of PG 5/2 (12)]
[http://www.doeni.gov.uk/pg_5-2_crematoria.pdf]
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Appendix 1 : LAPPC04 / P1 [Site Location Plan]
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Appendix 2 : LAPPC04 / P2 [Site Boundary]
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Appendix 3 : LAPPC04 / P3 [Table 3 of PG 5/2 (12)]
[http://www.doeni.gov.uk/pg_5-2_crematoria.pdf]
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END OF PERMIT