The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and Chapel Hill Memorial Park Cemetery, Inc. d/b/a Chapel Hill Memorial Park Crematory (“Chapel Hill”) entered into a December 13th Consent Administrative Order (“CAO”) addressing alleged violations of an air permit. See LIS No. 21-129.
The CAO provides that Chapel Hill owns and operates a crematory (“Facility”) in Jacksonville, Arkansas.
Chapel Hill manages the Facility in accordance with:
General Air Permit for Minor Source Animal/Human Remains Incinerator Facilities 1976-AGP-000 (“Permit”)
According to DEQ personnel, they have conducted a compliance inspection at the Facility from June 22nd through May 31, 2021.
The Facility’s incinerators’ maximum hourly charging rates established in a confirmation letter are stated to be 150 pounds per hour for each incinerator. Specific Condition 11 requires Chapel Hill to keep records that demonstrate compliance with the hourly or annual charging rates as set out in the confirmation letters.
According to the CAO, the Facility exceeded its maximum charge rate of 150 pounds an hour on April 8, 2019, and May 24, 2021 based on the hours it was operated and the weight of each charge. Further, the records were inspected and found to contain:
- 72 times, the hours worked do not match the recorded start or stop time.
- Three instances where there was no stop time
- 2 instances where the charge rates weren’t recorded
- 1 instance where the temperature at the beginning and middle of a cycle was not recorded
It is also claimed that the Facility used one incinerator log sheet to record both units’ operation, instead of using separate log sheets for each unit.
Chapel Hill replied to DEQ regarding the inspection and said it now has separate log sheets for each incinerator. The Facility also stated that it provides ongoing recordkeeping training for its staff to correct recordkeeping mistakes.
Chapel Hill denies or admits the legal and factual allegations in the CAO.
Chapel Hill must submit three months’ worth of incinerator run log sheets to the CAO in order to comply with Specific Condition 10 and 11. The CAO contains a table that details the due dates and the month for which the reports are to be submitted.
A civil penalty of $6.240 will be assessed. However, this could have been reduced by one-half if signed and returned to DEQ prior to December 8.
Download a copy the CAO Here.
