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Dennis Welsch <br />Page 2 of 4 <br />May 17, 2002 <br />Based upon our review of the material and previous discussions with you, the City Council and <br />various Roseville residents had several concerns regarding the Proposed Roselawn Crematory <br />Facility. The most critical concerns appeared to involve the emissions from the proposed facility <br />and the potential long-term health effects of these emissions. DPRA will attempt to present the <br />critical e�sting information regarding these concerns in lay terms to clarify the impact of the <br />proposed facility. <br />Crematory Facility Emissions <br />To comply with Section 129(a)(1)(E) of the amended Clean Air Act, which discusses EPA <br />requirements for crematory facilities, the EPA conducted emission testing at a representative <br />crematory at the Woodlawn Cemetery in New York The specifications of the cremation <br />equipment used at Woodlawn were similar to the proposed Roselawn equipment. The results of <br />this testing, which were presented in the Emission Test Evaluation prepared by MRI, present <br />specific emission concentrations of each of the pollutants from a similar crematory. The <br />proposed facility will emit pollutants at identified concentrations; these pollutants include <br />particulate matter, carbon mono�de, nitrogen oxide, sulfur dio�de, polynuclear aromatic <br />hydrocarbons (PAHs), hydrogen chloride, cadmium, lead, mercury, and total chlorinated <br />dibenzo-dioxins (TCDD). Generally speaking the emission concentrations of the criteria <br />pollutants and toxic pollutants from the proposed facility are defined and predictable. <br />Based upon DPRA's review, two statements in the City Council Meeting Minutes regarding <br />these emissions should be clarified. First, according to information provided by Industrial <br />Equipment and Engineering Ca (IEE), typical cremation systems are unable to control hydrogen <br />chloride and nitrogen o�de emissions. This should not be interpreted to mean that crematory <br />emissions are unknown, unpredictable, or uncontrollable. It does mean that air pollutant removal <br />systems will not affect these two pollutants; however, the EPA Study results clearly identified the <br />emission concentrations of hydrogen chloride and nitrogen oxide. In addition, DPRA provides <br />clarification of a statement from the NIl'CA regarding crematory emissions being unregulated. <br />According to Ms. 7ackson, the reason that crematory emissions do not require a specific air <br />permit from the NIl'CA is that the EPA Study and other experience indicates that actual <br />crematory emissions are well below any NIl'CA risk-based thresholds. <br />Various concerns were raised by residents and the City Council involving the potential emission <br />of radioactive material from patients that were treated with brachytherapy seeds. Based upon the <br />information provided by Mr. Douhitt, Cincinnati College of Mortuary Science, it is critical that <br />the operator of the crematory facility determines if brachytherapy seeds were implanted in the <br />patient, inquires to the type of seeds used, and, if they remain radioactive at the time of <br />cremation, ensures that they are removed by a trained professional. <br />