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Cremation, Air Pollution, and Special Use

Permitting: A Case Study
a b b
Laura C. Green , Edmund A. C. Crouch & Stephen G. Zemba
a
Environmental Health & Toxicology, CDM Smith , Cambridge , MA ,
USA
b
Cambridge Environmental , Cambridge , MA , USA
Accepted author version posted online: 27 Aug 2012.Published
online: 25 Nov 2013.

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 Human and Ecological Risk Assessment, 20: 559–565, 2014
Copyright C Taylor & Francis Group, LLC
ISSN: 1080-7039 print / 1549-7860 online
DOI: 10.1080/10807039.2012.719391

REGULATORY ISSUES ARTICLE

Cremation, Air Pollution, and Special Use Permitting:

A Case Study

Laura C. Green,1 Edmund A. C. Crouch,2 and Stephen G. Zemba2

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1
Environmental Health & Toxicology, CDM Smith, Cambridge, MA, USA;
2
Cambridge Environmental, Cambridge, MA, USA

ABSTRACT
Risks to health posed by emissions of hazardous air pollutants from crematories
are emerging concerns. The presence of silver–mercury amalgams in bodies results
in airborne emissions of mercury; and the combustion of essentially any material
results in emissions of polychlorinated dibenzodioxins and furans (PCDD/Fs; “diox-
ins”). These and other trace emissions from crematories are not regulated at the
U.S. federal or (typically) state level, but neighborhood concerns may necessitate
quantitative evaluations of potential local impacts, and local officials may need to
rely on such evaluations in order to determine whether and under what conditions
to grant (or deny) operating permits. Here we present a case study in which these
and other issues were evaluated. Using air dispersion models and health risk assess-
ment models, we predicted exposures that would be within health-based guidelines.
Concerned citizens provided information that seemed to suggest otherwise. In the
end, communication, education, and compromise led to a favorable result.
Key Words: cremation, mercury, dioxins, health risk assessment, permitting.

INTRODUCTION
The siting of new crematories often involves consideration of impacts to ambient
air from exhaust gases. Traditionally, the impacts of interest have been the potential
for smoke and odors, but more recently, emissions of trace quantities of potentially
toxic pollutants have also become concerns (Rahill 2008).
In terms of emission rate thresholds, crematories are not major sources of air
pollution, so that oversight by environmental regulators at the Unite States federal

Received 14 June 2012; revised manuscript accepted 13 July 2012.

Disclaimer: The work underlying this article was funded by Pierce Funeral Home, Manassas,
Virginia, but the article itself was not, and no one other than the authors had a role in writing
or reviewing it. We have no conflicts of interest.
Address correspondence to Laura C. Green, Environmental Health & Toxicology, CDM Smith,
50 Hampshire Street, Cambridge, MA 02139, USA. E-mail: [email protected]

559
 L. C. Green et al.

and state level is minimal. At the local level, however, interest and oversight can
be both intensive and extensive. This is especially true if the owners of a proposed
facility are seeking a change in local zoning, a special use permit, or other approvals
to be granted (or denied) at the level of the town, city, or county.
In what follows, we describe our analysis of impacts to ambient air and poten-
tial health-risks there from, due to emissions of trace pollutants from a proposed
crematory. The crematory was proposed to be located next to a long-standing and
well-regarded funeral home, located in a residential/mixed-use neighborhood in a
small city in Virginia. Several neighbors expressed concerns about airborne emis-
sions in general, and about polychlorinated dibenzodioxins and furans (PCDD/Fs;
“dioxins”) and Hg in particular. Our assignment was to determine whether these
concerns were valid; and, if so, in what ways the proposed facility might be altered
in order to render impacts acceptably small.
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METHODS
Our assessment proceeded in three steps. First, we estimated the amounts of
PCDD/Fs and Hg that might be emitted from the proposed facility. To estimate emis-
sions of PCDD/Fs, we obtained emission factors from the U.S. Environmental Protec-
tion Agency’s (USEPA’s) Webfire database system (http://cfpub.epa.gov/webfire/).
These factors derive from testing in 1992 of a crematory in California. Per standard
health-risk assessment practice, we multiplied each congener-specific emission fac-
tor by its “toxic equivalency factor,” as established by the World Health Organization
(WHO 2005), to generate a toxicologically equivalent effective emission rate of
2,3,7,8-tetrachlorodibenzo(p)dioxin (2,3,7,8-TCDD), the congener for which the
largest amount of toxicity data are available. Assuming that non-detected congeners
might be present just at their analytical limits of detection, we derived an emis-
sion factor of 0.735 μg 2,3,7,8-TCDD toxic equivalents (TEQs) per cremated body.
For our analysis, we assumed that the proposed facility would cremate four bodies
per day (d), yielding an estimated PCDD/F emission rate of approximately 3 μg
2,3,7,8-TCDD TEQs per day.
With regard to Hg, the amount emitted during cremation depends on the amount
of Hg in the cremated body, which depends in turn primarily on the body’s number
and weight of silver-Hg amalgam dental restorations. Mercury emissions from cre-
matories have been measured or modeled in various ways (reviewed in NESCAUM
2011; Mari and Domingo 2010; Rahill 2008; Tetra Tech 2007). Because the emissions
datasets are few, highly variable, and may not be representative of the case at hand,
we relied instead on a mass balance analysis by Cain and co-workers (2007), which
yielded an average of 3 g of Hg emitted per cremated adult. Based on this estimate,
combined with our assumption that the proposed facility would cremate four bodies
per day, we estimated an Hg emission-rate of 12 g/d.
Second, we modeled the dispersion of the assumed emissions of PCDD/Fs and Hg
into ambient air to determine levels of exposure to these chemicals. In particular, we
used the USEPA air dispersion models ISCST3 and AERMOD (USEPA 1995b, 2004)
to estimate the potential increases in PCDD/Fs and Hg in air at nearby residences
and schools. We assumed regulatory default model options along with rural land
use and flat terrain, according to USEPA (2005) guidelines. Mercury and PCDD/F

560 Hum. Ecol. Risk Assess. Vol. 20, No. 2, 2014

 Cremation, Air Pollution, and Special Use Permitting

emissions were assumed to be released over a facility operating period from 8:00 a.m.
to 9:00 p.m. (per the special use permit conditions). Stack parameters used as model
inputs were determined from engineering drawings and technical specifications,
and include an emission height of 26.75 ft, a stack exit diameter of 20 in, an effluent
exit temperature of 1100◦ F, and an effluent flow rate of 2500 ft3/min. Aerodynamic
plume downwash was evaluated based on the dimensions of the existing funeral
home and proposed crematory building. Five years of hourly meteorological data
observations from the nearest airport were used to predict concentrations over grids
of densely spaced receptor locations. Concentrations were modeled at ground level
and at “flagpole” heights of 5, 10, and 15 m above ground, in order to evaluate
plume impacts at neighboring, multi-story townhouses.
Third, we compared the predicted impacts with health-based guidelines, in order
to determine whether these impacts would be acceptably small.
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RESULTS
With regard to PCDD/Fs, we estimated a worst-case impact to ambient air of
0.0008 pg/m3 2,3,7,8-TCDD TEQs at modeling locations throughout the residential
areas to the east of the proposed crematory, and a worst-case increase of 0.0005
pg/m3 at the nearest neighborhood school. To determine whether these dioxin
impacts would be acceptably small, we first translated them into doses by assuming
that a person would be at the point of maximum impact for 24 h/d, day in and day
out; and, using “standard values,” that he or she would weigh 70 kg and breathe
20 m3 of air daily. Our resulting worst-case dose-estimates were thus 0.0002 pg/kg-d
in the residential area and 0.0001 pg/kg-d at the school. For a child weighing 15 kg
and breathing 10 m3/d air, the corresponding dose-estimates were 0.0005 pg/kg-d
and 0.0003 pg/kg-d.
To then determine whether these doses would be acceptable, we compared them
with the “reference dose” (essentially, an acceptable daily intake) for 2,3,7,8-TCDD
recently published by the USEPA (2012), which is 0.7 pg/kg-d 2,3,7,8-TCDD. Since
our conservatively predicted incremental doses are thousands of times smaller than
this acceptable limit, they would not be expected to harm health.
With regard to Hg, the maximum incremental concentration of Hg in the res-
idential neighborhood was estimated to be 3 ng/m3, and the predicted impact at
the nearest school was estimated to be 2 ng/m3. To evaluate whether these airborne
concentrations of Hg are acceptably small, we compared them with exposure guide-
lines and limits that have been derived by various groups of regulatory toxicologists,
whose tasks are to protect industrial workers and/or the general public, includ-
ing infants. The occupational guidelines apply to exposures that may occur 8 h/d,
throughout a working lifetime. Similarly, the guidelines for the general population
represent long-term average concentrations (typically calculated as annual averages)
expected to be safe over a lifetime. These values are provided in Table 1. Note that
the predicted maximum incremental impact of Hg in ambient air (3 ng/m3) is well
within these long-term, health-based guidelines.
As just noted, the ambient air impacts of Hg that we predicted—and the guidelines
against which we measured them—are long-term average concentrations. However,
some states, including Virginia, also have guidelines for allowable “peak” exposures

Hum. Ecol. Risk Assess. Vol. 20, No. 2, 2014 561

 L. C. Green et al.

Table 1. Benchmark concentrations of Hg in air.

Concentration Regulatory/scientific
Type of exposure (ng/m3 Hg in air) agency
Health-based exposure 100,000 OSHA (2007)
limits/guidelines for workers
50,000 NIOSH (1992)
25,000 ACGIH (2001)
Health-based exposure 300 USEPA (1995a)
guidelines for the general 200 ATSDR (1999)
population 100 Virginia DEQ (2012)

that might occur over a worst-case hour. In particular, the hourly ambient air guide-
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line for Hg set by regulators at the Virginia Department of Environmental Quality

is 2,500 ng/m3 Hg in air. For purposes of our analysis, we assume that this guideline
would be enforced as are several federally enforceable standards, such that at least
99% of the hourly impacts at the maximally affected residence would have to be
smaller than this guideline. To predict hourly impacts, we performed a probabilistic
analysis that considered (i) the variability in the Hg content of human bodies, based
on dental restoration counts from the National Health and Nutrition Examination
Survey (NHANES) and various other factors (as estimated by Craft 2012) and (ii)
hourly meteorological conditions that influence atmospheric dispersion and trans-
port. Our analysis indicated that 99.99% of the predicted hourly impacts at the
maximally affected residence would be smaller than the 1-h ambient air guideline-
limit.
We would add that because moderate concentrations of Hg in air are not acutely
toxic— but can, of course, be toxic given chronic over-exposures—compliance with
long-term guidelines is more important than compliance with short-term limits.
Indeed, toxicologists at USEPA and the Agency for Toxic Substances and Disease
Registries (ATSDR) have set guidelines only for long-term, and not short-term,
exposures to Hg. This is because Hg is not a respiratory irritant, and acutely toxic
concentrations essentially cannot be reached in ambient air (Magos and Clarkson
2006).
We note also that dentists appear to be increasingly using non-Hg-amalgams
to repair cavities (Figure 1), and the total number of restorations per person also
appears to have been declining since at least 1980 (Eklund et al. 1997; Eklund 2010).
Thus, all other things being equal, emission-rates of Hg from crematories are likely
to decline over time (and to otherwise be smaller than assumed in our conservative
analysis).

DISCUSSION AND RESOLUTION

Community members concerned about new projects increasingly turn to the Web
for information. However, as we all do or should know, not all such information is
evidence-based, unambiguous, or otherwise reliable. Complicating matters is the
fact that decision-makers, such as city council members, may not be completely

562 Hum. Ecol. Risk Assess. Vol. 20, No. 2, 2014

 Cremation, Air Pollution, and Special Use Permitting

Fraction of fillings that were amalgam

0.9
0.8
0.7
Fraction of fillings

0.6
0.5
0.4
0.3
0.2
0.1
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0
0 10 20 30 40 50 60 70 80 90 100
Age/yrs
2007 2002 1997 1992
Figure 1. The fraction of new dental fillings that were amalgam, based on insur-
ance claims of 1.25 to 1.84 million people in Michigan, USA (data from
Eklund 2010). (Color figure available online.)

conversant with environmental sciences, toxicology, and other aspects of health risk
assessment—and rarely have the funds to hire technical experts on whom they might
rely.
In the case at hand, one concerned citizen found and submitted Figure 2 to
the city council, a figure that apparently was adapted from the site No2Crematory.
wordpress.com. The bar chart looks worrisome indeed, except that, the more you
look, the less clear it is just what is being presented. In particular, in what way is
<25 g the “EPA maximum ‘safe’ exposure level over 1 year”? No citation is provided,
and we could not reproduce this value given any standard toxicologic approaches.
Emissions of 25 pounds of Hg annually do distinguish a “major” source from a
“non-major” source of pollution per USEPA’s Clean Air Act regulations, but, of
course, such distinction does not separate “safe” from “unsafe” facilities—and in
any event, since 1200 g is 2.6 lbs, a crematorium would be classified as a “non-major”
source. The concerned citizen could not have known this, and took the website’s
“information” as fact.
Another concerned citizen submitted to the city council a draft report from an
air quality engineer with the Monterey Bay Unified Air Pollution Control District
in California, entitled, Crematory Toxic Emissions Inventories, Risk Assessments, and Risk
Reduction Measures (Craft 2012). The Executive Summary reads, in part:
The information contained in this report shows that although many toxic sub-
stances are emitted from crematory operations, mercury is the most significant
substance impacting people residing or working nearby. . . . Downwind mercury
concentrations can be above the level the State of California has identified as
having no acute adverse health effects.

Hum. Ecol. Risk Assess. Vol. 20, No. 2, 2014 563

 L. C. Green et al.

>1200g
Average number of bodies cremated
annually per crematory (Crematory
Association of North America)

Grams of Mercury released annually

(based on an average number of amalgam
400 fillings per cadaver, estimated to release 3
grams of Mercury per cremation)

EPA maximum "safe" exposure level over

<25g
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one year <25g

ONE CREMATORY UNIT

Figure 2. Erroneous bar chart, available at http://no2crematory.wordpress.com/
faq/. (Color figure available online.)

On the face of it, this information is also worrisome. And, unfortunately, decision-
makers often have little time to read beyond the Executive Summary. The body of
the report indicates that the “downwind concentrations” alluded to are not measure-
ments, but instead modeled estimates. These estimates were generated using “worst-
case” estimates of Hg emission-rates, and a screening-level air dispersion model
(SCREEN3)—and were reported at a (theoretical) location only 20 m away from
the exhaust stack of the (theoretical) crematory. Moreover, the “level the State of
California has identified as having no acute adverse health effects”—600 ng Hg/m3
of air (OEHHA 2008)—is likely based on a misinterpretation of the mechanisms by
which 1 h/d exposures to pregnant rats of mg/m3-level concentrations of Hg vapor
are toxic to their offspring (Danielsson et al. 1993).
Needless to say, discussing the technical details of issues such as these in public
meetings is difficult at best, and made more difficult still by genuine fears and
distrust. In the case at hand, the project’s developer met with neighbors, agreed
to limit operations in various ways, to plant large numbers of evergreen trees and
address other aesthetic concerns, and to otherwise partner with the neighbors to
mutual benefit. When all was said and done, by a vote of 4 to 3, the special use
permit was granted by the city council.

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Profile for Mercury. US Department of Health and Human Services, Public Health Service,
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