A Letter to the City Council from a local scientist

August 14, 2018
Dear Petaluma City Council members,
I am writing you in regards to the Proposed 16-bay Safeway fueling station on Petaluma’s east side.  I am a toxicologist with the State of California and I have reviewed the relevant scientific literature on the Health Impacts of Gasoline and Fuel Emissions in children.  Much of it is fairly recent, so you may not be up to date on the most current scientific findings regarding adverse health impacts and proximity to gas stations.
The US Environmental Protection agency (USEPA) classifies gas stations as point sources for benzene, a potent volatile carcinogen that is linked to cancer in children.  Living next to a gas station (within 328 feet) quadruples the risk of acute leukemia in children and increases the risk of developing acute non-lymphoblastic childhood leukemia by 7 times, compared with children who don’t live near a gas station (Steffen et al., 2004).  (Cancer is a leading cause of childhood mortality in the US, and leukemia is the most frequent malignant disease effecting children).  Because benzene is a carcinogen, the World Health Organization (WHO) has determined that there is no safe level of exposure.

Studies show that living within 100 yards (300 feet) of a gas station damages your health and that a 100 yard distance, at a minimum, should apply to vulnerable facilities such as schools (Morales et al., 2010).  Children with higher exposures to toxins such as benzene and vehicle exhaust are more likely to require academic support services later in childhood, and to adversely impact their educational trajectories (Stingone et al., 2017).  The USEPA publishes School Siting Guidelines that recommend careful evaluation for any potential school location within 1,000 feet of a LARGE gas station (defined as dispensing more than 3.6 millions gallons/year).   The proposed Safeway gas station, with 16 bays, will dispense well in excess of 12 million gallons fuel/year - and there is a preschool, a children’s playing field, and numerous residences within 160 feet, and an elementary school within 300 feet of this fueling station!  These are unsafe distances.
There is a large body of scientific literature on the health impacts of gasoline and fuel emissions, particularly in children.  Attached is a summary of some of the scientific findings for your review. Cancer, neurotoxicity, respiratory and other inflammatory effects are some of the health endpoints of concern.  Even at low levels, airborne concentrations of benzene have been shown to result in oxidative damage to nucleic acids in children 5-11 years of age (Andreoli et al., 2015).  (Oxidative damage is implicated in many chronic diseases.). 
Simply put, I don’t think Petaluma can manage the liability this has the potential to create in terms of the risk of adverse health outcomes – given the scientific weight of evidence.  Moreover, I am concerned about your proceeding with this decision when neither the City Council nor Safeway have properly evaluated the health risks of this fueling station. Whatever revenues may be realized from this commercial enterprise would be offset by likely lawsuits regarding children’s, teacher’s and resident’s health.  Fueling stations, especially mega fuel stations, should not be located in areas where vulnerable populations and activities (e.g., schools, child-care centers) would be impacted.  Interestingly, Petaluma’s general plan already forbids new drive-throughs, in an effort to reduce greenhouse gas emissions from idling vehicles, and a 16-bay gas station would do just that: significantly increase greenhouse gas emissions.  
In 2018, as Petaluma continues to grow and land becomes increasingly expensive, it doesn’t make economic sense to keep building gas stations, let alone mega-sized gas stations.  In many cities, a gas station falls far down on the list of the best things to do with a piece of land. It would be far more preferable to build housing above with stores below than to put in a conventional gas station which - given the cheap price of natural gas and the drive to move towards natural gas-based fuels and electric cars - is on the wane.  Moreover, no need for additional gas stations to meet the needs of Petaluma citizens has been shown. Thus, the building of this gas station is without merit, and poses a gravely unacceptable risk to our community’s most vulnerable citizens: young children.
Thank you for your time and attention to this critical matter.  
Sincerely,
Moira Sullivan, M.S.

Health Impacts of Gasoline and Vehicle Emissions on Children
Toxicity summary prepared by Moira Sullivan, M.S., Toxicologist

With fueling stations, comes traffic. Lots of it.  From the refueling trucks, to the numerous idling cars. Residents living, working, and playing in close proximity to gas stations have a greater risk of developing serious health effects, including cancer.  There is a considerable volume of peer-reviewed, scientific literature on the adverse health effects of traffic pollution on infant and children’s health. Some of the studies showing adverse effects specifically relate to children’s proximity to gas stations.  

Liquid, aerosol, and gaseous components in fuel and fuel exhaust (e.g., volatile compounds, particulate matter, and nanoparticles) are examples of hazardous air contaminants found in and around fueling stations.  Benzene, a volatile organic compound (VOC), is a carcinogen found in gasoline and automobile exhaust. Areas in close proximity to gas stations contain a different ratio of contaminants from those found in urban air, due to vapor emissions from unburned gasoline (aliphatic and aromatic hydrocarbon pollutants) from fuel loading and unloading operations, refueling and liquid spillages.  A study by Johns Hopkins School of Public Health reports that even small spills at gas stations – “droplets of fuel” - cumulatively cause long-term environmental damage to soil and groundwater in residential areas close to the stations, resulting in significant public health risks (Hilpert and Breysse, 2014). Large filling stations can dispense as much as 1 million gallons fuel/month (12 million gallons/year).

The proven causal relationship between benzene and cancer is well documented and accepted by the scientific community – and gas stations are classified by the US Environmental Protection Agency (USEPA) as a point source for benzene.  A number of studies have linked residential proximity to gas stations to an increased risk of adverse health outcomes (Brender et al., 2011). 
Proximity to gas stations is a risk for cancer (Talbott et al., 2011), and, specifically, leukemia in children (Brosselin et al., 2009; Infante, 2017; Steffen et al., 2004; Steinmaus and Smith, 2017).  Living next to a gas station quadruples the risk of acute leukemia in children and increases the risk of developing acute non-lymphoblastic childhood leukemia by 7 times, compared with children who don’t live near a gas station (Steffen et al., 2004).  Thusly, gas stations should not be located in areas where housing or vulnerable populations and activities – such as those in schools, hospitals, or community centers – would be impacted.  

Studies show that living within 100 yards of a gas station damages your health, and that a 100 yard distance, at a minimum, should apply to vulnerable facilities such as schools (Morales et al., 2010).  A link between childhood leukemia and residence within 100 meters (328 feet) of a gas station has been reported by one group of researchers (Steffen et al., 2004). Distances between gas stations and schools depend on the number of gas pumps, the amount of fuel drawn from them, and the traffic intensity that, in the case of a 16-bay gas station, is considerable. The USEPA publishes School Siting Guidelines that recommend careful evaluation for any potential school location within 1,000 feet of a LARGE gas station (defined as dispensing more than 3.6 millions gallons/year).   I don’t think Petaluma can manage the liability this would create in terms of adverse health problems.

Finally – as Petaluma continues to grow and land becomes exceedingly expensive, it doesn’t make economic sense to keep building gas stations, let alone mega-sized gas stations.  In many cities, a gas station falls far down on the list of the best things to do with a piece of land. It would be far preferable/desirable to build housing above with stores below than to put in a gas station which - given the cheap price of natural gas and the drive to move towards natural gas-based fuels and electric cars - is on the wane.

Studies in Humans

Overall, babies and children are at greater risk than adults from exposure to environmental toxins/insults because their cells are rapidly dividing, and because they have higher rates of respiration. In one modeling study that assessed the impact of inhalation exposure to benzene in adults, pregnant women, toddlers, and neonates - neonates were always the most sensitive subpopulation (Valcke and Krishnan, 2011). Body burdens of benzene have been found in greater amounts in children than adults (Choi et al., 2017; Jain, 2015).  In one study of 65 elementary school children, levels of the VOCs benzene and toluene were detected above the “limits of quantification of the samplers” in 90% of the children; the median concentration of benzene was 10.9 mcg/m3 (Araki et al., 2012).  Because benzene is a carcinogen, the World Health Organization (WHO) has determined that no safe level of benzene exposure can be recommended.  An airborne benzene concentration level of 17 mcg/m3 is associated with a lifetime cancer risk of 10 -4, or 1 in 10,000 (WHO).  That’s dangerously low (1 in 10,000 individuals).  Crosignani et al. (2004) showed significantly increased risks for childhood leukemia with benzene concentrations higher than 10 mcg/m3. (This study just looked at cancer as an endpoint, but no amount of exposure to a carcinogen is a good thing).   
Several studies that looked at VOC levels (including benzene) in education environments for young children found that indoor and outdoor levels of benzene were higher than the European Union standard of 5 mcg/m3 (Norback et al., 2017).  In CA, a number of VOC levels, including benzene, exceeded age-adjusted “safe-harbor levels” based on California’s Proposition 65 guidelines of educational facilities (Hoang et al., 2017).  The authors of the CA study – the Berkeley School of Public Health, Lawrence Berkeley National Laboratory, and the California Air Resources Board - state that, “mitigation strategies are warranted to reduce exposures”.  

Evaluation of VOC concentrations in indoor and outdoor microenvironments at 4 elementary schools in Texas showed that VOC levels (benzene, ethylbenzene, toluene, and xylene) were higher in schools situated near areas of high traffic density (Raysoni et al., 2017). Other studies have reported similar findings, and that the source of polycyclic aromatic hydrocarbons (PAHs) in primary school environments originates from infiltration of ambient air indoors, and that vehicular traffic is the predominant source of indoor PAHs (Oliveira et al., 2017).  The study found that the total cancer risk of children 8-10 years old exceeded (by up to 22 fold) the USEPA and WHO recommended guidelines for PAHs. Because of such findings in numerous scientific studies, exposure of susceptible populations (e.g., infants, children, pregnant women) to ambient VOCs should be considered when planning public service facilities, such as fueling stations (Wang et al., 2016).  

Cancer Risk

Children
Cancer is a leading cause of childhood mortality in the U.S.  And leukemia is the most frequent malignant disease affecting children.  A number of scientific studies have found that environmental exposure to gasoline and automobile exhaust are associated with significant elevations in the risk of childhood cancers (leukemia and central nervous system tumors) (Janitz et al., 2017; Raaschou-Nielsen et al., 2018).  Childhood leukemia has been significantly associated with living near gasoline stations (Brosselin et al., 2009; Steffen et al., 2004). Moreover, a significant exposure-response relationship exists between the likelihood of childhood leukemia and the number of gasoline stations per square mile (Weng et al., 2009).  
A meta-analysis of outdoor pollution and risk of childhood leukemia reported a link between ambient exposure to traffic pollution and childhood leukemia risk, particularly due to benzene (Filippini et al., 2015).  Even at ambient levels, exposure to benzene was found to increase the risk for childhood cancer (Raaschou-Nielsen et al., 2018).  One meta-analysis that compared a number of studies on childhood cancer and early-life exposure to benzene found evidence of associations between childhood leukemia and exposure to benzene (Carlos-Wallace et al., 2016).  A study that examined brain cancer risks in children with early life exposure to ambient air toxics, found that prenatal exposure to PAHs generated by industrial and road traffic sources (including benzene) was associated with brain and central nervous system tumors in young children (von Ehrenstein et al., 2016).  Studies that have looked at susceptible populations – like school children - with exposure to PAHs, have found that “city” school children (compared to children in rural areas) have significantly higher levels of PAH-DNA adducts, 8-OHdG (biomarker for indicating the presence of DNA damage), and DNA strand breaks, and significantly lower levels of DNA repair capacity.  Further, that the levels of benzene and PAH exposure correlate significantly with 8-OHdG levels, DNA strand breaks, and DNA repair capacity in schoolchildren (Ruchirawat et al., 2010).

Adults
Another study that evaluated leukemia in a community in Pennsylvania following exposure to gasoline vapors from a fuel spill found an association between chronic, low-level benzene exposure and increased risk of leukemia (Patel et al., 2004; Talbott et al., 2011).  The overall evidence (from looking at 43 case –control worker studies that evaluated exposure to benzene and adverse health outcomes), supports an association between benzene exposure and non-Hodgkin lymphoma (Smith et al., 2007). Even at low benzene exposure levels (levels >100 times lower than the Occupational Safety and Health Administration), blood levels of MtDNAcn, a biological oxidative response to mitochondrial DNA damage and dysfunction, were increased (Carugno et al., 2012).  Benzene is an established leukomogen (promotes development of leukemia). 
Neurotoxicity in Children
There is a growing body of literature showing associations between prenatal and early-life exposures to air pollution, and children’s neurodevelopment.  Children with higher exposures to PAHs, such as benzene, toluene, ethylbenzene and xylene (BTEX) were more likely to require academic support services later in childhood, and to adversely impact their educational trajectories (Stingone et al., 2017).  In one study that looked at neurobehavioral performance in 606 adolescents, an inverse association was found between sustained attention and traffic exposure; benzene was used as a biomarker of exposure (Kicinski et al., 2015). A study that looked at 438 mother-child pairs found that prenatal residential exposure to PM2.5 (particulate matter 2.5 microns in diameter) resulted in impaired cognitive and psychomotor developments in infants in their second year of life (Lertxundi et al., 2015).
Inflammatory Effects
Significantly higher serum IgG antibodies to benzene and other air pollutants were found in children from high pollution areas compared to those with low air pollution exposures; the children showed an early brain imbalance in oxidative stress, inflammation, innate and adaptive immune response –associated genes, and blood-brain barrier breakdown (Calderon-Garciduenas et al., 2015).  Exposure of children and other susceptible groups to vehicle exhaust induces mechanisms of pathogenesis in heart and lung tissue (cardiopulmonary pathologies), and contributes to long-term diseases such as asthma, allergies, and cancer (Manzetti and Andersen, 2016). In a study that looked at intrauterine and early postnatal exposure to outdoor air pollution, higher exposures to benzene were associated with reduced lung function in preschoolers (Morales et al., 2015).  Significant changes in airway response were seen in the respiratory tract of 51 children exposed to increasing air pollution levels (Martins et al., 2012). Increasing exposure to benzene, toluene, ethylbenzene, nitrogen oxides, and PM10 was significantly associated with a decrease in forced expiratory volume in 1 second (FEV1), and with an increase of change in FEV1. Increasing benzene levels were also related to a significant decrease in forced vital capacity, and with acidity of pH in exhaled breadth condensate (EBC).  An evaluation of long-term exposure to close-proximity air pollution and health effects in 6,683 children aged 9-11 years attending 108 schools showed that asthma, eczema, and sensitization to pollens was significantly associated with benzene, as well as other vehicular contaminants (PM10, sulfur oxides, nitrogen oxides, and carbon monoxide) (Penard-Morand et al., 2010). VOCs such as benzene, found in gasoline, are a risk factor for Otis media in children (Kim et al., 2017); and indeed, from studies in gas station attendants, it is known that gasoline causes alteration in the central hearing system (Ototoxicity) (Quevedo et al., 2012).  Even at low levels, airborne concentrations of benzene have been shown to result in oxidative damage to nucleic acids in children 5-11 years of age (Andreoli et al., 2015).  (Oxidative stress plays a critical role in the development and perpetuation of inflammation).  Oxidation and inflammation are implicated in many chronic diseases.

Studies in Animals
Numerous studies have reported associations between benzene exposure and development of lymphomas in mice (Smith et al., 2007). Studies in animals have shown that short-term exposure (i.e., 2 hours) to particulate matter from gasoline engines exhaust upregulates genes related to PAH metabolism and inflammation in the lungs of mice (Maikawa et al., 2018).  

References
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Brosselin P et al. (2009). Occup Environ Med. 66(9):598-606.  Acute childhood leukaemia and residence next to petrol stations and automotive repair garages: the ESCALE study (SFCE).

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