The Chemical Risk Management Report

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Summary and Conclusions

REPORT from Roger L. Wabeke, President, Chemical Risk Management, Eight Windham Lane, Dearborn, Michigan 48120-1108

September 10, 2005

To: John A. Gasior, Esq., Law Director, City of Avon, Stringer, Stringer & Gasior, 36815 Detroit Road, Avon, Ohio 44011

Re: Avon school bus staging area proposal

Dear Mr. Gasior:

Thank you for retaining me through Chemical Risk Management to review the proposed school bus garage, school bus staging and storage area, and related issues. The purpose of my retention was to consider the risks and benefits of the proposals and to recommend the most prudent course of action.

Five primary issues were taken into consideration:

  • Health preservation of those exposed to diesel engine exhaust emissions.

  • Safety of pedestrians from increased traffic density from busses on or about the existing school property.

  • Project proposal economics.

  • Appearance and esthetics of the proposed bus maintainance garage, bus staging area, and bus storage during periods of inactivity.

  • Engineering proposals.

    I met with you; Mr. Daniel P. Stringer of your firm; Mrs. JoAnne Easterday, Avon Council at Large; Mr. Jim Piazza, Planning Cooridnator; and the cheif mechanic for the city's school busses (whose name I apologetically do not recall) on August 24, 2005. I inspected the proposed site, the adjacent school, the adjacent farmland, nursing home, and the present school bus storage area and service facilities.

    I critically reviewed and carefully studied the following documents and records provided by your office:

    1. Your August 24, 2005 document transmittal letter to me along with the dispositions of Ms. Mary Angela Marsiglia, President of Avon's School Board; Mr. Jim Reltenbach, School Superintendent; Mr. Dale Smitek, Avon School Board member; and Mr. Kent Zerman, Avon School Treasurer.

    2. May 20, 2005 report to Mr. Hans J. Liebig re: Avon Local Schools Bus Garage from Micheal DiMaio & Associates.

    3. Mr. Gerald Gentz's comments at 6-13-05 Regular Meeting.

    4. June 28, 2003 fax from Mr. Ken Miller to Mr. Bill Bonazza re: Comments on Bus Garage.

    5. A list of 38 school busses (number, year manufactured, manufacturer, model). Two of these have been sold. Five (13%) have exhaust gas recirculation control devices.

    6. General Development Plans for Saint Mary of the Woods nursing home including diagrams, elevations, plot plans, footprints, etc.

    7. 34 architectural and site plot plans for proposed Avon Local Schools Bus Garage.

    8. Various related documents regarding the proposal.

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    In summary, after careful consideration of

  • the above records and documents;

  • the meteorological conditions for Avon, Ohio;

  • the inhalation health hazards of diesel exhaust emissions;

  • the proximity of the school to the bus staging area and the garage;

  • the young ages of students;

  • and increased vehicular traffic density associated with the proposal,

    I do not support this proposal.

    Of the five areas considered (as mentioned above), a risk management evaluation was done considering all.

    The health and safety of the students and others prevails over every other consideration.

    I recommend the proposed garage be constructed at the existing bus storage area and that busses continue to be stored and maintained at this area which is somewhat remote from a highly populated area such as the school and the nursing home. The following points support my position:

    1. Up to 20 to 40 school busses can be idling at any one time. This will produce clouds of engine exhaust emissions during idling, acceleration, cruising, and deceleration.

    2. These emissions will consist of -- particulate matter (diesel soot), -- sulfur oxides, -- oxides of nitrogen, -- lead, -- carbon monoxide, -- and volatile organic compunds (hydrocarbons and unburned diesel fuel and partial fuel conbustion products). All six are priority air pollutants regulated by the Environmental Protection Agency and State Agencies.

    3. The United States Department of Health and Human Services, National Toxicology Program regards diesel exhaust particulates as "reasonably anticipated to be a human carcinogen." Please see attachment 10th Report on Carcinogens, 2002.

    4. It is not, in my view, prudent to place so many sources of suspect carcinogens near a highly populated area of youngsters early in their lives with a higher probability of respiratory-pulmonary cancer induction because of their youth.

    This risk is considerably greater for children than, say, for elderly residents of the nursing home because the cancer induction latency period can be 10 to 40 years later.

    [NOTE TO PARENTS: Save this Chemical Risk Management report for any of your children who may attend Heritage North after the bus garage is built and busses are stored along the west side of the school. The City of Avon and the Avon Board of Education will be liable for treatment costs and compensation for pain, suffering, and loss of income because of any disease which may be reasonably attributed to your child's exposure at Heritage North as much as 40 years before the detection of the disease. (The potential liability for Avon taxpayers is in the millions.)

    More optimistically, some citizens may pay to have Heritage North inspected for tiny (2.5 microns or less) particles of diesel pollution after several years of build-up, and then have Heritage North shut down until it is decontaminated and the sources of contamination permanently removed. Heritage North could become the most expensive bus parking lot in northern Ohio.]

    Elderly people will not normally live long enough to develop a diesel exhaust emission-induced malignancy. Moreover, the nursing home is more remote from the busses than the school so that the exhaust emissions concentrations are diluted with increasing distance.

    5. A major contaminant of diesel engines is sulfur dioxide (SO2) and, with time, conversion into sulfur trioxide, sulfurous acid, and sulfuric acid aerosols.

    Nationally, various degrees of asthma afflict over six percent of our population. The incidence rate is increasing for reasons not clearly understood at this time. Moreover, the rate of increase is greater in children than in adults.

    Sulfur dioxide is a major cause of asthma, and this gas exacerbates asthmatic responses in those who are diagnosed with asthma. SO2 is a potent bronchoconstrictor to the point of fatalities.

    6. Although low-sulfur diesel fuel helps reduce this public health issue, it may be many years before diesel engine combustion technology eliminates this public health risk.

    7. One cannot rely on the wind to reliably and regularly dilute diesel engine exhaust emissions to "safe" levels or even to EPA regulatory limits. Wind varies in velocity, direction, temperature, and mixing effectiveness based on the surrounding topography and buildings. Avon, being near Lake Erie, is subject to the so-called "land breezes" and "sea breezes" depending upon the season and the time of day.

    8. I considered designing a local exhaust ventilation system for the idling busses. The costs for design, construction, permitting, operating, and maintaining such a system would be prohibitive.

    Such a system would include manifolding the exhaust of, say, no more than eight busses to an exhaust fan located in a small building. As many as five manifolds and fans are erquired along with air pollution control devices, a stack permit (if Avon requires such), and a stack designed high enough to ensure that downwash of the exhaust air will not intrude into breathing zones of people before substantial dilution

    Such a stack would be very high and require a discharge velocity of no less than 4000 feet per minute and a weather cap that prevents exhaust downwash onto the school property and building makeup air inlets. The height of such a stack might be an eyesore to some. This area of Avon is not an industrial community. [The busses parked at Heritage North will certainly be an eyesore.]

    9. Of all types of internal combustion engines, diesels are the nosiest - horsepower vs. horsepower output. Numerous idling busses will produce noise annoying to some. The planting of Arbor vitae on the berm between the busses and the farm will be fairly effective to attenuate the higher frequencies of noise that, by themselves, travel only relatively short distances in air as contrasted to the lower frequencies of diesels that, with their throbbing sounds, travel greater distances.

    It is reasonable to assume that, in time, disruptive noise complaints from neighbors will, most likely, be voiced. [Busses stored at Heritage North School will be a major nuisance to students and residents.]

    10. I am not an arborist or horticulturist, but I question whether the Arbor vitae will thrive on top of the berm without very frequent watering. It appears the hydraulic gradient of the artificial berm will cause rapid soil desiccation and tree death within a year.

    11. Using the school area as the bus staging area will increase traffic density. Some parents drop their children off at school. With busses coming and going frequently at two or more nodes within the school day, this introduces a pedestrian safety factor that is somewhat relieved with the present storage area for busses. Said another way, for example, the departing busses now leave from a remote site - not from the school. Detroit Street might require more traffic signals if the proposal is adopted.

    Regardless of Avon's decisions regarding my recommendations, the following steps are recommended as a general set of public health and industrial hygiene precautions:

    1. Reduce bus engine idling times to as low as possible. With all factors considered, reducing the idling time from 15 minutes to five is a 67% reduction of air pollution emissions during this phase of engine operation.

    2. Purchase the lowest sulfur fuels commercially available.

    3. Remove "smokey" busses from service immediately for repair and engine tuning.

    4. Boost the preventative maintainance program for all school bus engines. Make it a regular PM program instead of a "repair as needed." My interview of the supervisor of the garage revealed this ["repair as needed"] is the procedure ...

    5. Improved catalytic converters for diesels are slowly developing. Install these as they appear on the market.

    6. Ensure that the service garage meets the minimum ventilation requirements of the American Society of Heating, Refrigerating, and Air-Condition Engineers and the recommendations of American Conference of Governmental Industrial Hygienists (attached).

    7. For those busses that can be so equipped, install exhaust gas recirculation devices.

    8. If busses are air-conditioned, ensure that windows remain closed so that exhaust emissions that might swirl around the bus do not enter passenger compartment.

    Please do not hesitate to call if there are any questions or if I may be of further assistance.

    Sincerely, Roger L. Wabeke, President

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