FOR IMMEDIATE
RELEASE
CONTACT: Sierra Club:
Arthur Feinstein: (415) 680-0643
Michelle Myers:
(415) 646-6930
Sierra
Club Sues City to Stop Beach Chalet Soccer Fields Project
SAN FRANCISCO -- The Sierra Club has joined a lawsuit
charging the City of San Francisco with failing to comply with the California
Environmental Quality Act (CEQA) in its proposed Beach Chalet Soccer Fields
project. The complaint alleges that the City:
.
Is potentially putting children at risk
when they play on the suspect artificial turf;
. Abdicates significant control over the quality and safety of
artificial turf to a private association;
.
Failed to even consider a feasible alternative site outside
of Golden Gate Park and a design using a safe, non-toxic artificial turf.
The Sierra Club has joined SF Coalition for Children’s
Outdoor Play, Education and the Environment
and other co-plaintiffs, who initially filed a Petition and Complaint against
the City on October 12, 2012. City Fields Foundation, a private non-profit
association that is funding part of the Project and who says it has spearheaded
the Beach Chalet project for the past six years, has intervened as a party in
the lawsuit on the City’s behalf.
The lawsuit asks the court
to order the City to immediately
stop the Beach Chalet Soccer Fields Project until a legally adequate
Environmental Impact Report (EIR) is prepared and adopted by the City.
Michelle Myers, Chapter Director of the San Francisco
Bay
Chapter of the Sierra Club, says, “The City should be protecting the health of
its residents. Without giving any reason, it decided not to analyze the
potential dangers of using an artificial turf that has been identified as toxic
in several peer-reviewed scientific articles [see references at the end of this
release], and it exceeds the CEQA threshold for acute toxicity and cancer risk by 120% -- as the EIR admits.
The City has refused to
analyze an alternate site that could provide the same quantity and quality of
soccer experience using a non-toxic artificial turf. The City instead decided
to desecrate the natural character of the west end of Golden Gate Park with:
·
stadium lighting on ten 60-foot-tall light
poles, broadcasting 150,000 watts of light, 365 days a year, until 10 p.m.;
·
the installation of stadium seating for 1,000
spectators
·
while paving and expanding the existing parking
lot by 30%.
Arthur Feinstein, Chairperson of the Sierra Club Bay
Chapter
said, “This is why we have an California Environmental Quality Act. It is meant
to ensure that decison-makers actually have all the information they need to
amke informed decisions that do not threaten us or our environment’s health and
it also let’s us, the public, know on what basis these decisions are made. In this
case, however, the City decided to ignore a CEQA mandated threshhold level of
acute toxicity that should have triggered further investigation and possibly
mitigation for potential impacts to our health. Instead the City simply said,
in our[ wisdom, and without any evidence, we choose to not consider this
important. We believe that when the City gives away much of its ability to
control the type and construction and placement of this artificial turf, the
City is abdicating its responsibility. Here we believe a 2006 agreement between
City Fields Foundation and City shows the City has not exercised its
independent judgment. When we go to a City park we should feel confident that
the City has done all it can to ensure the safety of the park. In this case, the
City has failed to do this by ignoring its CEQA responsibiities.
The
President for Viking Soccer Parents for Grass Fields in Golden Gate Park,
Kathleen McCowin wants to reflect on her concerns as a mother. “When our kids
play on ground tire based fields, we see poor containment of the infill by the
surface plastic turf. These industrial waste particles contain many toxic
chemicals, such as the carcinogens benzene and carbon black, and toxins at
levels fatal to water animals exposed to field run-off. After our kids
play on plastic turf over ground-tire fill, they have these particles all over
them, including their hair, in their ears, and wiping it from their eyes. We
believe San Francisco can do better for its children.”
The Amended Petition and Complaint alleges several
deficiencies in the EIR, including:
1)
The EIR fails to disclose the significant health risks of the toxic chemicals
found in the styrene-butadiene rubber (SBR) tire crumb used in the artificial
turf proposed for the soccer fields and fails to consider safe alternatives to
this material. In the EIR, the City admits that the material has an acute
toxicity index more than double the City’s CEQA significance threshold, yet
decides, without providing any reason, that this is not significant (“the hazard index
was 2.2, sufficiently
close to a hazard index of 1.” -- Final EIR).
2) The City, in a 2006
Memorandum of Understanding with City Fields Foundation, gave up
significant control of the type of artificial turf used:
“The Foundation
will select a contractor or contractors of
its choice to perform all services relating to site preparation and
installation of the Fields. The Foundation will fund all costs associated with
the Foundation contracts or subcontracts for construction management, design
consultation/value engineering, and contractor's work, and with the acquisition
of all materials and supplies necessary for the contractor to perform its work,
including, but not limited to, the Turf.”
###
The
Sierra Club is world’s oldest, largest, and most effective grassroots
environmental-advocacy organization, founded in 1872 with over a million
members nationwide and 27,000 in San Francisco, Contra Costa, Alameda, and
Marin counties. Our mission is to enjoy, explore and protect the planet.
###
Quotations from the Sierra Club's
brief--relating to the dangers of artificial turf, including quotations from a
number of key publications:
- The EIR
relies on a study conducted by the California Environmental Protection
Agency Office of Environmental Health Hazard Assessment (OEHHA) in 2009.
That study concludes that artificial turf fields with SBR crumb rubber
infill create a cancer risk of approximately 18.8 per million – 18 times
above the CEQA significance threshold. The OEHHA Study concludes:
"Estimated
inhalation exposures of soccer players to five of these (benzene, formaldehyde,
naphthalene, nitromethane and styrene) gave theoretical increased lifetime
cancer risks that exceeded the insignificant risk level of 10-6 (OEHHA,
2006)." (p.33)
California
Office of Environmental Health Hazard Assessment (OEHHA) (2009):
Chemical Increased Cancer
Risk
Benzene 2.8/million
Formaldehyde 1.6/million
Naphthalene 3.8/million
Nitromethane 8.7/million
Styrene 1.9/million
CUMULATIVE 18.8/million
- A recent
peer-reviewed journal article study published in 2011 concludes that soccer pitches with SBR infill create a significant
cancer risk above 1 per million due to dioxin-like chemicals.
Menichini, et al., Sci Total Environ. 2011 Nov 1;409(23):4950-7. Epub 2011
Sep 9. The article concludes:
“The artificial-turf
granulates made from recycled rubber
waste are of health concern due to the possible exposure of users to dangerous
substances present in the rubber, and especially to PARs [petroleum
hydrocarbons]. In this work, we determined the contents of PARs, metals,
nondioxin-like PCBs (NDL- PCBs), PCDDs and PCDFs in granulates, and PAR
concentrations in air during the use of the field… an excess lifetime cancer
risk of 1 x10(-6) was calculated for an intense 30-year activity.”
- The
EIR fails to analyze health risks from dioxin-like compounds at all.
- The City
refused to consider the most recent peer-reviewed scientific journal
article on SBR, published in the highly respected journal Chemospere,
entitled “Hazardous Organic Chemicals in Rubber Recycled Tire Playgrounds
and Pavers” (Llompart, M., et. al.) that became available on August 22,
2012. The study investigated the presence of hazardous organic chemicals
in surfaces containing recycled rubber tires. The study was initiated
because of a concern that the application of used tires in recycled
products such as rubber mulch used for sport fields and playground
surfaces places children at risk. The study revealed that the used tires
on sport fields and playground surfaces contain a large number of
hazardous substances including polycyclic aromatic hydrocarbons (PAHs),
phthalates, antioxidants, benzothiazole and derivatives, among other
chemicals. Many of these hazardous substances were at high or extremely
high levels. In addition, vapor studies revealed that many of the organic
compounds are volatile even at room temperature. The study concludes that
because of the “presence of a high number of harmful compounds, frequently
at high or extremely high levels, in these recycled rubber materials…they
should be carefully controlled, and their final use should be restricted
or even prohibited in some cases.”
- Dr. Phillip
Landrigan, MD, epidemiologist and Director of the Mount Sinai School of
Medicine Children's Environmental Health Center in New York, submitted a
letter to the City Planning Department on May 8, 2012, stating:
The major chemical components
of crumb rubber are styrene
and butadiene, the principal ingredients of the synthetic rubber used for tires
in the United States. Styrene is neurotoxic. Butadiene is a proven human
carcinogen. It has been shown to cause leukemia and lymphoma. The crumb rubber
pellets that go into synthetic turf fields also contain lead, cadmium and other
metals. Some of these metals are included in tires during manufacture, and
others picked up by tires as they roll down the nation's streets and highways.
There is a potential for all of these toxins to be inhaled, absorbed through
the skin and even swallowed by children who play on synthetic turf fields. Only
a few studies have been done to evaluate this type of exposure risk, the most
notable by EPA in 2009, NY State DEC in 2009, and CT DEP in 2012.
- Matthew
Hagemann, C.Hg., former director of US EPA’s West Coast Superfund program,
concludes that the Project will have significant cancer and non-cancer
health risks. Mr. Hagemann states:
Toxins from tire crumb can
enter the body through inhalation
of particulates, fibers, and volatile organic compounds (VOCs). VOCs can cause
organ damage, irritation of eyes, throat, and airways, and nervous system
impairments. Synthetic turf can be heated to high temperatures when exposed to
sunlight which, in turn, can lead to further release of VOCs.
The DEIR includes references
to synthetic turf studies that
have shown risks to human health from inhalation of VOCs to exceed a commonly
accepted threshold of one additional cancer incidence in a population of a
million people (“one in a million or 10- 6”). Although this is disclosed in the
DEIR, the DEIR fails to identify this as a significant impact and fails to
mitigate the risk.
One study cited in the DEIR,
a 2009 study prepared by the
California Office of Environmental Health Hazard Assessment (OEHHA), concludes
that soccer players with inhalation exposure to vapors from a theoretical
scenario of playing for 51 years on synthetic turf would have increased
“lifetime cancer risks that exceeded the insignificant risk level of 10-6” from
breathing benzene, formaldehyde, naphthalene, nitromethane and styrene,
chemicals associated with VOC vapors from synthetic turf. The OEHHA finding of
significant health risks was corroborated by a 2011 Italian study in which
showed risk to be in excess of 10-6 from particle-bound polycyclic aromatic
hydrocarbons. Another 2011 study found that benzothiazole, a chemical that
causes respiratory irritation and dermal sensitization, volatilizes from crumb
rubber resulting in inhalation exposure. The latter two studies are not
mentioned in the DEIR.
The individual risks from
benzene, formaldehyde,
naphthalene, nitromethane and styrene each exceed the one in a million
threshold. When summed, the cancer risk from chemicals identified in the OEHHA
study equals 1.9 in 100,000 which exceeds a 10-5 level (or one in a hundred
thousand) risk level (19 in a million).