The Forgotten Marsh Part 3

a presentation by

Guive Mirfendereski

24 Carleton Street, Newton, Massachusetts 02458

Phone: (617) 964-5252 . Email: Guive@aol.com

December 2008

What’s coming?

PRODUCT

- 80,000+ sq. ft. of artificial turf

- 10 lbs of material/sq. ft. of carpet

- 400 tons of material to be disposed at replacement time

- 100 tons of crumb rubber – usually form shredded used tires, derived from 20,000-22,000 tires

- Impervious surface

- Heat island

- Unmitigated carbon footprint.

William Crain and Junfeng Zhang, “Hazardous Chemicals in Synthetic Turf,” in Rachel’s Democracy & Health News, No. 871

September 7, 2006

• Six polycyclic aromatic hydrocarbons (PAHs) above the concentration levels that the New York State Department of Environmental Conservation (DEC) considered sufficiently hazardous to public health to require their removal from contaminated soil sites.

• Levels of zinc exceeded DEC's tolerable levels. Lead and arsenic also were present. Many scientists believe that these metals should not be introduced into the environment at all.

Crumb Rubber

Environment & Human Health, Inc., North Haven,

Connecticut/Connecticut Agricultural Experiment Station

August 2007

More than two dozen chemicals, including Benzothiazole,

Butylated hydroxyanisole, N-hexadecane, and 4-(toctyl)

Phenol come with crumb rubber.

• Benzothiazole: Skin and eye irritation, harmful if swallowed. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.

• Butylated hydroxyanisole: Recognized carcinogen, suspected endocrine toxicant, gastrointestinal toxicant, immunotoxicant (adverse effects on the immune system), neurotoxicant (adverse effects on the nervous system), skin and sense-organ toxicant. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.

• N-hexadecane: severe irritant based on human and animal studies. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.

• 4-(t-octyl) phenol: corrosive and destructive to mucous membranes. There is no available data on cancer, mutagenic toxicity, teratogenic toxicity, or developmental toxicity.

Health endpoints of concern are numerous, including acute irritation of the lungs, skin and eyes, chronic irritation of the lung, skin and eyes. Knowledge is somewhat limited about the effects of semi-volatile chemicals on the kidney, endocrine system, nervous system, cardiovascular system, immune system, developmental effects and the potential to induce cancers.

Lead

• 100 ppm maximum allowable in toys per an Act of the U.S. Congress (February 2009)

• 40 ppm – upper limit of “allowable” exposure by children per American Academy of Pediatricians

• Lead levels far exceeding these amounts have been found in “new generation” of turf fields, particularly in the multi-sport boundary fibers.

Consumer Reports

New legislation will essentially eliminate lead in all children's products,require safety testing of toys before they hit the market, and give theConsumer Product Safety Commission more muscle and a biggerbudget. All good. But that doesn't mean we're in the clear …. And thenthere are those artificial-turf playing fields. Various government agencies are at odds over whether the levels of lead found in some ofthem should worry us. CU thinks it should, and we've asked the appropriate agencies to assess all risks and not ignore research thatraises concerns.

Jim Guest, “Safe Enough? No.” Consumer Reports, January 2009.Online: Consumerreports.org, December 1, 2008.

Impervious Surface

• “Impervious surface” is defined as any areas that are paved, covered, compacted, or limit infiltration of stormwater. This includes buildings, roofs, decks, patios, and paved, gravel, or crushed stone driveways, parking areas, and walkways.

“[T]hose areas that prevent or impede the infiltration of stormwater into the soil as it entered in natural conditions prior to development. Impervious areas include, but are not limited to, rooftops, sidewalks, walkways, patio areas, driveways, parking lots, storage areas, compacted gravel surfaces, awnings and other fabric or plastic coverings, and other surfaces that prevent or impede the natural infiltration of stormwater runoff which existed prior to development.”

Lewiston, Maine ordinance

Carbon Footprint

The tree planting offset requirements to achieve a 10-year carbon neutral synthetic turf installation at one American football field (exclusive of end zones and sidelined) id estimated to be 930.5 conifer trees.

Estimating the Required Global Warming Offsets to Achieve a Carbon Neutral Synthetic Field Turf System Installation, by Jamie Meil and Lindita Bush, Athena Institute, Toronto, Canada, 2006.

For a two-field 9,000 square-meter artificial turf facility a 10-year period, the research showed a total carbon dioxide emission of 55.6 tons in turf’s life cycle from raw material acquisition through manufacturing, transportation, use and maintenance, and end-of-life disposal of the turf field.

Per U.S. Department of Energy estimate (1998), a medium growth coniferous tree, planted in an urban setting and allowed to grow for 10 years, sequesters 23.2 lbs of carbon, equivalent to 0.039 metric ton of carbon dioxide.

The tree planting offset requirements to achieve a 10-year carbon neutral synthetic turf installation was estimated to be 1861 trees.

Heat Island Effect

[Artificial turf] surfaces are among the hottest possible for urban areas, rivaling dark roofs and fresh asphalt. Measuring at 140 to 160 degrees Fahrenheit, they create heat islands.

Stuart Gaffin, Center for Climate Systems Research, Columbia University, as quoted in Connie Paige, “Turf wars heat up,” The Boston Globe, March 25, 2007

UrbanHeatIslands.com - Camilo Pérez Arrau

Jeanne-Mance Park, Montreal, Canada

Field is 46°C [114.8 F] on June 27, 2005 (10:32am)

Closer to home …

At 11 a.m. on an August [2007] morning, for example, the fake grass at Veterans Memorial Field in Waltham measured 126 degrees. Hotter than a patch of natural grass. Hotter than a nearby strip of concrete, too.

reported by Megan Woolhouse, “The Grass-roots uprising,” The Boston Globe, September 13, 2007.

The Sciacca Heat Study (Summer 2007)

CONSEQUENCES

Pollution

Loss of Groundwater

Microclimate

Effect on Flora & Fauna

Pollution & Loss of Groundwater

“In regard to the turf itself the heat island effect of urban development is a legitimate concern and recognized phenomenon deserving of attention. I was not previously aware of the degree to which synthetic turf contributed to the heat island effect.”

“The impervious nature of artificial turf is also something of concern to EOEA. We presently discourage impervious surfaces in the form of roads, parking lots, and buildings and it would be a shame to have impervious surfaces in parks as well.”

• Kurt Gaertner, Dir. of Sustainable Development, Exec. of of Environmental Affairs, Feb. 2007

Migration: As turf fiber wears and breaks down overtime and crumb rubber migrate off the field by the forces of nature and man.

Leaching & Off-gassing (CAES – August 2007): Out-gassing and leaching from synthetic turf rubber crumb under aqueous ambient temperatures: Several compounds were present, but four compounds gave the highest responses on GC/Mass spectrographic analysis. These chemicals were released in laboratory conditions that closely approximate ambient conditions.

The Ecology & Wildlife

Memorandum from the Open Space Committee of the Newton Conservators and the Newton Local Audubon Program (L.A.P.)

Ruth Rabinow [1977]

• The planned construction of playing fields at Newton South High School may damage one of Newton’s most unique natural areas.

• From wheeler Road, on the westerly side of the oak Hill School, a dirt path runs north bordered by aspens and willows, surrounded by fields and ending in a small pond flagged with cattails. This ten acre patch of ground is a unique sanctuary for specialized plants, geological formation, animal life and over seventy species of birds. It is all that remains of what was originally Great South Meadow which disappeared with the building of homes and schools in the neighborhood.

• [T]he area provides a rare combination of open field, shrubby cover, wetlands, and fresh shallow water which is used extensively by migrating birds and resident wildlife although it lies within a highly developed section of Newton. An ever-increasing number of nature lovers find nesting species such as snipe, sparrows, red-winged blackbirds and pheasant. Even killdeer nest on the land adjacent to the bog.

Brewster W. Fuller, EngineerWhitman & Howard, Inc.

October 18, 1977

• According to an inventory made by persons unknown to me, but listing plants, animals and birds observed in the wetlands area, I find listed thereon ninety-one (91) plant species; seventy-one (71) bird species and six (6) animals included in the natural ecosystem of the wetlands.

• The impact on the birds and animals in particular, who as habitants of the wetland are adjusted to their environment, could be seriously affected by the proposed project. The affect on the plant families in the wetland might not be quite so overwhelming; however, an increase of pollution in the wetlands which could result from careless refuse disposal might alter the ecosystem enough to adversely affect the plant life.

The 1977 Whitman & Howard report indicated 91 plant species in WR #16 area. The recent Conservators’ survey (Summer 2008) listed only 38 botanical species. That is more than 50% reduction in the species of plant life in this area.

There is no updated comprehensive inventory of wildlife for WR #16.

The 1977 Conservators’ survey lists Grasshopper sparrow and

Warblers present in WR #16. Some warblers and grasshopper sparrow are endangered species.

We simply do not know what else we have The Forgotten Marsh. We need to find out before all is lost.

Flora & Fauna

NEWTON CONSERVATORS

An unfinished inventory

(Summer 2008 – present)

IT’S THE WILD WEST!

“The state has no long-term study of artificial turf planned and there is no regulation of the fields, other than to ensure that runoff doesn't end up in protected land.”

Ed Colletta, spokesman, Mass. DEP, as reported by Megan Woolhouse, “The Grass-roots uprising,” The Boston Globe, September 13, 2007

• “[Artificial turf] materials would be regulated as solid waste at the end of their useful life and would be acceptable for disposal at permitted landfills or municipal combustors.”

• “Turf field materials are similar to many other waste materials being disposed, such as carpeting.”

James C. Colman, Asst Comm.,

Bureau of Waste Prevention,

Mass. DEP – Feb 2008

The Wayland Model

In connection with Wayland High School, in October 2006, an “independent” laboratory test was performed as to the quality of the leachate that is created after stormwater percolates through the infilled system. Two methods were used. In one, the lab tested the leachate by sampling drainage outflows of several artificial turf fields in Massachusetts. In the second method, the lab used Synthetic Precipitation Leaching Procedure (EPA Method 1312) to extract leachate from crumb rubber and test the fluid for total solids (metal), volatile organic compounds (VOCs) and PAHs.[1]

[1] Leachate Analysis Report (Gale JN 71 2050), Wayland High School Athletic Facility Submitted to Wayland Conservation Commission, October 31, 2006

Limitations of the test

• 1. The correct protocol to use in searching for components of tires would be EPA

• 525.2 (Organic Compounds by Liquid Solid Extraction), not EPA Method 524.2 that was used by the lab.

• 2. The SPLP test for metals showed the presence of antimony, copper, arsenic, chromium and lead. One of the most ubiquitous metals to be found in tires – zinc – especially problematic with tire leachates, was absent from the test results, except in the case of one field, which also tested positive for thalium!

3. Copper and zinc are known to be especially toxic to organisms in aquatic environments and accumulate.

4. Chromium is known to be a human carcinogen and even in small quantities will have a detrimental effect on drinking water supplies.

5. Thallium is especially toxic to the human skin and if ingested. It is a know carcinogen, and its presence in the leachate even in detectable amounts is of special concern.

6. Emerging contaminants of concern: Some of the most harmful leachates from tire rubber are a family of endocrine disrupters such as octylpenol, bisphenol A, and nitrosomines. These are not tested for in the crumb rubber leachate.

7. Apparently, the test did not look for inorganic chloride levels.

8. Seasonal variations require that the runoff of tire-crumb be tested on a cold October day as well as on a hot August day, as different results would obtain in the different temperatures.

9. There is considerably more leaching of chemicals from crumb when they are newly exposed to the environment and the resultant degradation. This is especially found to be the case in the first three months in the environment. The test did not differentiate the results on the basis of the age of the crumb rubber. It would be most helpful to have test results from a new installation, especially during the first three months.

10. The fields that have been in place for years are suitable for tests that determine the level of metals of concern -- especially zinc, copper, lead, chromium (and thallium) in the sedimentation near the outfalls.

Department of Environmental Protection (Superseding Order of Conditions)

An alternative design relocating the outfall pipe out of the zone of the well field;

Infiltration trench design, including two test pits;

Operation and management plan to address a potential threat to the public water supply: a redesigned stormwater management system with an outfall pipe and vegetated swale located outside of the 100-foot buffer zone associated with bordering vegetated wetland.

Inadequate safeguards

Town’s measures in response to DEP’s Superseding order was not enough to effectively reduce significant soluble nutrients such as phosphorus and toxic contaminants found in tire rubber leachate

Inadequately safeguard as to discharges on wetland and riparian organisms. Insufficient information to determine the impact on the wetland resource with its environmental sensitivity, and presence of rare species mapped habitat. Unacceptable to have any runoff from the project affect refuge lands.

Failure to address adequately the effects of toxic leachate from the tire crumb infill discharging into the bordering wetlands and areas of high aquatic sensitivity.

Toxicity of tire leachate to wetland and aquatic organisms has been well documented in the past ten years. Many leachate of tire rubber include polycyclic aromatic hydrocarbons (PAH’s) such as benzapyrene which is persistent, bioaccumulates and is carcinogenic. Phthalates are esters used in tires as solvents and softeners. Since they are not chemically bound they can leach from the tires and disrupt reproductive health of organisms. Alkyl phenols are added to tires as anti-oxidants to slow tire disintegration and are very persistent in the environment and bioaccumulate in organisms. And the toxicity of zinc and other metals leaching from crumb tire is well documented with some studies indicating concentrations even in excess of drinking water standards.

Final Order of Conditions: DEP Docket No. 2007-085, File No. 322-661

The municipality in consultation of citizens’ group shall hire and pay for an independent consultant to develop a testing protocol and conduct testing of the leachate from the field for contaminants associated with leachate from synthetic turf and tires which is likely to have adverse effects on drinking water or wetland resources in the municipality.

If the leachate from the field is having or is likely to have adverse effects on wetlands resources in the municipality, then the municipality shall take such steps to remediate and/or prevent any such effects in a reasonable and timely manner.

The municipality in consultation of citizens’ group shall hire and pay for an independent consultant hydro-geologist with low impact and sustainable development experience to determine whether the swale and its related components must be modified in scale, scope, and/or efficacy of contaminant removal to prevent potential adverse effects on wetland resources.

The municipality shall endeavor to use commercially available and reasonable non-toxic products in cleaning, disinfecting, maintaining, and repairing the field, and shall notify an officer or director of the municipal board of health of the application of such products.

The presiding officer of DEP’s Office of Administrative Appeals and Dispute Resolution, or his designee, will preside over any material disputes that the parties cannot reasonably resolve through good faith efforts among themselves.

CONCLUSION

First, Do No Harm!

Precautionary Principle

When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof. The process of applying the Precautionary Principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action.