The following is the testimony that Deanna Doohaluk, MPH of the Conservation Foundation gave in support of the ban of coal tar sealers in Illinois. When it comes to summarizing the watershed/taxpayer nexus with clarity, she threw nothing but strikes! It is included here with the permission of the Conservation Foundation.
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PAHs are a large group of organic compounds found naturally in coal and petroleum products. They
are formed by the incomplete combustion of organic matter from fossil fuels, wood, and cigarettes. As there are many sources of PAHs in the environment such as motor oil, automobile exhaust, and asphalt, it is not uncommon to find these chemical in our stream sediments. What was shocking was the level of PAHs we found. Twenty-seven of these sites had 1 or more PAHs above the “Probable Effects Concentration”. The probable effect concentration (PEC) is the level which adverse effects to aquatic life are expected to frequently occur. All sites had one or more PAHs above the above the “Threshold Effect Concentration” (TEC). The TEC is the level which adverse effects to aquatic life are likely to occur. The PECs and TECs were determine from a review of dozens of individual studies that then utilized a consensus-based approach to set the limits. I just want to reiterate, we did not set out looking for PAHs but due to the levels observed, we could not ignore them.
PAHs have documented effects on aquatic life. Fish exposed to high levels of PAHs exhibit chronic effects including fin erosion, liver abnormalities, tumors and immune system impairments. Benthic macroinvertbrates (or the insects found in streams that serve as the base of the aquatic food chain) that are exposed to PAHs exhibit reproduction impairments and mortality. Amphibians such as frogs and salamanders have also exhibited negative effects including stunted growth and delayed development. PAHs in sediments are one of the primary stressors on aquatic organisms in the urban streams of DuPage County.
Considering this, we started looking for potential sources for elevated PAHs in urban stream sediments. A literature review lead us to the research the United States Geological Survey (USGS) conducted in 40 US lakes. This study linked coal tar sealants to elevated PAH levels in stream sediment in urban areas. Since that the publication of that study in 2010, numerous other studies from Illinois, Michigan, Minnesota, New Hampshire, Texas, Washington, Washington DC, Wisconsin and Utah have confirmed the link between coal tar sealants and elevated PAH levels in the sediment of urban areas. In fact, a recent study found that 77% of PAH pollution in Milwaukee streambeds came from coal tar-based sealants.
There may be a spectrum of concerns among those in attendance here today on the negative effects that PAHs have on fish and insects but that is only part of the story. The State of Illinois has laws in place that require the fish and insects in our streams to meet certain threshold criteria to be considered “healthy”. If the streams fail to meet these thresholds, it is up to the local governments and holders of the National Pollutant Discharge Elimination System (NPDES) permits issued by the State of Illinois to improve the quality of the waterways until these thresholds are meet. In our waterways, it would cost hundreds of millions of dollars to build the infrastructure needed to capture the PAHs in our storm water runoff at the source prior to them entering our waterways. This is on top of the hundreds of the millions of dollars already being spent annually to meet these water quality goals. The most cost effective way to control PAHs in our waterways would be to ban the use of sealant products with high-PAH levels and utilize a substitute product such as acrylic or asphalt based sealants.
The high costs associated with the removal of high PAH sediments from the environment have already been documented. Due to high PAH levels, soils dredged from storm water management facilities such as detention basins and roadside swales need to be disposed as hazardous and/or special waste to comply with State of Illinois regulations. The disposal cost for hazardous and special
We do not need to make this more complicated that it is. We cover driveways, parking lots and playgrounds with these high PAHs sealants knowing that the PAHs will erode and enter our streams and sediments. We do this knowing there are alternative products such as acrylic and asphalt based sealants that have a comparative cost and life span. A ban on coal tar and other high PAH sealants makes sense not just for the environment but also for the taxpayers of Illinois.
The Conservation Foundation/DuPage River Salt Creek Workgroup
10S404 Knock Knolls Road
Naperville, Illinois 60565
Testimony of The Conservation Foundation/DuPage River Salt Creek Workgroup
IN SUPPORT OF HB2958-HCA 1, EPA-COAL TAR BAN
Before the House Consumer Protection Committee
March 14, 2017