Steve Greason

It's great to see HB1614 getting started. I'm an environmental scientist and expert in this field and have assisted other States and Canada with bans and regulations concerning this topic. The proposed 10,000 ppm PAH limit is too high and definition needs improvement as other sealcoating products exist which are just as toxic. Since it's so new, it's important that New Hampshire gets it right.    I would strongly recommend you amend and change the bill title and definition to: "Restricting the sale and use of coal tar and other high-PAH pavement sealcoating products used on driveways, parking lots or playgrounds." "A high PAH pavement product means any material that contains more than 0.1% (1,000 ppm) polycyclic aromatic hydrocarbons (PAH) by weight and may contain coal tar, coal tar pitch, refined tar, steam-cracked petroleum residues, heavy pyrolysis oil, steam-cracked asphalt, pyrolysis fuel oil, heavy fuel oil, ethylene tar, ethylene cracked residue, or a variation of those substances assigned the Chemical Abstracts Service (CAS) numbers 65996-92-1, 65996-93-2, 65996-89-6, 8007-45-2, 64742-90-1, or 69013-21-4, used on asphalt or concrete surfaces." "PAHs include U.S EPA's list of 16 priority pollutant compounds, plus 2-Methylnaphthalene, which all have specific toxicity limits and are commonly referred to as the sum or total of 17 compounds added together. PAHs are analyzed by certified laboratories using U.S. EPA Method 8270 by GC/MS instrumentation." There will be no economic impacts to businesses serving this market. There are no coal tar plants in New Hampshire (or New England), so no loss of jobs. Coal tar sealcoating products come from Ohio - mostly - or from the Southern US, where it's used in the steel industry. NH does have sealcoating contractors, and they buy their products from Sealmaster, Neyra, Gemseal, STAR and a few other vendors, which comes here by truck or train. Over the last few years, all these manufacturers have developed high performance asphalt-based sealcoat products - which have no PAHs - to meet the demand and regulations in New York, Maine and elsewhere where their coal tar products have been banned. NH sealcoating contractors can easily switch to using cleaner asphalt-based sealcoats, which cost the same as coal tar products, so there is no impact to their profits. In addition, all the 'bucket' brands sold at Home Depot, Lowes, Walmart or local hardware stores only sell asphalt-based sealcoats, so again there is no economic impact. Lastly, sealcoating is not applied to roads or highways, so asphalt and paving companies in New Hampshire will not be affected by this ban. Coal tar-based sealcoats contain high concentrations of PAHs ranging from 50,000 ppm to over 100,000 ppm, which are highly toxic to human health and the environment. If a parking lot smells like creosote on a warm summer day, it's coal tar. My bio is below. Steve Greason is an environment scientist and business owner at Sitelab Corporation (site-lab.com) located in West Newbury, MA, with over 25 years' experience testing petroleum hydrocarbons. Steve grew up in Bow, NH, has a BS degree from UNH in Durham, owns a summer home up in Dalton, NH and has family in Holderness on Little Squam Lake. He is a strong advocate for protecting and restoring the Merrimack River in New Hampshire and Massachusetts, which can only benefit from this ban. In 2022, Sitelab completed an $85,000 grant with U.S. EPA and Chesapeake Bay Trust to create a national certification program testing the PAH content in pavement sealcoating products. Since then, Sitelab has performed work or provided assistance with regulatory agencies in Austin, TX, Charlotte, NC, Washington DC, New York State, USGS, the Canadian government and over a dozen sealcoat manufacturers. See this link for more info: https://www.site-lab.com/pahs-coal-tar-sealcoats-certification.htm