Polyaromatic Hydrocarbon (PAH) in Sealants - Stormwater Impact Studies

Collaborative studies by the City of Austin, TX, and the U. S. Geological Survey have identified coal-tar based sealcoat as a major and previously unrecognized source of polycyclic aromatic hydrocarbon (PAH) contamination. Several PAHs are suspected human carcinogens and are toxic to aquatic life.

Studies in Austin, Texas, showed that particles in runoff from coal-tar based sealcoated parking lots have concentrations of PAHs that are about 65 times higher than concentrations in particles washed off parking lots that have not been sealcoated. Biological studies, conducted by the City of Austin in the field and in the laboratory, indicate that PAH levels in sediment contaminated with abraded sealcoat are toxic to aquatic life and are degrading aquatic communities.

This research has led the City of Austin to ban the use of coal-tar sealants for roads, parking lots, driveways, and other paved areas.

Caltha LLP assists private and public sector clients in evaluating potential stormwater pollution sources and developing cost effective stormwater pollution prevention programs to minimize their environmental impacts.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SWPPP Training – Stormwater Training

Caltha LLP offers a wide variety of SWPPP Training courses developed to meet the requirements of individual States. Separate stormwater training programs are provided to Industrial, Municipal (MS4) and Construction stormwater dischargers.

Training is offered in a number of flexible formats, ranging from traditional classroom training presented periodically in different locations, to facility-level training conducted at individual sites to meet employee and/or contractor training needs. Caltha offers web-based and remote training options. Caltha also creates facility-specific training materials and conducts “train-the-trainer” sessions for facility training staff.

Caltha also offers stormwater training options especially designed for small groups or small organizations.

Caltha provides State-specific SWPPP training for the following States:
[Click on a State to request information on upcoming stormwater training programs and training options]

[See a map showing States where Caltha LLP worked in 2008]

Alabama
Arkansas
California
Connecticut
Florida
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Massachusetts
Michigan
Minnesota
Mississippi
Nebraska
Nevada
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
South Carolina
South Dakota
Tennessee
Texas
Utah
Virginia
Washington
Wisconsin

Hazardous Metals in Stormwater – Texas (TCEQ) Requirements

As general permits for stormwater discharges are revised, States will attempt to address requirements for impaired waters into the permit requirements. How these requirements are expressed in the permit varies widely from State-to-State. Some States have developed requirements which promote pollution prevention measures.

As one example, the State of Texas has detected levels of selected heavy metals in surface waters which are of concern, and has promulgated numeric discharge standards for “hazardous metals” into the industrial stormwater permit. However, the Texas Commission on Environmental Quality (TCEQ) approach is to allow facilities to do a self-assessment for sources of hazardous metals and implement pollution prevention measures to avoid the higher costs of hazardous metal sampling and testing. To be exempted, facilities must certify that:

• Facility does not use a raw material, produce an intermediate product, or produce a final product that contains one of the listed hazardous metals, or


• Any raw materials, intermediate products, or final products which contain a hazardous metal are never exposed to stormwater or runoff, or


• Facility collects and analyses stormwater samples from the facility and the results indicate that hazardous metal(s) are not present in detectable levels.
  

Waivers may be obtained on a metal-by-metal basis, or on an outfall-by-outfall basis. A waiver from hazardous metals monitoring does not exempt the facility from other benchmark monitoring requirements which may apply. [Read more about benchmark monitoring]

Caltha LLP provides support to facilities nationwide on meeting State stormwater permit requirements and developing effective stormwater pollution prevention programs, including SWPPP training and stormwater compliance training programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Knowledge Based SWPPP Training – Texas (TCEQ) Construction Permit Example

Stormwater training requirements in most general permits are prescriptive and require specific documentation to demonstrate compliance. If documentation can be produced that shows an employee received appropriate training, the permit requirement is considered to be met. Most often, training rooster sign-in sheets are used as documentation.

An alternate requirement for SWPPP training is “knowledge-based”, meaning that compliance or noncompliance is determined by what the employee knows and not what training courses the employee has attended.

An example of knowledge-based training requirements is found in the Texas Commission on Environmental Quality (TCEQ) general permit for construction stormwater discharge (Permit # TXR150000). In this permit, “training” is only required for personnel responsible to conduct site inspections. No specific training needs to be documented. However, inspectors must be “knowledgeable of [requirements of the] general permit, familiar with the construction site, and knowledgeable of the SWPPP for the site”. Regardless of any specific training inspectors can show, if they can not meet these performance criteria, they may not be considered qualified to conduct inspections.

Although knowledge-based training requirements have the advantage that no specific training documentation is needed, they also require a higher standard for actual knowledge. Employers need to assure that their employees know what they need to know.


Caltha LLP has several training programs created to help Texas contractors meet the performance standards of the TCEQ construction site discharge permit, including several customized programs to meet the requirements of small and medium size contractors in all States.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website