Environmental Authorisations (Scotland) Regulations 2018: ​Proposed Standard Conditions for Registration level activities

Closes 24 Nov 2024

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3.2.4. Road vehicle resprayers

This activity applies to sites where road vehicles are being resprayed with various solvent-containing coatings. The respraying may be as part of a vehicle repair, conservation or for decorative purposes.

Activity description

The repainting or respraying road vehicles or parts of them where the organic solvent use is 2 tonnes or more in any 12-month period.

Standard conditions

Below is the list of core and activity-specific standard conditions for road vehicle respraying.

  1. Dusty processes must be contained to minimise emissions.
     
  2. Sanding and grinding must be carried out:

    a. with local ventilation; or

    b. air extraction-fitted equipment;

    which is vented to suitable, fully functional arrestment plant.
     
  3. All potentially odorous waste materials must be stored in suitable closed containers.
     
  4. Containers used for the storage of liquids containing solvents must be kept closed and lidded and stored within a bund / secondary containment system that must:

    a. hold at least:

       i. for a single container, 110% of its total capacity; or
       ii. for two or more containers the greater of:

          1. 110% of the capacity of the largest container, or
          2. 25% of the capacity of all containers together.

    b. catch all spills from the container(s) and related parts;

    c. be leak-proof;

    d. be located and/or protected, to prevent damage as far as reasonably practicable;

    e. be stored away from sources of heat and bright light; and

    f. have any spills and/or rainwater removed as soon as reasonably practicable.
     
  5. All spray coating must be carried out in a fully enclosed booth which is:

    a. under negative pressure; and

    b. equipped with air extraction;

    which is vented to suitable, fully functional arrestment plant.
     
  6. All cleaning, testing and spray-out of spray guns must be within an enclosed machine or chamber which is:

    a. designed to minimise fugitive emissions; and

    b. fitted with local ventilation or extraction equipment.
     
  7. Coatings used for the authorised activity must not exceed the volatile organic compound (VOC) limit for the product type and coating in Table 1.
Table 1: VOC limits
  Product Type Coating VOC g/l *
a Preparatory and cleaning Preparatory 850
b Preparatory and cleaning Pre-clean 200
c Bodyfiller / stopper All types 250
d Primer Surface / filler and general (metal) primer 540
e Primer Wash primer 780
f Topcoat All types 420
g Special finishes All types 840

(*) g/l of ready for use product. Except for (a), the water content of the product ready for use should be discounted.

  1. Coatings containing isocyanate must not be used.
     
  2. Emissions to air from the authorised activities must only be made from the vehicle respraying process stack(s) and abrasive blasting process stack(s).
     
  3. Any vehicle respraying or abrasive blasting emission point stack height(s) must be:

    a. greater than or equal to 3 metres above the roof ridge height of the building on which it is located; or

    b.     greater than or equal to 3 metres above the ground if it is located separate to any building; and

    c. greater than or equal to the height of any part of a building which is located within a distance of 5 times the uncorrected stack height.
     
  4. Emissions of substance(s) to air from the vehicle respraying process stack(s) and abrasive blasting process stack(s) must not exceed the applicable emission limit value specified in Table 2.
     
  5. Air must not be added to dilute emissions in order to achieve the emission limit values specified in Table 2.
     
  6. The emission of any other substance, not specified in Table 2, from the authorised activities must not cause environmental harm.
     
Table 2: Emission limit values from vehicle respraying and abrasive blasting
Substance Emission Limit Value (mg/m3) Emission Source
Dust 10 Spray Booth
Dust 50 Abrasive blasting equipment and any other sources (except spray booths)
  1. Monitoring must be undertaken at the vehicle respraying process stack(s) and abrasive blasting process stack(s) at the sample port, frequency and using the monitoring standard as specified in Table 3.
     
  2. Sample points must be installed, maintained and appropriately identified so that representative samples may be safely obtained.
     
  3. Monitoring must be undertaken during normal operation and under stable conditions.
     
  4. The first monitoring of emissions must be undertaken within four months of the start of operations.
Table 3: Monitoring requirements
Substance Sample port Monitoring frequency Monitoring standard
Dust Sample port determined in accordance with BS EN 15259 Guarantee from the manufacturer 

OR

At commissioning and annually		 BS EN 13284-1
Dust Sample port determined in accordance with BS EN 15259 Annual

as 15-minute mean for contained sources		 BS EN 13284-1

  1. All releases to the air from the authorised activities, other than condensed water vapour, during normal operation must be free from visible emissions.

  2. Measures must be taken to prevent, or where that is not practicable, minimise:

    a. dust;

    b. odour; and

    c. heat emissions

    from the authorised activities.

  3. Dust from the authorised activities, which has a significant impact on the environment, people or property, must not be emitted beyond the boundary of the Authorised Place.

  4. Offensive odours from the authorised activities as perceived by a SEPA officer must not be emitted beyond the boundary of the Authorised Place.

  5. SEPA must be notified via its pollution hotline contact telephone number as soon as reasonably practicable, and in any case within 24 hours of identification of an event, of any of the following:

    a. an event that has caused or could cause adverse impact to the environment or harm to human health;

    b. an event that results, or could result, in an emission to the environment that is not authorised; and

    c. an event that has caused a breach of a condition of this authorisation.

    In this condition, the meaning of ‘event’ is as defined in the Interpretation of Terms of this authorisation.
     

  6. All measures that are reasonably practicable must be taken to stop an event and to minimise its effect on the environment.
     

  7. Within 14 days of an event a report must be submitted to SEPA detailing:

    a. the reason(s) for the event;

    b. the action(s) taken to stop the event and minimise the impacts; and

    c. the action(s) taken to prevent the event from reoccurring.
     

  8. All information recorded, kept or submitted to SEPA in accordance with a condition of this authorisation must be:

    a. true and accurate;

    b. kept for a minimum of six years; and

    c. provided to SEPA on request.
     

  9. Records must be kept of all monitoring results and verification of compliance with the emission limit values specified in Table 2.

  10. The results of the monitoring of emissions, as described in condition 14, must be submitted to SEPA within eight weeks of the date the monitoring took place via email to registry@sepa.org.uk.

Interpretation of terms

Interpretation of terms
Term Definition
Dust  Suspended solid particles and liquid droplets suspended in air which may be deposited on surfaces and may cause air pollution and/or nuisance. 
Emission Limit Value

The mass, expressed in terms of specific parameters, concentration or level of an emission, which may not be exceeded during one or more periods of time.

All emission limit values are defined at:

  1. temperature of 273.1K;
     
  2. a pressure of 101.3kPa;

without correction for water vapour content.
Environmental harm
  1. Harm to the health of human beings or living organisms,
     
  2. Harm to the quality of the environment, including:
     
    1. harm to the quality of the environment taken as a whole,
       
    2. harm to the quality of air, water or land, and
       
    3. other impairment of, or interference with, ecosystems,
  3. Offence to the senses of human beings,
     
  4. Damage to property, or
     
  5. Impairment of, or any interference with, amenities or other legitimate uses of the environment.
Event
  • Any accident which has caused or could cause environmental harm; or
     
  • Any malfunction, breakdown or failure of plant, infrastructure or techniques which has caused or could cause environmental harm; or
     
  • Force majeure or action taken to save human life or limb.
Fugitive emission Any emission released to the environment in the course of the activity other than through a single identifiable source.
Normal operation Operation of authorised activities excluding start-up and shut-down periods.
SEPA officer Any person who is authorised in writing by SEPA under section 108 of the Environment Act 1995.
Uncorrected stack height The stack height before any required increases in height are made to account for any nearby buildings. 

Rationale

The standard conditions contain controls on fugitive solvent emissions - specifically around storage requirements and odour control. There are also standard conditions to manage dust emissions and dust monitoring is required if a manufacturer’s guarantee for the spray booth is not in place. If you already have a permit for this activity, you will notice that the standard conditions proposed here are broadly similar, except for:

(a) The stack height requirement, which has been added to reflect SEPA’s air emission risk assessment.

(b) The requirement to minimise heat emissions, which ties into one of the general aims of EASR – namely to use resources in a sustainable way. Further information on what is expected from operators regarding the control of heat emissions will be contained in supporting guidance.

 

85. Do you agree with the list of standard conditions for the repainting or respraying road vehicles or parts of them where the organic solvent use is 2 tonnes or more in any 12-month period?