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

Closes 24 Nov 2024

3.2.6. Coating roadstone with bitumen

This activity applies to roadstone coating, which is the production of asphalt. Asphalt is commonly used to surface roads, parking areas and paths.

Activity description

The coating of roadstone with bitumen.

Standard conditions

Below is the list of core and activity-specific standard conditions for the coating of roadstone with bitumen.

  1. All reasonable steps must be taken to minimise emissions during start-up and shut-down of the process.
     
  2. Bitumen must be stored and handled within the appropriate temperature range to minimise odour.
     
  3. Dust emissions must be minimised by:

    a. containment of dusty processes; and/or

    b. suppressing dust using water.
     
  4. Potentially dusty materials must be:

    a. stored in storage bays; and

    b. not filled above the external wall height.
     
  5. Recycled asphalt containing coal tar must be:

    a. identified and stored separately from other recycled asphalt; and

    b. removed from site as soon as reasonably practicable.
     
  6. Waste oil (including waste oil referred to as ‘recovered oil’) must not be used as a fuel.
     
  7. All deliveries of filler to silo(s) from tankers must only be made using vehicles fitted with onboard pressure relief valves and filtration equipment.
     
  8. Displaced air, resulting from delivery to silos, must either be:

    a. vented to suitable arrestment plant; or

    b. back vented to the delivery tanker.
     
  9. Silos and bitumen storage containers must have an overfilling alarm.
     
  10. When loading silos, deliveries must automatically stop where overfilling or over-pressurisation is identified.
     
  11. Emissions to air from the authorised activities must only be made from the roadstone coating process stack(s).
     
  12. The roadstone coating process stack height 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.
     
  13. Emissions of substance(s) to the air from the roadstone coating process stack(s) must not exceed the emission limit value specified in Table 1.
     
  14. Air must not be added to dilute emissions in order to achieve the emission limit values specified in Table 1.
     
  15. The emission of any substance, not specified in Table 1, from the authorised activities must not cause environmental harm.
Table 1: Emission limit values from roadstone coating
Substance Emission Limit Value (mg/m3)
Dust 50
  1. Monitoring must be undertaken at the roadstone coating process stack(s) at the sample port, frequency and using the monitoring standard as specified in Table 2.
     
  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. An alarm system must be provided and maintained in order to provide visual and/or audible notification when arrestment plant fails or malfunctions.
     
  5. The first monitoring of emissions must be undertaken within four months of the start of operations.
Table 2: Monitoring requirements
Substance Sample port Monitoring frequency Monitoring standard
Dust Sample port determined in accordance with BS EN 15259 Annual 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. All reasonable steps must be taken to prevent the discharge of water from dust suppression activities which may cause harm to the environment.
     
  6. 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.
     
  7. All measures that are reasonably practicable must be taken to stop an event and to minimise its effect on the environment.
     
  8. 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.
     
  9. All information recorded, kept or submitted to SEPA in accordance with a condition of this authorisation must be:

    a. true and accurate; and

    b. kept for a minimum of six years; and

    c. provided to SEPA upon request.
     
  10. Records must be kept of the following:

    a. all monitoring results and verification of compliance with the emission limit values specified in Table 1.
     
  11. The results of the monitoring of emissions, as described in condition 18, 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
Arrestment equipment Equipment used to mitigate the effects of emissions.
Asphalt A mixture of dark bituminous pitch with sand or gravel, used for surfacing roads. 
Coal tar A thick black liquid produced by distilling bituminous coal, containing benzene, naphthalene, phenols, aniline, and other organic chemicals. Asphalt waste containing coal tar is considered to be hazardous waste where the level of coal tar is >0.1%. Asphalt waste containing coal tar is considered to be hazardous waste where the level of coal tar is >0.1%.
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.
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 mainly focus on emissions of odour and dust. Monitoring of dust is required to ensure emissions are not above the emission limit value. 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.

The use of tar in roadstone coating processes is a concern due to health and safety issues relating to the high concentration of polyaromatic hydrocarbons (PAHs), which may be 10,000 times higher than that of bitumen. We have prohibited its use in the Registration level activity. A Permit is required to carry out this activity.

 

87. Do you agree with the list of standard conditions for the coating of roadstone with bitumen?