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

Closes 24 Nov 2024

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3.2.3.1. Ensiling of dead fish or fish offal, including or storage of ensiled liquor at the same location below 10m³

Activity description

The ensiling of dead fish or fish offal including the storage of the ensiled liquor at the same location below 10m³.

Standard conditions

Below is the list of core and activity-specific standard conditions for ensiling or storage of ensiled dead fish or fish offal below 10m3.

  1. The transfer of fish to the fish ensiling tank and the transfer of ensiled fish to tanker truck(s) or storage tank(s) must be totally enclosed.
     
  2. The pH of ensiled fish must be 4 or lower.
     
  3. Spillage equipment must be available for immediate use.
     
  4. The base and walls of any container, and the pipes and pipe connections of any system used to store ensiled fish and ensiling solutions must be:

    a. impermeable and protected against corrosion; and

    b. capable of withstanding the loads on them when the storage system is full.
     
  5. Any storage system must be maintained in such a condition that no ensiled fish or ensiling solution escapes from the system.
     
  6. Measures must be taken to prevent, or where that is not practicable, minimise:

    a. odour; and

    b. the presence of vermin

    from the authorised activities.
     
  7. Offensive odours from the authorised activities as perceived by a SEPA officer must not be emitted beyond the boundary of the Authorised Place.
     
  8. 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.
     
  9. All measures that are reasonably practicable must be taken to stop an event and to minimise its effect on the environment.
     
  10. 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.
     
  11. 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 upon request.

Interpretation of terms

Interpretation of terms
Term Definition
Ensiling The processing of dead fish and fish offal by maceration and preservation in formic acid. 
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.
SEPA officer Any person who is authorised in writing by SEPA under section 108 of the Environment Act 1995.

Rationale

The main emissions from the fish ensiling process are odour and the potential for ensiled fish or ensiling solutions to escape. The conditions are less onerous than for fish ensiling where above 10m3 of ensiled liquor is being stored. They contain some basic process controls and require that the storage system is suitable for use and well maintained. There is also a requirement to minimise the presence of vermin which could be an issue given the nature of the process.

 

83. Do you agree with the list of standard conditions for the ensiling of dead fish or fish offal, including the storage of ensiled liquor at the same location below 10m³?