Afternoon all,
You will be probably be interested in the following:
Environment Agency (2014) Regulatory position statement 075 The movement and use of treated asphalt waste containing coal tar (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/419686/LIT_10118.pdf); and
ADEPT (2013) Managing Reclaimed Asphalt – Highways & Pavements (http://www.adeptnet.org.uk/getfile.php?path=cms/files/policies/Managing%20Reclaimed%20Asphalt%20v2013-12.pdf&privatefile=public) - this states that "the Environment Agency considers that if benzo[a]pyrene is present at a concentration of 50 mg/kg or more in the asphalt arisings (excluding any other waste material), the
waste should be classed as hazardous and denoted by the EWC code 17 03 01*".
The CL:AIRE CoP does apply to "ground based infrastructure that is capable of reuse within earthworks projects, e.g. road base, concrete floors" so long as you can demonstrate the four factors via a MMP; and the CoP doesn't specifically exclude tar bound materials as far as I can tell. Though does the Environment Agency's Regulatory Position Statement (i.e. specifically ruling out any uses other than in bound sub-surface layers e.g. sub-base, base and binder layers) trump the CL:AIRE CoP!?
Please note that the Standard Rules Environmental Permit, for use of waste in construction, doesn't allow the reuse of hazardous road planings. Therefore a bespoke permit would typically be required.
A Quality Protocol (QP) for asphalt waste containing coal tar is currently being considered by the European Pathway to Zero Waste Quality Protocols Team. The QP, if published, will define the standards which asphalt waste containing coal tar must achieve (to be considered a non-waste) to encourage its use as recycled aggregate. The EA’s regulatory position statement is therefore an interim position pending the outcome of the quality protocol process and will be withdrawn once a decision is made as to whether it is possible to develop a QP.
P.S I'm glad some of you found the 'A66 Little Burdon to Newton Grange resurfacing' case study useful, that was one of mine ; )
Kind regards,
Dan
Dan Lean BSc (Hons) MIEnvSc
Material Resource Efficiency Consultant
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