WASTE/RECYCLING Russell Corbyn demonstrating that logging, examining and preparing cores is a dirty and long job
to test the arisings. This has several disadvantages: • There is no opportunity to consider whether coal tar containing materials can be left undisturbed.
• The removal process cannot be designed in advance to separate tar and non-coal tar materials. If coal tar is present in some but not all layers, this will result in a larger quantity of ‘suspected’ material containing coal tar being produced.
• Testing will be required after excavation before a decision can be made on how to use the arisings; this could delay the project.
• Under the CDM Regulations, it will be necessary to inform the Contractor that “excavated materials may contain coal tar”. After analysis, an assessment of the results is required. Assessment can include the option for reuse but will certainly classify the material as either hazardous or non-hazardous. The material may still be applicable for reuse depending upon the solution employed. However, the relevant environmental permit and assessment will be required from the EA. Waste Recycling Action Plan (WRAP)
consider that material containing coal tar can be recycled by in situ or ex situ methods assuming there is agreement with the EA and LPA. Further assessment for suitability may be requested depending upon the sensitivity of the site’s end use or its proximity to environmentally sensitive receptors.
WRAP is currently investigating an End of Waste Protocol for AWCCT. The EA have a regulatory position statement regarding AWCCT (EA, 2012): recycling/reuse for use as a construction material should always be considered as the first option; it encourages sustainable development. If it’s decided that the material could be
reprocessed then it can be used as aggregate in a bitumen bound material such as cold mix asphalt, cement bound material or a hydraulically bound material such as a Structural Material for Reinstatement (SMR), assuming that any other specifications for that final
EA Regulatory Position Statement, 2012 http://www.environment-
agency.gov.uk/static/documents/Business/MWRP_RPS_075_v3_Use_of_AWCCT_in_ construction_-_July_2012.pdf Definition of Waste: Development Industry Code of Practice (version 2), 2011, CL:AIRE
European Pathway to Zero Waste, Environment Agency, 2013
http://www.environment-agency.gov.uk/aboutus/wfo/epow/123624.aspx
product are met such as British Standards, Specification for Highways Works. Further to this, where employed in a Hub and Cluster Site scenario, if the material reaches the “End of Waste Criteria”, as defined within the CL:AIRE document “Definition of Waste: Development Industry Code of Practice” (DoWCoP; version 2, CL:AIRE, 2011), by submission of a ‘declaration’ then the material from the producer site is likely to be deemed as suitable for use at a receiver site and, according to the protocol, the material is no longer deemed as waste (assuming all facets of the DoWCoPv2 are adhered to). To conclude, site investigations are essential prior to any work being carried out that may involve the excavation of materials containing coal tar. Assessment of materials will not only classify them but provide a rationale for disposal and reuse, saving money and time as well as preserving environmental health and safety issues within a sustainable framework.
© Kiwa CMT Testing March 2013 For further information contact 01332 383333 or Email
cmtenquiries@kiwa.co.uk
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carbontoes PUBLIC SECTOR SUSTAINABILITY • VOLUME 3 ISSUE 3 17
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