Coal tar was used extensively in roads until the early 1980s in urban and rural locations, therefore any road which was constructed or maintained pre-1980 may contain hazardous levels of coal tar.
What are the hazardous limits?
The Environment Agency advise that AWCCT with
benzo(a)pyrene above 50mg/kg are equivalent of coal tar
at 1000 mg/kg the legal threshold to demonstrate HP7 carcinogenicity.
Will the Client advise whether excavated materials contain tar?
On larger HE and LA sites chemical analysis may have been conducted by taking material cores for tar testing in a laboratory.
Under these circumstances the Client will advise Contractors that the site contains AWCCT.
It is a legal duty on the waste producer to adequately describe these materials.
What would make me suspect the presence of tar in the excavated material?
The initial reason to suspect the presence of tar in material is due to the strong coal tar odour. On closer inspection the material may contain a glossy black tar rather than a matt bitumen.
Is there any technical way of checking on site for the presence of tar?
PAH marker is an indicator for coal tar, which when sprayed will change colour from white to yellow or brown if PAH levels are above 125 mg/kg.
Only chemical analysis in the lab for polyaromatic hydrocarbons can properly determine if the waste is hazardous.
You can apply to the EA on line for an S2 storage exemption which will allow you to store a maximum 500t at that location for no more than 12 months.
Can I blend it with other non-hazardous material to dilute the tar content?
No, this is an offence under the Hazardous Waste (England and Wales) Regulations 2005, Regulation 18.
Apparently some companies are using AWCCT to make concrete – is this ok?
This is only acceptable under a number of Regulatory Position Statements issued by the Environment Agency.
It cannot be used for structural concrete purposes, such as concrete blocks.
Can we make concrete with it and sell it to someone else?
No! AWCCT are a hazardous waste and must be handled in line with current regulations.
Is a Section 3.5, Part B Permit acceptable for my site to receive AWCCT?
Only if the site has an EA S2 Permit which restricts the use of the site to 500 tonnes.
What if I want to store more than 500 tonnes on my site?
A bespoke Environmental Permit will need to be in place for storage above 500t.
Is this easy to obtain?
These can take months to be issued and there is also the cost of the application to be considered.
There are very few landfill sites licensed to receive this material in the UK, transport costs become prohibitive.
Hazardous waste disposal costs are high.
Landfill tax will have to be paid at £88.95 per tonne (from April 2018).
It is a waste of a fully recoverable resource.
What about making a cold recycled material for roads?
This can be done in line with a Regulatory Position Statement issued by the Environment Agency.
What are the inherent problems?
This method is expensive, requires Environmental Permitting, expensive plant, raw materials, labour and finally creates a legacy issue.
What is a legacy issue?
The hazardous waste will always be there for the generations to come.
Is there a better solution?
TARREC’s solution is unbeatable, as it fully recovers hazardous waste in the form of AWCCT producing energy and clean aggregate for re-use.
Is it expensive?
TARREC’s recovery costs are significantly lower than landfill costs. TARREC’s recovery costs are in line with the alternative legacy burdened techniques being used in the UK currently.