Environmental Permit Site Reports

Under the Environmental Permit Regulations, contamination and pollution of the environment is the prime concern.

A Site Report is required for every Bespoke Environmental Permit site, and may also be required for Standard Rules Low Impact sites:

• at Permit Application to provide a “baseline” of existing ground and groundwater conditions,
• sometimes during the Permit lifetime, and
• at Permit Surrender.

The purpose of an Environmental Permit Site Report is to provide information on the land and groundwater quality to demonstrate whether there has been significant pollution from the Permitted activities during the permit lifetime.

If there has been significant pollution under Permit, either due to an incident or ongoing leaks, the Site Report should provide information on what that pollution is, and quantify (as far as possible) how much was released and needs to be be cleaned up to return the site to its baseline condition.

In some circumstances, where returning a site to its baseline condition is impractical or the costs are prohibitive or disproportionate to the benefits, it may be possible to negotiate a different set of clean-up conditions.  This would usually be to a state where harm to people and the environment is no longer considered significant, in other words a small amount of pollution may still be left in situ with the agreement of the regulators.

Every Site Report is based on a desktop study, but it usually also contains site walkover information, and an infrastructure survey.

Ground Investigations

If appropriate, intrusive ground investigations may be carried out at Permit Application (or as an early Permit Condition, soon after the site goes into Permit).  Ongoing monitoring works may be carried out during the permit lifetime (e.g. groundwater monitoring, and sometimes soil monitoring).  At Permit Surrender, all of the information gathered previously is consolidated, and if necessary a surrender ground investigation carried out.

In some circumstances, a ground investigation may not be appropriate, and we discuss this in our white paper “Do you need to have an intrusive ground investigation at permit entry”, which is part of the EP Application Toolkit (see details below).

An application or surrender intrusive site report is similar to a Contaminated Land investigation, but the emphasis is on assessing the presence and concentrations of substances stored and used under Permit in the land and groundwater, rather than finding all historic pollutants.

Intrusive ground investigations can be relatively simple where only a few chemicals are handled, and can be analysed for individually in soil and groundwater. On sites with multiple substances being handled under Permit, or sites where the substances are difficult to analyse for, it is possible to agree a reduced set of “marker” substances with the regulators to simplify the work and reduce costs.

The “baseline” levels found in an Application Site Report Ground Investigation form the standard to which the site must be returned on completion of permitted activities at the site, and before the permit can be surrendered.

If elevated levels of contamination are found in comparison to the “baseline”, then remediation is likely to be required.

Remediation may involve further investigation to determine the physical extent and severity of pollution above the baseline, and assess which clean-up techniques are appropriate.  Remediation techniques can include in-situ treatment of soil or groundwater; removal of impacted soil and replacement with clean material; or a programme of monitored natural attenuation.

Remediation

As part of the remediation process, validation and verification sampling and analysis is usually required, to demonstrate that it has been successful.

TT Environmental have experience of undertaking both baseline and surrender site reports, with particular familiarity in the chemical sector.

Ground investigations on chemical sites are often complex and risky, especially on working sites where chemicals are being delivered and processed, and all the utility services are “live”.

Usually, this type of work requires full-time project management and is unlikely to be accommodated into the daily duties of site staff (e.g. HSE managers). We prefer to project manage these investigations ourselves, liaising between the site and contractors ourselves to help the project run as smoothly as possibly.  Our input helps to ensure that the relevant Health and Safety issues are identified and dealt with appropriately, and risks are communicated to all parties.

Over the years, we have developed a short-list of approved experienced sub-contractors in areas such as:

• Drain survey and repair
• Topographic surveying
• Buried services/ utilities mapping and remote sensing
• Laboratory analysis of common and less common industrial chemicals
• Ground investigation works (trial pits, groundwater monitoring wells)
• Remediation or removal of contaminated land and groundwater
• Waste disposal for contaminated materials

We are happy to use our clients’ approved contractors as long as they can provide the quality of work which the project requires, and comply with the necessary safety requirements.

For help with your Environmental Permit Site Report, contact Janet on 01422 24 22 22 to discuss, or email Janet.