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Do you need a Site Condition Report?

Site Condition Reports (SCRs) are required for any facility regulated by the EA under the Environmental Permitting Regulations where there may be a significant risk to land or groundwater including where one is necessary to satisfy the requirements of the Industrial Emission Directive. This applies to new permit applications, variations and during the transfer or surrender of permits.

The SCR details the condition of land and groundwater at a particular point in time. As such, it enables you to demonstrate that you have protected land and groundwater during the lifetime of the site and that the land is in a satisfactory state when you come to surrender your permit. Therefore, SCRs are completed over the course of the following three stages:

  1. Application – this details the condition of the land and groundwater at the time of application and as such establishes baseline conditions to which the land and groundwater will need to be returned to on surrender of the permit.
  2. Operational phase – this allows you to provide updates on the condition of the land and groundwater throughout the lifespan of the permit.
  3. Surrender – this details the condition of the land and groundwater at the time of surrender of the permit.

A detailed and robust SCR with primary data helps operators limit liabilities by identifying the condition of the ground at the point of permit issue, which is often particularly important as many new waste sites have had historical waste or industrial uses. If primary data is not collected, then the land is assumed to be uncontaminated and at point of permit surrender, the operator will be liable for any historical contamination that is present beneath the site. The Environment Agency must be satisfied that land and groundwater have been left in a satisfactory state at the close of operations in order to accept the permit surrender.

At WRM, we have detailed knowledge and experience of producing Site Condition Reports. All of our SCRs are produced in accordance with the EAs H5 Guidance which covers the requirements of SCRs in the context of the Environmental Permitting Regulations. Our method for producing SCRs include the following:

  1. Site walkover survey.
  2. Review of;
    • historical maps, aerial photographs of the site;
    • the geology and hydrogeology of the land on which the site is located;
    • the wider environmental setting;
    • pollution incidents in the vicinity of the site;
    • nearby industrial activities;
    • any existing data.
  3. Attaining of primary data, where appropriate (see below) following an agreed sampling strategy.
  4. Completion of SCR for submission to the EA.

Step 3, attaining primary data, can sometimes be as simple as taking near surface soil samples with a hand auger. Alternatively, it can involve coring and drilling to significant depths until groundwater is reached. Working on our own or with specialist drilling sub-contractors, WRM can manage this entire process.

For further information about when a Site Condition Report is required or for support in the production of a Site Condition Report, please contact Martin Ropka martin.ropka@wrm-ltd.co.uk or another member of the Permitting team (info@wrm-ltd.co.uk).

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