Environmental Permitting and Site Condition Assessment
Major industrial, energy, waste and manufacturing sites require an environmental permit to operate under the Environmental Permitting Regulations (EPR) in England and Wales, and the Pollution Prevention and Control (PPC) Regulations in Scotland. Under this system industrial sites, referred to as installations, must hold a permit to operate, which, in turn, specifies the application of best available techniques (BAT) to either eliminate pollution altogether, or to reduce it to harmless levels. All emissions, including to air, water and land, and impacts on adjacent receptors need to be considered.
The environmental permitting regime is very complex and requires detailed knowledge of technical guidance and experience of securing agreement with the regulators. RSK has many years’ experience of providing environmental permitting support to operators across a wide range of industrial sectors and in-depth understanding of relevant legislation and technical guidance. This enables us to assist companies in achieving their permitting requirements, including new permits, variations and surrender applications.
RSK has comprehensive knowledge of the environmental permitting regimes in all parts of the UK. We have a strong track record of successfully assisting companies to achieve their permitting requirements while enhancing their knowledge base and protecting their brand image and reputation. We gain in depth understanding of their activities and demonstrate that they meet the benchmarked requirements of BAT. In so doing, RSK provides a comprehensive service that is consistent with the business objectives of an organisation while demonstrating good environmental governance to key stakeholders.
Through its geosciences team, RSK also advises on site condition aspects for environmental and PPC permitting, and waste management licensing, including in support of new permits, variations, including EU Industrial Emissions Directive (IED) baseline and soil and groundwater monitoring requirements, and surrender applications. We also offer National Quality Mark Scheme (NQMS) accreditation of our reports, which helps to facilitate regulatory approval.
Working since the beginning
RSK’s team have been undertaking environmental permitting and site condition assessments in relation to PPC since it was first introduced in 2000, thereby building on our already strong track record of supporting clients through a wide range of consultancy offerings and services. Since then, we have developed a pragmatic and proactive approach for meeting permitting requirements combined with an excellent reputation and working relationships with environmental regulators. More recently, the IED has brought in additional requirements leading to variations to existing permits. We can also help with complying with the Control of Major Accident Hazards Regulations (COMAH) and provide compliance auditing.
Understanding the potential pitfalls
We know that each client’s priority is to gain regulatory consent for its permit, or to achieve its surrender, as cost-effectively as possible. We also know that there are several potential hurdles a client must consider, such as budget restrictions, lack of regulatory engagement and unforeseen circumstances, such as below-ground contamination. All of these carry the risk of causing unforeseen delays and therefore must be considered and mitigated, whenever possible, as early as is feasible.
Gaining permits and variations
Operators know their facilities better than anyone else, so we tailor our approach to supplement your in-house capability and offer the specialist services that are required to support your application for a permit or variation. We offer as comprehensive a service as is needed, from preparation of a full permit application to provision of specific services, including air quality and noise impact assessments; site condition or baseline assessments; demonstrating the application of BAT; emission impact assessments; and the associated monitoring and testing services.
We are renowned for our pragmatic and proactive approach to meeting permitting requirements, which is combined with an excellent reputation and working relationships with environmental regulators.
RSK provides bespoke waste-management services including waste compliance, hazardous waste classification, closed landfill management and technically competent management of waste facilities.
We also support organisations after they gain their permits as they strive to manage their carbon commitments. For instance, we offer value-adding services relating to carbon footprinting, emissions trading and offsetting. We have delivered projects that meet the Kyoto Protocol’s flexibility mechanisms, joint implementation and the Clean Development Mechanism.
We are certified to ISO 9001, ISO 14001 and BS OHSAS 18001, accredited by CHAS and have members who hold registrations with Constructionline, Link-up and UVDB. We pride ourselves on our effective health and safety management on operational sites.
What happens when a permitted site closes?
Operators have to apply to the regulator to surrender the permit(s) in place when a site closes. The final condition of the site has to been shown to be in “a satisfactory state”, as defined in regulatory guidance. This involves documenting how plants and/or processes that involve potentially polluting substances have been decommissioned safely and without environmental impact. It also requires a detailed assessment to show whether releases to soil and groundwater could have occurred from activities operated under the permit and, typically, an intrusive site investigation to detail the site’s final condition at surrender. Remediation work may be required to address any releases to soil and groundwater that have occurred to achieve a satisfactory state. It can be a costly and time-consuming process to satisfy the regulator that all requirements have been met.
RSK has extensive experience of undertaking site condition assessments to support environmental permit surrender, providing support to decommissioning works such as environmental auditing and collating documentation, as well as preparing full permit-surrender applications.