IPPC Application Site Reports

Regulations

One aspect of the Integrated Pollution Prevention and Control (IPPC) regime, which did not feature under previous directives, is the requirement to submit an Application Site Report (ASR). ASRs must be submitted by applicants of a Part A installation or Part A mobile plant.

What is an Application Site Report?

The principal objective of the ASR is to provide information on the ground conditions of the site to enable the Regulator to set appropriate permit conditions to protect the land. A completed ASR must:

• > Identify the environmental setting and pollution history of the installation
• > Identify any substance in, on or under the land that could have arisen from materials currently
     used or produced by the activities under the Permit (or are likely to be used or produced
     in the future)
• > Identify preventative measures that are in place to protect the land
• > Be sufficient to form the basis of the Operator’s Site Protection and Monitoring Program
     (SPMP)

Desk Based Reviews

This service encompasses desk based research and site reconnaissance on behalf of the client to enable the collation and review of all readily available information concerned with the site for the ASR. This is then used to develop the conceptual model of the site. The main data collection activities under the ASR system are therefore:

• > Desk based research: Internal and external sources
• > Site reconnaissance: To obtain visual and other sensory indicators of the contamination
     on a site and to confirm that initial expectations determined from the desk study are viable
• > Data interpretation: Assessment of whether an intrusive investigation is required to support
     the data collected via the desk study

Identification of Potentially Polluting Substances

The operator needs to identify all the substances at the installation that, if released to land, have the potential to pollute soil and groundwater, whether alone or in combination with other substances already in the land or groundwater. This could be as a result of spills, leaks, failure of tanks or pipelines or deliberate discharges. Substances may include raw materials, fuels, intermediates, products, wastes and effluents. In addition, the Applicant needs to identify substances that are used or produced at the installation that may have already polluted the land although no quantification is required at this stage.

Pollution potential will be determined not only by the volume and manner in which a substance is stored but also the chemical properties of that substance. The operator must therefore consider the toxicity, environmental fate, behaviour and transport characteristics of each substance.

Potentially polluting substances that may already be in the land as a result of past activities or use of the site must also be identified.

Assessment of the Adequacy of Pollution Prevention Measures

For each of the operational activities and associated substances the operator needs to identify and record what pollution prevention measures are in place to protect soil and groundwater.

The objective of this stage is to bring together all of the data collected to enable an assessment to be made on the potential for land pollution from the activities at the installation. For each relevant activity at the installation, the operator will need to assess whether there is:

• > Little likelihood that pollution or leaks to land will occur during the future life of the installation
• > A reasonable possibility that there is potential for current or future pollution of the land
     from the installation

Conceptual Site Models

The information assembled as part of the desktop review is combined to form a Conceptual Site Model (CSM). This is a fundamental objective of the ASR and is required in all cases regardless of whether the applicant has made the case that there is little likelihood of pollution or not.

The CSM is a descriptive representation of the key source areas of contamination, migration pathways and receptors. An assessment of the likelihood of adverse impacts to on-site and off-site receptors is also included.

Reporting and Support

We believe that it is very important for the Regulator to be involved with parts of the ASR activities and to be made aware of the proposals and outcomes of the report.

We therefore recommend that a series of meetings are held with the local inspectors. Adopting a “pro-active” approach will give the inspector an opportunity to become "involved" and to make any comments and adjustments without significantly affecting the programme for the project.