Helen Culshaw, Senior Advisor from the Environment Agency’s Geoscience Operations Team, explains how the team audit permitting applications for the deposit of inert waste that could impact the subsurface environment.
As a regulator, the Environment Agency (EA) audits all environmental permit applications received that have the potential to cause environmental harm to the subsurface environment for sites in England. Our Geoscience Operations Team (GOT) is a specialist team in our Permitting Network responsible for auditing the technical assessments known as Hydrogeological Risk Assessments (HRA). These HRA assess the impact of emissions to land that could give rise to harm to human health or lead to deterioration of the quality of the receiving water environment and need to be provided for most waste deposit applications.
You will usually need a HRA if you are wanting to deposit inert wastes via landfill disposal or via deposit for recovery. Before applying you will first need to have developed and written a Conceptual Site Model (CSM). This is the first element of your application that we review. We screen applications as they arrive to quickly flag flawed or uncertain CSMs, advising applicants to withdraw and improve their submission before resubmitting.
Pre-application and Environment Agency guidance
Applicants for environmental permits should first read our published guidance:
- For inert deposit proposals this will be Landfill operators: environmental permits – Landfills for inert waste,
- For deposit recovery proposals this will be Deposit for recovery operators: environmental permits)
We strongly encourage pre-application engagement from applicants to try to ensure that any issues relating to the permit application are addressed during the development of the application documentation.
Pre-application advice can help you make sure you provide the best evidence, that your assessments are fit for purpose and that the public can understand your proposals. A poor-quality application is likely to require us to ask for additional information and cause delays in the application determination process. Operators who have used the service have said that these discussions have helped give them confidence in making their application and addressed any uncertainties they had in the conceptual site model or proposed development.
The paid for enhanced pre-application service (requested at Get advice before you apply for an environmental permit) can include a review of monitoring or assessment proposals and/or meeting(s) between the us, applicant, and consultant where that is considered helpful. As the Permitting pre-application service has evolved our team has developed a series of internal pre-application discussion notes that reflect activities being proposed at a site which allow us to provide a consistent response to common questions raised by applicants ahead of submission of an application. We provide these notes to applicants through the service to aid your understanding of our determination process and to help you identify and target the specific technical problem you need advice for if this is not initially provided.
As the regulator, we cannot provide instruction on how to design a site, how to undertake assessments, or how to collate data to support the surrender of an application. This advice should be sought from an appropriately qualified consultant with experience of the Environmental Permitting Regulations as they apply to waste deposits.
Further advice on commonly raised questions for Conceptual Site Models and Hydrogeological Risk Assessments
When we pick up an application the first element looked at is the conceptual site model (CSM) proposed. This will underpin a Hydrogeological Risk Assessment (HRA). The CSM describes the site and its environment, both natural and man-made in four dimensions, including time.
Advice on commonly raised questions for preparing water environment Conceptual Site Models is available on the CIWM Knowledge Centre. This article highlights the importance of a robust CSM supported by sufficient site investigation that addresses all the uncertainties at the site or with the proposal. The article includes questions asked in relation to the source, pathway and receptors that make up the CSM, such as “Do I really need a year of monitoring data?” and “My site sits on a non-aquifer or an already contaminated site, so I don’t have any receptors of concern”.
The CIWM Knowledge Centre also houses further information for commonly raised questions on completing the Hydrogeological Risk Assessment that needs to be provided for most waste deposit applications to show that it meets the requirements of the Environmental Permitting (England and Wales) Regulations. The article aims to answer common questions such as “What is a risk assessment and when does it need quantitative modelling?” and “What software tools should be used?”. The article also includes what makes a risk assessment report easier to audit and explains why an overly complicated report or model leads to more questions and a lengthier determination time.
If you have specific technical queries for your application after reading these articles and the published guidance you can request pre-application discussions at Get advice before you apply for an environmental permit.
Who are GOT?
GOT are part of EA Permitting, which is responsible for determining permit applications. GOT staff work alongside both the ground and environmental engineering specialists based in the our National Services Environment and Business team, who provide strategic overview in relation to policy and operation guidance, and the local Area Staff to whom GOT provide support on technical operational issues encountered on the portfolio of waste deposit sites regulated by us in England.
We deliver technical advice and assessment for new permit applications where waste is to be deposited, typically covering applications for inert landfilling, non-hazardous landfilling, the deposit of waste for recovery, to any applications looking to make technical variations to the permits, and finally for the surrender of these permits. We directly support the specialist Waste Deposit Teams who provide a single dedicated function within the Permitting Network for the permitting of Waste Deposit activities. We are a technical team of currently 12 staff with varied backgrounds, such as former consultants, or testing laboratory managers alongside staff with extended careers within the EA. Team members are encouraged to achieve Chartered Status by the time they reach a level of leading on the determination of applications, and the team provides the EA with a centre of excellence on the past, present and foreseeable future risks of regulated waste deposit activities that includes the legacy of sites dating back over the past half century.
