Lithos were asked to prepare a Site Condition Report for two sites owned by WJ Timber Group because their Environmental Permits were being upgraded to Industrial Emission Permits.
Site history and characteristics
The Industrial Emissions Directive was enacted in the UK in 2015, and this European Directive requires all ‘installations’ to provide quantitative baseline data to support the IED permit. Whilst establishing baseline data for a new permit is relatively straightforward, the requirement to retrospectively establish baseline conditions for continuing operation of an existing facility, can be far more problematic.
Many industries are located on brownfield land, having occupied the same site over several decades. Establishing accurate baseline data and allocating responsibility to either the current or previous processes is a complex issue. An awareness of European and UK guidance on baseline reports is essential.
What we did
WJ Group have two timber process yards; in Hull and Rochester. The site in Hull was a new purpose-built yard that had previously only been used for caravan storage. By undertaking a detailed Phase I assessment of land use and environmental setting, Lithos determined that soil and water quality could be assessed qualitatively and were reasonably represented by typical background concentrations. Specific chemicals, used within the permitted process were identified as potential indicator compounds for any future monitoring in the event of a spillage etc. This approach was agreed with the Regulatory body, in this instance Hull City Council.
WJ Group’s second site in Rochester is located on a former dockyard and has been used for timber treatment and storage for many years. Historic land use is likely to have given rise to land contamination and this may include timber treatment products. In this instance, it would be inappropriate to consider background conditions as this places a high degree of liability on WJ Group at the point of permit surrender. Instead, Lithos developed a sampling strategy that considered only ‘relevant’ indicator compounds, as defined under the IED guidance. This approach allows some distinction to be made between historic contamination (associated with dockland) and any WJ Group may be responsible for remediating.
WJ Group were able to successfully progress their permit applications with a clear understanding of future liabilities and the additional work required.