Guidance On The Protection of Land Under The PPC Regime

Technical Guidance Note
IPPC H7
Integrated Pollution Prevention
and Control (IPPC)
Guidance on the
Protection of Land Under the
PPC Regime:
Application Site Report and
Site Protection and Monitoring
Programme
H7 Guidance - Application Site Report and Site Protection and Monitoring Programme
CONTENTS Page
BACKGROUND
1.0 Introduction 1
1.1 What is an Application Site Report ? 1
1.2 Which Sites Does This Apply To? 1
2.0 How to Use This Guidance 2
3.0 Framework for the Protection of Land under PPC 3
3.1 Application Site Report 3
3.2 Two Months After Permit Issue 6
3.3 Six Months After Permit Issue 7
3.4 Life of the Permit 7
GUIDANCE ON THE PREPARATION OF AN APPLICATION SITE REPORT
4.0 Stage 1 – Preparation of an Application Site Report 8
4.1 Introduction 8
4.2 Step 1 – Site Environmental Setting and Pollution History 9
4.3 Step 2 – Identify Potentially Polluting Substances 11
4.4 Step 3 – Identify Pollution Prevention Measures 12
4.5 Step 4 – Assess the effectiveness of the
Pollution Prevention Measures 16
4.6 Step 5 – Conceptual Site Model 23
4.7 Step 6 – Reporting 26
GUIDANCE ON THE PREPARATION AND IMPLEMENTATION OF A SITE PROTECTION

AND MONITORING PROGRAMME
5.0 Stage 2 – Designing a Site Protection and Monitoring Programme 29
5.1 I ntroduction 29
5.2 Step 1 – Designing an Investigation to Collect Reference Data 30
5.2.1 Introduction
5.2.2 Review Conceptual Site Model
5.2.3 Designing Intrusive Investigations To Collect Reference Data
5.3 Step 2 – Designing the Monitoring Programme 33
5.3.1 Introduction
5.3.2 Designing the Environmental Monitoring Programme
5.3.2.1 Define Objectives
5.3.2.2 Designing the Environmental Monitoring Infrastructure
5.3.2.3 Designing the Environmental Monitoring Schedules and
Protocols
5.3.3 Designing the Infrastructure Monitoring Programme
5.4 Step 3 – Designing an Information and Data Management and
Reporting Programme 37
6.0 Stage 3 – Implement the Site Protection and Monitoring Programme 39
6.1 Introduction
39
6.2 Step 1 – Implementing the First Phase of the Site Protection and
Monitoring Programme SPMP 39
6.3 Step 2 – Implementing the Remaining Part of the Site Protection and
Monitoring Programme 40

References 42
Appendices
Appendix A What are Reference Data ?

Appendix B Action to be taken if Pollution is Identified in the Reference Data
Appendix C Investigating and Remedying Pollution Identified During the Operation
of the Site Protection and Monitoring Program
Appendix D Glossary
Figures
Figure 1 Summary of the Key Stages of the Protection of Land through PPC
Figure 2 Assessing the Likelihood of Pollution
Figure 3 Development and Implementation of the Site Protection and Monitoring
Programme
Tables
Table 1 Information Requirements for Step 1 including Site Reconnaissance

Table 2A Assessment of the Likelihood of Pollution
Table 2B Assessment of the Likelihood of Pollution – Continued
Boxes
Box 1 Example where environmental monitoring would normally be required –

reasonable possibility of pollution of the land
Box 2 Situations where intrusive investigations would be required as part of a
Permit application
Box 3 Zoning of a site
Box 4 What is meant by “likelihood” and “reasonable possibility”
Box 5 Indicative measures to control emissions to land
Box 6 Example of graphical preliminary conceptual site model
Box 7 The objectives of a Site Protection and Monitoring Programme
Box 8 Examples of factors that affect the distribution of a substance in the
land
Box 9 Objectives of monitoring land and groundwater at an installation
Box 10 Reporting requirements where Reference Data is required
BACKGROUND
1. Introduction
This technical guidance supports the Environment and Heritage Service (EHS) policy on the
requirements for site reports in the PPC regime. The policy is designed to improve the overall
level of protection of the land on a PPC site and protect it from degradation.
1.1 What is an Application Site Report?
A site report is required to be submitted as part of a Permit application (Application Site Report
or ASR) to operate a Part A installation under the PPC regime. The principal objective of the
ASR is to provide information on the ground conditions of the site to enable the EHS to set
appropriate conditions to protect the land. These conditions may include a requirement on the
Operator to submit a Site Protection and Monitoring Programme (SPMP). In addition the report
will be essential at Permit surrender in the establishment of restoration requirements.
1.2 Which Sites Does This Apply To?
This approach applies to all sites that fall into the PPC regime including new and existing
installations, with the exception stated below.
This guidance is not applicable to areas of a landfill installation which form the stationary
technical unit for the landfill activity. However, there may be directly associated activities
included in the installation. For all the areas of the landfill installation which do not consist of
permanent deposits of waste forming part of the stationary technical unit, the requirements of
this guidance do apply.
Guidance on the surrender of existing specified waste management activities and for landfill will
be provided by the Waste and Contaminated Land Unit of the EHS in due course.
The Groundwater Directive (80/68/EEC), as implemented by the Groundwater Regulations

1998, must be implemented via the PPC Permit. Thus, where there is or is proposed to be a
deliberate discharge or disposal to land of listed substances, a “prior investigation” is required.
The Directive requires that there is no discharge of List I substances to groundwater and no
pollution of groundwater by List II substances.
1
2.0 How to use this guidance
This guidance has been produced to provide an indication to Applicants of the EHS
requirements for an ASR and, if required, an SPMP. It is not intended to be a substitute for the
use of or advice from suitably qualified and competent professionals or the PPC Regulations
themselves.
The guidance is broken down as follows:
Purpose
Background Provides background information on the

Sections 1.0, 2.0, 3.0 overall objectives and approach to the
requirements of the PPC regime in relation
to the protection of the land.
Guidance on the Preparation of an ASR Detailed guidance on how to prepare an

Section 4.0 ASR as part of a PPC Permit application.
Guidance on the Preparation and Detailed guidance on how to design and

Implementation of a Site Protection and implement an SPMP.
Monitoring Programme
Section 5.0
Where this guidance refers to an “installation” this means both a Part A Installation and also a
Part A Mobile Plant where regulated by the EHS.
To support this guidance reporting templates are available to help Applicants and Operators
with the submission of the correct information in a suitable format to the EHS. The templates
are:
H7 Reporting Template 1 –
Template for an Application Site Report in PPC Applications
Design of a Site Protection and Monitoring Programme for Installations Requiring
Reference Data to be Collected
Design of a Site Protection and Monitoring Programme for Installations that DO NOT
Require Reference Data to be Collected
First Phase Reporting of the Site Protection and Monitoring Programme for Installations
where Reference Data is Required
First Phase Reporting of the Site Protection and Monitoring Programme for Installations
where Reference Data is NOT Required
Direct cross referencing to the applicable sections in the relevant template is provided in each
section of this guidance.
2
3.0 Framework for the Protection of Land
The framework for the protection of land under PPC is illustrated in Figure 1. This demonstrates
the actions required at pre- and post-Permit determination stages and the link to eventual
Permit surrender. All these stages are described in more detail in the following section.
Figure 3 illustrates the key decision points and data collection requirements during the
preparation of the ASR and the SPMP.
Much of the information on substances used and pollution prevention measures at the
installation will be required elsewhere in the PPC Permit application. The Applicant is not
required to repeat any data collection exercise and should cross reference documents provided
in other parts of the application wherever possible.
3.1 Application Site Report (ASR)
The key objectives of the Application Site Report are to collect and collate (normally) desk
based information on the activities and substances used at the installation that could present a
pollution risk to the land now or in the future.
A completed ASR must:
a) Identify the environmental setting and pollution history of the installation.
b) 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).
c) Identify preventative measures that are in place to protect the land.
d) Be sufficient to form the basis of the Operator’s Site Protection and Monitoring
Programme of impact to land to be conducted during the life of the Permit.
The EHS will not normally require intrusive site investigations to be undertaken before it
determines an application provided that a)-d) above are satisfied. However the Applicant must
state within the ASR whether there is either:
• little likelihood that pollution or leaks to land will occur during the future life of the
installation.
or there is:
• a reasonable possibility of current or future pollution of the land from the installation.
The EHS will review the information provided in the ASR and assess whether it agrees with the
assessment of the likelihood of pollution. The EHS will consider the case the Applicant has
made in relation to the installation including:
− the inventories (quantities and types) of substances held on the site;
− the quality, engineering and maintenance of tanks, pipework and other items which could
give rise to pollution and the associated control measures such as bunds;
− the testing, monitoring and maintenance procedures in place; and
− the quality of operator management and competence, including past record of incidents,
non-compliance and enforcement action.
The EHS will use this assessment in deciding whether to apply Permit conditions requiring the
collection of Reference Data as part of the SPMP. Reference Data are defined in detail in
Appendix A but will normally involve the collection and analysis of soil and groundwater
samples and reporting of contaminant concentrations in the land.
3
As noted above intrusive investigations would not normally be required at the application stage.
However, in certain situations it may be the case that the site’s environmental setting cannot be
established adequately and intrusive investigations will be necessary, the results of which
should be reported in the ASR. For example where desk study information is inadequate or of
such poor quality that the site’s condition cannot be described. Further details on this issue are
provided in Box 2.
The Permit will normally have conditions requiring the Operator to implement a SPMP to
ensure the protection of the land throughout the lifetime of the installation this will be
undertaken in the following phases:
Two Months after Permit Issue - SPMP submitted to the EHS
Six Months after Permit Issue - where Reference Data is required the reporting of these
results to the EHS
During the life of the installation - collection and reporting of data in accordance with the
SPMP
The detail and scope of the required SPMP will be based on the assessment of pollution
prevention measures undertaken in the ASR and will be proportionate to the risks posed by the
installation.
If the EHS agrees with the assessment that there is:
• little likelihood that pollution or leaks to land will occur during the future life of the
installation.
The SPMP will only require a testing, inspection and maintenance programme to ensure that
the site’s pollution prevention measures are maintained and continue to be effective.
In exceptional circumstances there may be installations where the possibility of pollution is so

small, even if controls fail, that the requirements to ensure the protection of land will be
achieved through other conditions of the Permit and operating procedures. Therefore
conditions requiring an SPMP will not be applied.
However, where this case has not been made by the Applicant, or the EHS disagrees with the
Applicants assessment, and it is considered that there is:
• a reasonable possibility of current or future pollution of the land from the installation.
then the required SPMP will need to be far broader in its scope and, in addition, must include
the collection of Reference Data and where the potential for ongoing pollution has not been
removed the undertaking of long term environmental monitoring.
An example of the scope of an SPMP where there is a reasonable possibility that there is a
potential for current or future pollution is provided in Box 1.
4
Figure 1 Summary of the Key Stages of the Protection of Land through PPC
APPLICATION • Identify environmental setting

and pollution history
- STAGE 1
• Identify substances that may
lead to the pollution of the land
• Identify Preventative Measures
to protect the land
• Assess effectiveness of
preventative measures
Application Site Report
PERMIT ISSUED
PERMIT
SUBSISTENCE • Design monitoring programme to
ensure pollution prevention
measures are effective
Site Protection & Monitoring

Within 2 months Programme
- STAGE 2
• First phase of monitoring completed

Within 6 months • Reference conditions established
- STAGE 3 where required
• On going site monitoring
PERMIT
SURRENDER
• Assessment of operational records

• Sampling of soil and groundwater
• Has pollution occurred ?
• Determine restoration requirements
3.2 Permit Subsistence - Site Protection and Monitoring Programme (SPMP)
Permit Surrender
Report
5
Box 1
Example where environmental monitoring would normally be required as part of an SPMP.

(reasonable possibility of pollution of the land)
An installation includes a series of activities that produce liquid effluents that are transferred to an on-
site treatment plant (prior to discharge to foul sewer) via a below ground effluent system. The
drainage system consists of brick lined catch pits drained by single-butted clay pipes which in turn
connect to a main brick-lined conduit to the treatment plant. The system is gravity drained.
The installation lies within a river valley and is underlain by 2 to 4 meters of alluvial gravel overlying
low permeability clays. A shallow water table exists within the gravel perched upon the clay.
A CCTV survey is conducted as part of the investigations to collect Reference Data which does not
identify any major breaks in the drainage system. However due to its age and construction its integrity
cannot be assured. Replacing the drainage system along with improved effluent treatment and reuse
within the activities have been identified as improvement conditions. Due to high capital costs and
major disruption to operations this work is to be phased in over a number of years.
The SPMP should include investigations of groundwater quality beneath and down groundwater
gradient of the drainage system to collect Reference Data for those polluting substances in the
effluent. Proposals to monitor groundwater quality during the life of the installation should be included
in the SPMP until such time that the system is replaced and testing and inspection procedures are
developed and implemented to demonstrate its continued integrity.
3.2 Two Months After Permit Issue
Conditions may require that within two months after the Permit has been issued the Operator
must submit to the EHS a design document of the required SPMP.
The purpose of the SPMP is to demonstrate that the pollution prevention measures designed to
protect the land at the site are effective throughout the life of the installation.
If there is a reasonable possibility of pollution, which will be established before the Permit is
determined, then the first stage of the SPMP must establish Reference Data for substances in
use or produced or likely to be in the future at the installation that could be emitted to land or
groundwater.
Intrusive sampling may form part of the SPMP and will always be required where there are:
• bulk storage facilities for liquid chemicals or other potentially polluting substances; and
• no preventative measures e.g. lack of hard standing or use of sub-surface pipework for
transport of substances; or
• inadequate preventative measures e.g. cracked or inappropriately maintained hard
standing or bunding or where the delivery pipework or valves are located outside of such
bunding; or
• a history of pollution incidents or spillages at the site; or
• no, or in adequate, proposals to conduct integrity testing of preventative measures.
Such sampling would not normally be necessary as part of the SPMP at installations where it
can be demonstrated that there is little likelihood of pollution. To achieve this the following
criteria must be met:
• adequate preventative measures are in place e.g. above ground pipework or other
equipment, the leakage from which could lead to pollution, is over an impermeable
6
surface, bunded and surfaced in accordance with the standards set out in general sector
guidance and, where available, sector specific guidance; and
• integrity testing continues to demonstrate that the preventative measures are intact; and
• the site does not have a history of pollution incidents or spillages; and
• adequate management systems are in place.
3.3 Six Months After Permit Issue
At installations that require Reference Data to be collected these results must be submitted to
the EHS within six months from the date of Permit issue. At installations where Reference Data
does not need to be collected the undertaking and reporting of monitoring will be set out in the
SPMP. The submitted results and implemented SPMP must meet the requirements as laid out
in this guidance and relevant reporting template.
3.4 Life of the Permit
The SPMP will normally require the Operator to continually monitor the site during the life of the
Permit to assess the continued effectiveness of the pollution prevention measures. This could
be via the collection and analysis of samples and/or the inspection of site infrastructure.
Monitoring will require the review and assessment of data and if it indicates that a pollution
incident has or is occurring the Operator will be required to undertake remediation. Further
details on what would be required in these situations is provided in Appendix C.
7
GUIDANCE ON THE PREPARATION OF AN APPLICATION SITE REPORT
4.0 Stage 1 – Application Site Report - ASR
4.1 Introduction
Completion of the ASR will normally involve the following activities:
• Desk based review of all available reports, site plans, operational records, material
inventories, records of pollution incidents, etc.
• Site reconnaissance (or walk over) to make site based observations;
• Assessment of the adequacy of pollution prevention measures;
• Reporting.
The completion of these activities will need to be undertaken in the following steps:
Step 1 – Site Environmental Setting and Pollution History – collection of information about
the environmental setting and history of any land or groundwater pollution at the site of the
installation.
Step 2 – Identify Potentially Polluting Substances – identify the areas where potentially
polluting substances are to be used, produced or stored. Where are the potential “emission”
points? Identify what substances could already be in the land from past pollution events or
activities (analysis and concentrations of contaminants is not normally required).
Step 3 – Identify Preventative Measures – for all the potential emission points what pollution
prevention measures are in place.
Step 4 – Assessment of Pollution Prevention Measures – for all the emission points assess
whether the pollution prevention measures are adequate to protect the land from pollution.
Step 5 – Development of Conceptual Site Model – using the information gathered in the
earlier steps construct a Conceptual Site Model of the site’s environmental setting and potential
for pollution. This model will be an important reporting tool and will be essential when
designing and implementing any subsequent SPMP.
Step 6 – Reporting – Presentation of information collected, assessments made and

conclusions drawn.
Further details on the requirements of each stage are outlined in the following sections of this
guidance and direct cross reference to the applicable sections in the ASR Template are also
provided.
8
4.2 Step 1 – Site Environmental Setting and Pollution History
Key Task
• Undertake desk based research and site reconnaissance.
The first stage in the process of preparing an ASR is to collect existing information about the
site, the site reconnaissance or site walk over should also form part of this activity and Table 1
outlines examples of what information is required.
This information is required to start the understanding of the condition of the site and will be
essential in the production of the Conceptual Site Model (CSM) and the design of any
subsequent monitoring programmes to ensure that they are as efficient and effective as
possible.
Table 1 – Information Requirements for Step 1 Including Site Reconnaissance
Information Requirements
− Size and location

− Current use (including site layout)
− Details of the proposed activities of the installation
Information to inform the desk study:
− Historical uses of the site that could present a potential source of land contamination
− Authorisations for Part A and B prescribed processes on site or in surrounding area
− Waste management licences on site or in surrounding area
− Local geology (drift and solid)
− Local surface water and groundwater hydrology and surface/groundwater water quality, pollution
− History of pollution incidents to land or groundwater
− Surface water and groundwater catchment and source protection zones, groundwater vulnerability
− Water abstraction details
− Topography
− Proximity of protected or “sensitive” habitats or species
− Existing site investigation, assessment and remediation records if available
− Details of the operation of the proposed installation, including review of chemical inventory for the
installation
− Existing operational records, environmental audit etc. (for installations which are already operating)
− Emergency response records (e.g. explosion, fire, spillages etc.)
− Effluent discharge consents / trade effluent agreements
Information obtained by site reconnaissance:
− Access arrangements
− Site layout including presence and condition of above and below-ground buildings/structures etc.
− Evidence of disturbed land, discoloured soil or water, subsidence, above ground deposits etc.
− Vegetation type and signs of distress or absence where it might be expected
− Significant odours from the land
− Liquid discharges from the site
− Direction and flow of surface water run-off and presence of ponding
− Land uses in the vicinity of the site
− Presence and condition of surface water features
− Evidence of any accidental/uncontrolled releases at the site (previous or current)
− Identify potential access constraints e.g. overhead cables, location of machinery, operations at the
site.
9
Completion of this stage will be achieved by the collection of desk based information and the
EHS will not normally require intrusive site investigations before determining the application.
However, there may be cases where the desk study information is incomplete or particularly
poor and intrusive investigations would be required prior to the Permit being issued. The
Applicant will need to consider whether an intrusive investigation is required to support the data
collected via the desk study. Situations where intrusive investigations may be required is
presented in Box 2.
References 6 to 10 provide further technical guidance on undertaking a desk study and site
reconnaissance.
Applicants may of course collect intrusive site investigation data for their own purposes and the
EHS would not wish to restrict this activity, provided that it was carried out in an appropriate
manner.
Box 2
Situations where intrusive investigations would be required as part of the Permit application
It is considered extremely unlikely that intrusive investigations would be required before a Permit is
determined as long as an Applicant can adequately describe the condition of the site with desk
based information. However, there may be exceptional cases where this is not the case, an
example could be the lack of important geological information that without it other relevant permit
conditions to prevent pollution cannot be identified.
It is expected that in the majority of cases information from the British Geological Survey (BGS)
would be adequate to describe the geology of a site. However, where:
• This data is insufficient or not available from BGS or other sources; and
• The actual geology at the site would significantly effect the impact of a pollution incident due to:
- the differing mobility of contaminants in different geological strata; and
- the particular circumstances at the site, large volume and type of substances stored
produced or used.
then it is likely that the Applicant would need to undertake intrusive investigations to fully understand
the site's environmental setting.
It is important to remember that data collected during other site investigation works for other
purposes, such as geo-technical design, may be used in the ASR.
Relevant ASR Template Sections:
Section in Template Requirements
3.0 Site Setting and Sources of Desk Introduces the sources of information used in the
Based Research Information report.
4.0 Site Reconnaissance Outlines the findings of the site reconnaissance or
walk over.
6.1 Geology and Hydrogeology Presents and interprets the detailed findings of the
6.2 Surface Water Feature desk based research and site reconnaissance
6.3 Results of Previous Investigations using a Conceptual Site Model.
6.4 Other Receptors
6.5 Pollution History
6.6 Site Zoning
10
4.3 Step 2 – Identify Potentially Polluting Substances
Key Task
• Identify any substance in, on or under the land which may constitute a pollution risk
The Applicant 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 pipe lines 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. However 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. Therefore it is important that the
Applicant considers the toxicity, environmental fate, behaviour and transport characteristics of
each substance.
In addition to considering the chemical behaviour and properties of a substance Operators

should also take into account whether impurities and potential degradation or reaction products
may pose a pollution threat to soil and groundwater quality.
The Applicant should therefore confirm what substances are used or produced at the installation,
including volume, noting where they are stored or used, what activity they are used in, key
environmental properties and whether, if released, they would pollute land or groundwater.
Substances that have similar environmental behaviour and/or toxicity may be grouped together.
The Applicant will also need to identify potentially polluting substances that may already be in the
land as a result of past activities or use of the site. This historic information will be gathered
during the desk study exercise in Step 1.
Information on the past uses of a site can often be found on old ordnance survey maps or other
historic records. Lists of potentially polluting substances associated with different types of
industry can be found in the DoE Industry Profiles series, ref 10. This information should be
presented in tabular form clearly illustrating the possible contamination at the site. The applicant
is not required to quantify historic contaminants in the ground, rather all that is expected is a desk
based assessment/identification of potential historic pollutants in order to describe the condition
of the site of the installation.
The Applicant must also consider how to split the site of the installation into zones. This will
assist the later stages of the process enabling targeted and effective (ie risk based) monitoring
and sampling. Zoning should be based on the identification of “emission points” of where
substances are stored, transported, produced or handled. Site zones must be illustrated on a
suitable drawing included in the ASR. Further explanation of site zoning is provided in Box 3.
Reference concentrations will need to be set only for those zones where it has been
demonstrated that there is a reasonable possibility of pollution.
Sources of information should be referenced and detailed information should be included in the
appendices of the ASR.
The Applicant may have undertaken intrusive surveys previously and may include such
information as part of a site report if they are relevant. However, the Applicant is not obliged to
include the results of previous intrusive surveys as a part of the ASR . The findings of this step
will need to be fed into the assessment of the pollution prevention measure as outlined in Step 4
Section 4.5.
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4.4 Step 3 – Identify Pollution Prevention Measures
Key Task
• For all the potential emission points identify what pollution prevention measures are in place to
protect the land.
For each of the operational activities (that could result in pollution of the land ie “emission
points”) and associated substances the Applicant needs to identify and record what pollution
prevention measures are in place to protect soil and groundwater
The principal means of pollution prevention is the careful handling and storage of potentially
polluting substances. In the majority of cases for the protection of land this is determined by
the level of containment of a particular substance, ie spill prevention. Three levels of
containment can be considered and will need to be identified:
• Primary : For example, a drum, vessel, pipe, bag, etc. containing the substance
• Secondary : For example, a bund, double wall vessel or pipe, vent pipe, catch-pit, etc.
designed to retain the substance in the event of a failure of primary containment.
• Tertiary : Additional measures provided to contain a spillage (e.g. an oil interceptor in a
surface water drain, a concrete hardstanding for road-tankers offloading to a bulk storage
tank, etc.).
The findings of this step will need to be fed into the assessment of the pollution prevention
measures as outlined in Step 3 Section 4.5.
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Box 3
Zoning of a site
The Applicant will need to split the site into zones to assist in the assessment of whether there is a
reasonable possibility of pollution and, where required subsequently, with the design of any intrusive
investigations required to collect Reference Data. Zoning a site allows for a targeted and risk based
approach to be adopted and is based on two factors:
i) Location of potential contaminant emission points; and
ii) Properties of the ground and the potential contaminant.
To split a site into zones the Applicant must first determine what are the sites “relevant systems” that
could contain contaminant sources, and for each system whether there are smaller “relevant
activities” that should be considered separately. The division of the site into these component parts is
essential when the Applicant assesses the effectiveness of pollution prevention measures.
An example of a “Relevant System” is presented below:
Potentially Polluting Substance: Kerosene

Relevant System: Factory Heating System
Within this site operation there are a number of “Relevant Activities” that could be considered to be
potential “emission” points of the potentially polluting substance should there be a failure of
containment or spill.
In the example of the Factory Heating System the Relevant Activities could be:
Relevant Activity Reason
Delivery by road tanker to installation Spillage from road tanker on installation

roads entering road drainage and hence
soakaways.
Road tanker off-loading Spillage from road tanker or delivery
pipework to land.
Storage Failure of containment leading to spillage to
land.
Fuel supply to boiler plant Failure of underground pipeline between the
oil storage tank and boiler plant leading to
loss of product to land.
Boiler plant Spillage within boiler room to land or site
drainage.
The Applicant will need to assess the likelihood of pollution as outlined in Section 4.5 for each of the
Relevant Activities at the site. Tables 2A and 2B illustrates how the splitting of the site fits into this
assessment process.
After completing the assessment of the effectiveness of pollution prevention measures the Applicant
will have determined which parts of the site represent potential emission points to land (where there is
reasonable possibility of pollution occurring) and will be required to collect reference concentrations.
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To complete the zoning of the site the Applicant must set a spatial zone around each of the potential
emission points for which reference levels, will be set. The size and shape of this zone will be based on
the extent to which a pollutant can spread away from the emission point and is a function of:
• Volume of substance that could escape;

• Geological conditions – soil type, physical properties, structure, retardation factors;
• Groundwater, depth, flow rates and direction;
• Attributes of the substance – fate and behaviour, transport characteristics if it is released into the
environment of the site.
The schematic drawings below show how a site zone is developed. Drawing 1 shows the relevant
system with its relevant activities and results of the pollution prevention assessment. This information is
superimposed on to data of the site’s geology and hydrogeology. Based on the pollution prevention
assessment, properties of the potential pollutants and site environmental setting the Applicant has
defined the extent of zones around each potential emission point, Drawing 2.
Reference concentrations will be required to be set for each of the defined zones. Note also that zones
can overlap.
Drawing 1
Schematic Plan of a Relevant System, Assessment Results and Information on Site
Environmental Setting Required to Develop Appropriate Site Zones.
Information on differing underlying geology and groundwater flow direction and depth is also indicated on
the plan.
Groundwater Flow at 2m bgl
Relevant Activity: Storage Tank

Assessment: Reasonable
Possibility of Pollution Tank
Reference Data Required
River Gravels
Clay
Relevant Activity: Pipeline Pipeline
Assessment: Reasonable
Possibility of Pollution
Reference Data Required
Relevant Activity: Boiler

Assessment: Little
Likelihood of Pollution Boiler
Reference Data NOT
Required
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Drawing 2
Schematic Site Plan Illustrating Appropriate Site Zones
Information on differing underlying geology and groundwater flow direction and depth is also
indicated on the plan.
Groundwater Flow at 2m bgl
Zone A
Tank
River Gravels
Zone B
Clay
Pipeline
Zone C
Boiler
15
4.5 Step 4 – Assess the effectiveness of the Pollution Prevention Measures
Key Task
• Assess the effectiveness of the pollution prevention measures and provide a statement of the
likelihood of pollution of the land.
The objective of this stage is to bring together all 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 Applicant will need to assess whether:
• There is little likelihood that pollution or leaks to land will occur during the future life of the
installation;
or:
• There is a reasonable possibility that there is potential for current or future pollution of
the land from the installation.
The outcome of this assessment will inform whether intrusive sampling and the collection of
Reference Data in the first phase of the SPMP will be required. The definitions of “likelihood”
and “reasonable possibility” are presented in Box 4 and an illustration of the questions to be
answered in making this assessment is presented in Figure 2.
Box 4
What is meant by “little likelihood” and “reasonable possibility” ?
The terms “little likelihood” and “reasonable possibility” are explained in greater detail in Section 4.5,
however they can be summarised as follows:
If the following situation exists at a site:
• bulk storage of liquid chemicals or other polluting substances; or

• high volume through put of polluting substances
Then there is the possibility of pollution. However, there also needs to be an assessment of whether
pollution might occur using the following questions:
a) Do preventative measures exist for each of the relevant activities at the installation?
b) Are the preventative measures adequate to prevent the emission of potentially polluting
substances to land?
c) Does the Applicant have NO record of pollution incidents or spills from the relevant activities to be
permitted? *See Note*
d) Are there proposals to conduct integrity testing of preventative measures?
e) Is there an adequate documented management system to demonstrate operator management

and competence for the relevant activities?
16
To satisfy the criteria that there is little likelihood that pollution will occur during the future life of the
installation the Applicant will have to have answered YES to ALL five of the above questions.
If the answer is NO to ANY of the above five questions then there is the reasonable possibility that
there is potential for current or future pollution of the land from the installation.
*Note* Question c) can be ignored if the Applicant can demonstrate appropriate measures have been
undertaken to ensure that further pollution incidents or spills do not occur. This could include
necessary improvements to management systems, equipment, plant or processes.
The criteria by which the key questions in this assessment should be answered is presented
below.
To assist the Applicant in the collection and presentation of data that is required to make this
assessment a specific template table has been prepared. An example of how to complete this
section of the ASR template is presented in Tables 2A and 2B.
Question ?
a) Do preventative measures exist for each of the relevant activities at the

installation?
This question is answered by the Applicant following the requirements outlined in Section 4.4
(Step 3) of this guidance.
Question ?
b) Are preventative measures adequate to prevent the emission of potentially

polluting substances to land?
To answer this question the Applicant must undertake an assessment of the pollution control
measures at its installation. Indicative requirements for the control of emissions to land are
presented in Box 5. The Applicant will need to demonstrate that it is applying these indicative
requirements or other equally applicable site specific measures to control potential emissions to
land in order to answer yes to question b).
Question ?
c) Does the Applicant have NO record of pollution incidents or spills from the
relevant activities to be permitted?
Data collected during the desk study and site reconnaissance, Section 4.2 (Step1) will enable
the Applicant to answer this question. At existing installations the Applicant needs to
demonstrate that they do not have a past record of pollution incidents or spills from those
activities that are to be permitted.
This question can be ignored if the Applicant can demonstrate appropriate measures have
been undertaken to ensure that further pollution incidents or spills do not occur. This could
include necessary improvements to management systems, equipment, plant or processes.
Question ?
d) Are there proposals to conduct integrity testing of preventative measures?
The criteria to assess integrity testing should in the first instance be whether there is any
proposed or currently undertaken. If it is then it will need to satisfy the following:
17
• Testing or monitoring to ensure continued compliance with performance standards. Eg

maintain relevant standards of construction and/or BS standards; or
• Certification or quality assurance by a competent person or body; or
• Type testing of equipment (eg. tanks) to a recognised standard and produced under a
quality assurance system complying with ISO 9000.
Question ?
e) Is there an adequate documented management system (preferably externally

certified or verified to a recognised EMS standard) to demonstrate operator
management and competence with the relevant activity?
The effectiveness of the pollution prevention measures identified in Step 3 are directly
related to operator competence. The following criteria should be considered to
demonstrate operator competence with the pollution prevention measures:
• Documented procedures for operation and maintenance;

• Emergency procedures – it is recommended that Operators draw up emergency plans
that are periodically tested.
• Training and training records covering the above.
The above criteria are integral to environmental management systems. An externally certified
or verified EMS is a useful tool to demonstrate operator management and competence
Other relevant Pollution Prevention Guidelines (PPGs) produced by the Environment Agency
include:
1. PPG 11: Preventing Pollution at Industrial Sites

2. PPG 18: Managing Firewater and Major Spillages
3. PPG 26: Storage and Handling of Drums and Intermediate Bulk Containers
All the Pollution Guidance Notes are available on the Environment Agency’s web site at:
www.environment-agency.gov.uk/business/444251/444731/ppg
5.0 Assessment of Pollution Potential This section sets out the

5.1 Polluting Substances and Relevant Applicant’s case whether there
Activities is little likelihood or reasonable
5.2 Preventative Measures possibility of pollution.
5.3 Assessment of the Likelihood of Pollution
18
Figure 2 – Assessing the Likelihood of Pollution
Notes: The need for Reference Data should be assessed on a relevant activity basis.
Question c) This question can be ignored if the Applicant can demonstrate appropriate measures have been undertaken to ensure that further pollution
incidents or spills do not occur. This could include necessary improvements to management systems, equipment, plant or processes.
a) Do preventative measures exist for

Is there:
each element of the activity?
• bulk storage of liquid
chemicals or other
potentially polluting
substances ? b) Are preventative measures
• high volume Y Answer ALL adequate to prevent the emission of Have you
through-put of potentially polluting substances to answered Y Collect
five of the
polluting land? "No" to any Reference
following
substances? questions of the five Data
questions?
c) Does the Applicant have NO record
of pollution incidents or spills from the
N relevant activities to be permitted? N
d) Are there proposals to conduct

Collection integrity testing of preventative Collection of
of measures? Reference
Reference Data NOT
Data NOT Required
Required e) Is there an adequate documented
management system to demonstrate
operator management and
competence with the relevant activity?
19
Box 5
Indicative measures to control emissions to land
Indicative Requirements
With regard to subsurface structures, the Applicant should:
• establish and record the routing of all installation drains and subsurface pipework;
• identify all subsurface sumps and storage vessels;
• engineer systems to ensure leakages from pipes and the like are minimised and are easily detected if
they do occur, particularly where potentially polluting substances are involved;
• provide, in particular, secondary containment and/or leakage detection for such subsurface pipework,
sumps and storage vessels;
• establish an inspection and maintenance programme for all subsurface structures, for example,
pressure tests, leak tests, material thickness checks or CCTV.
For surfacing, the Applicant should:
• describe the design(#), and condition of the surfacing of all operational areas;
• have an inspection and maintenance programme of impervious surfaces and containment kerbs;
• justify where operational areas have not been equipped with:
- an impervious surface;
- spill containment kerbs;
- sealed construction joints;
- connection to a sealed drainage system.
(# Relevant information may include as appropriate: capacities; thicknesses; falls; material; permeability;
strength/reinforcement; resistance to chemical attack; inspection and maintenance procedures; and quality
assurance procedures.)
All tanks containing liquids whose spillage could be harmful to the environment should be bunded. Bunds
should:
• be impermeable and resistant to the stored materials;

• have no outlet (that is, no drains or valves) and drain to a blind collection point;
• have pipework routed within bunded areas with no penetration of contained surfaces;
• be designed to catch leaks from tanks or fittings;
• have a capacity greater than 110 percent of the largest tank or 25 percent of the total tankage, or
whichever is greater;
• be subject to regular visual inspection, where appropriate, and any contents pumped out or otherwise
removed under manual control after checking for contamination;
• where not frequently inspected, be fitted with a high-level probe and an alarm as appropriate;
• have fill points within the bund where possible or otherwise provide adequate containment for filling
facilities;
• be subject to a routine programme of inspections (normally visual, but extending to water testing
where structural integrity is in doubt).
20
Table 2A Assessment of the likelihood of pollution
Site Operation Substance Relevant Activity Potential for 1. Records of pollution 2. Existence of Nature of Primary Testing and Inspection Nature of Columns
or Site Zone Pollution from the pollution Containment of Primary Secondary continue
relevant activity prevention Containment Containment on to
measures table 2B
Name Unit Name substance, Detail the relevant Detail the failure Detail any incidents of Do pollution Detail the nature of the Provide details of a Detail the nature of
Ope ration and provide CAS RN if activity for each mechanism and pollution or s pills from prevention storage vessel, including testing and ins pection the secondary
refer to the appropriate as well substance where potential pollution the relevant activity. measure exist for volume, location and programme or containment.
relevant as manufacturers the location, arising from the This can be based on each element of provide unique reference reference to a separate
section of the product name. pollution risk or loss of primary visual assessment during the relevant number and indicate which document, e.g. pressure
Permit Site Volume stored. For pollution containment site reconnaissance, activity ? site plan it is shown on tests, leak tests,
Report mixtures provide prevention installation or other material thickness
containing its breakdown of measures differ records and data sources. checks etc.
description polluting substances Have measures been put
and percentage by in place to ensure no
volume. further pollution
incidents?
A) Factory Kerosene 1. Delivery by Spillage from road No evidence/records of Yes Road Tanker Compliant to British Site drains
heating and road tanker tanker on spills or leaks Standard and DOT discharge to oil
steam to installation installation roads Regulations interceptors prior
generation by entering road to soakaways
boiler using drainage and
fuel oil hence soakaways
2. Road tanker Spillage from road Visual inspection Yes Road Tanker Compliant to British Tankers park
off-loading tanker or delivery indicates land impacted Standard and DOT when filling tank
pipework to land with heating oil Regulations on Impermeable
pavement with
kerbs and falls to
underground
sealed tank of 30
cubic metre
capacity
Storage Failure of No evidence/records of Yes 200 cubic metre floating None Earth Bund
containment spills or leaks roof tank (ref A1 figure 3) containing tank
leading to spillage and fill point
to land
Fuel supply to Failure of Leaking underground No Underground steel Annual pressure test None
boiler plant underground pipe discovered during pipeline (ref A2 figure 3)
pipeline between general maintenance
the oil storage works in service trench
tank and boiler in 1999, pipe repaired.
plant leading to
loss of product to
land
Boiler plant Spillage within No evidence/records of Yes Boiler Plant (ref A3 figure 6 monthly Kerbed concrete
boiler room to land spills or leaks 3) maintenance and floor with no
or site drainage inspection programme surface drainage
21
Table 2B Assessment of the likelihood of pollution, continued
Continued Testing and Inspection of Nature of Tertiary Testing and Inspection of 3. Adequacy of pollution 4. Are the 5. Is there an The assessment on the likelihood of pollution
from table Secondary Containment Containment Tertiary Containment prevention measures proposed adequate and hence the need to collect reference samples
2A Yes/No Integrity documented will be made on the questions set in the
testing of manage ment GREEN columns on this table and supported
pollution system to by the information provided.
prevention demonstrate To make the case that there is little likelihood
measures operator of pollution the Applicant will need to provide
Adequate manage ment and the following ans wers:
Yes/No competence with Green Column 1 - No past pollution incidents
the relevant or spillages
activity? Green Column 2 - Yes pollution prevention
Provide details of a testing and Detail the nature of Provide details of a Do the pollution prevention measures exist for each relevant activity
inspection programme or reference the tertiary testing and ins pection measures and testing and Green Column 3 - Yes pollution prevention
to a separate document, e.g. Containment programme or reference inspection programme measures are adequate
pressure tests, leak tests, material to a separate document, comply with the indicative Green Column 4 - Yes adequate integrity
thickness checks etc. e.g. pressure tests, leak require ments set out in Box testing undertaken or proposed
tests, material thickness 5? Green Column 5 – Yes there is an adequate
checks etc. If yes then justify how. manage ment system
IF THE ABOVE CRITERIA CAN NOT BE
SATISFIED THEN THERE IS THE
REASONABLE POSSIBILITY OF
POLLUTION AND THE OPERATOR WILL
NEED TO COLLECT REFERENCE DATA
IN THE SITE PROTECTION AND
MONITORING PROGRAMME
Little Likelihood of Reasonable Possibility
pollution ? of Pollution ?
1. Interceptors visually None None Yes Yes Yes
inspected monthly and
following any notified spill as
part of EMS ref x.x a -
2. High level alarm to notify None None No Yes No
need for emptying. No
Integrity testing
- a
3. None None None No No No
- a
4. None None None N/A Yes No
- a
5. Design quality assurance and None None Yes: Requirements of Yes Yes
inspection and monitoring surfacing in section 2.2.5
programme as part of EMS
ref x.x
of the Sector Guidance
complied with as part of a -
EMS
22
4.6 Step 5 – Conceptual Site Model
Key Task
• Collation and interpretation of data in the form of a Conceptual Site Model.
By undertaking the activities outlined in Steps 1, 2, 3 and 4 the Applicant will have
gathered a significant amount of site specific data. This information now needs to be
combined to form a Conceptual Site Model (CSM) of the site.
The CSM is required to describe the condition of the site. 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. It will describe the
site’s environmental setting, help understand ground conditions and it will be
impossible to design an adequate SPMP, if one is required, without the completion of a
satisfactory CSM.
The CSM is a descriptive representation of the site establishing the contaminant

sources, pathways, receptors, assessment of pollution potential and details of the
pollution prevention measures. The CSM can be expressed in tabular, text and/or
graphical form.
The normal approach to land contamination management requires consideration of

source-pathway-receptor relationships in a conceptual site model. However, the PPC
Regulations require that the land of an installation is returned to a "satisfactory state"
when the Permit is surrendered. No additional pollution of land should occur during the
operation of a Permit. A policy of no deterioration of land quality.
Therefore the presence, nature and risk of adverse effects to other receptors are not
primary considerations in the context of the protection of land under PPC, although
potential sensitive receptors must be reported in the ASR. The CSM within a ASR
should therefore consider the land as a receptor in its own right and should
concentrate on the source and pathway terms as these will define the
distribution of pollutants in the subsurface if there is an accidental emission.
The CSM developed and presented within the ASR will be used as the basis of the
design of any investigations to collect Reference Data as part of the SPMP. The CSM
must therefore clearly state what are known facts and what are assumptions. Assumed
parameters that can significantly affect the distribution and fate and transport of
pollutants in the subsurface may need to be determined through site investigation.
An example of a graphical CSM for a zone of the site where the assessment of
pollution undertaken in Step 4 indicates that there is a reasonable possibility of
pollution of the land is presented in Box 6.
23
Box 6
Example graphical preliminary conceptual model
ZONE 1
Operational Unit - Bulk Storage of Fuel Oil (line of section)
Sands and
Gravel
Clay
On 15 June 2002 a valve failed on number 1 fuel oil tank leading to the loss of 80 cubic
metres of fuel oil to the land. The failure caused a slow leak and the oil was lost over night.
The tank was decommissioned until the valve was repaired. The tank farm is surrounded by
earth bunds but the ground beneath the tanks is sufficiently permeable to allow fuel oil to
seep through. On the basis of the published geological data for the area and the known
characteristics of the pollutant the above graphical description of the likely nature and extent
of pollutant distribution in the subsurface has been produced.
Uncertainties in the preliminary conceptual model that could affect the distribution of
pollutants in the subsurface.
A GEOLOGY: Thickness of sand and gravel (S&G) horizon, nature of S&G / Clay
interface, particle size distribution of S&G, fraction of organic carbon, clay mineral
content, bulk density - heterogeneity of these geological parameters.
B WATER TABLE: Orientation, unsaturated zone thickness, seasonal fluctuation in

unsaturated zone thickness.
C RECHARGE: Effective recharge
D HYDROGEOLOGICAL PARAMETERS OF S&G: Porosity, Permeability, flow velocity,

dispersivity,
E UNSATURATED ZONE SOURCE TERM: Residual oil contamination concentration

and distribution; presence and volume and extent of free-product ponding on the
water table and capillary fringe; solubility of different hydrocarbon species, viscosity,
vapour pressure, density of the fuel oil.
F DISSOLVED PHASE PLUME: Existence, dimensions, orientation, concentrations,

extent of natural attenuation processes, speciation of hydrocarbons
24
6.0 Conceptual Site Model The whole of section 6.0 presents the CSM,
6.7 Summary of Conceptual Site Model however summary information and
importantly uncertainties in the model should
be presented in section 6.7
25
4.7 Step 6 – Reporting
Key Task
• Produce a site report that must accompany the Permit application.
By following this guidance the Applicant will be able to submit a PPC site report that
satisfies the requirements of the EHS.
A Template for the ASR has been produced and is designed to help the Applicant by
clearly setting out reporting requirements.
In preparing the ASR for the Permit application the Operator should consider the
following issues:
• Use of the ASR Template.
• The ASR is factual in its nature and consideration should be given to the
presentation of this data. The use of tables, drawings and graphics can be very
effective in summarising and communicating large amounts of data and
information.
• A site plan must be submitted clearly indicating the relevant systems or activities
that have been assessed to have a reasonable possibility of pollution. This plan
must also show the zone around each system or activity for which reference
concentrations will be set in the SPMP.
• A site plan showing the historic past uses of the site and areas of potential
historic contamination.
• Site plans submitted should be marked with a scale, compass bearing, date and
version number. They should cover the whole (or relevant part of) the installation
and incorporate key features, such as buildings or other structures that are to
remain in place. Key features should be labelled clearly and a key / legend
should be provided.
• The ASR will be used in the design of the SPMP and any subsequent monitoring
programmes, if required, it is therefore important to ensure that the ASR is
complete and detailed enough to ensure that any future monitoring is targeted,
effective and efficient.
26
GUIDANCE ON THE PREPARATION AND IMPLEMENTATION OF A SITE

PROTECTION AND MONITORING PROGRAMME
This next section covers the requirements after a Permit has been issued and details the
activities the Operator must follow to ensure compliance with any specific conditions relating
to the submission and implementation of a Site Protection and Monitoring Programme.
This covers Stages 2 and 3 of the protection of land under PPC as detailed in Figure 1,
however Figure 3 presents the activities in these stages in greater detail.
• Stage 2 – Submit a design of a Site Protection and Monitoring Programme to the EHS
within 2 months from the date of Permit issue; and
• Stage 3 – Where Reference Data is required to be collected this must be submitted to
the EHS within 6 months from the date of Permit issue.
The EHS will take enforcement action in line with its Enforcement Policy if the conditions in
the Permit to protect land are not complied with.
NOTES FOR FIGURE 3
+ If necessary
# PPC is a preventative regime and deals purely with any additional pollution since the
issue of a Permit, or for a Specified Waste Management Activity the date of issue of the
Waste Management Licence. It does not consider the risks associated with this
pollution, and any additional pollution must be cleaned up to pre-permit levels before
the Permit can be surrendered.
* The SPMP would not apply in respect of any pollution which might arise from activities
on the site of the installation which are not covered by the Permit.
27
Figure 3 Development and Implementation of the Site Protection and

APPLICATION SITE REPORT -

• Develop CSM (Environmental Setting & Pollution History) STAGE 1
• Identify Potentially Polluting Substances
• Identify and assess the adequacy of pollution prevention
measures for those substances
• Determine the need for Reference Data
Is reference data required? (Figure 2)

Permit issued
Y
STEP 1 - Design the investigations to collect STAGE 2
N Reference Data
STEP 2
• Design the testing, inspection and maintenance
programme
• Design the environmental monitoring
infrastructure +
STEP 3
• Design the information and data management
systems
STEP 4 - Submit SPMP to the EHS

2 Months from Permit issue
STEPS 1 & 2 STAGE 3

• Implement SPMP
¾ Install monitoring infrastructure +
¾ Report Reference Data +
6 Months from Permit issue
PERMIT SUBSISTENCE - Testing, Inspection, Monitoring and

Assessment to establish whether pollution is occurring (e.g. trends)
SPMP to be updated to
N take account of changes
Assess
Is pollution occurring? * monitoring
brought about by
improvement plans,
Y programme and testing and inspection
submit to the results, monitoring
Agency any
Identify Source
# proposed
results, variations to
permit etc
modifications for
formal written
Is it a result of permitted activities? N
agreement
Y
Design, seek EHS agreement
Notes for Figure 3: Record results in Surrender Application
and implement remedial actions SPMP
28
5.0 Stage 2 – Designing a Site Protection and Monitoring Programme

Document
5.1 Introduction
The objective of this Stage is to use the ASR as a basis in the design of the SPMP.
The output of this stage will be a design report outlining what monitoring the Operator
will undertake, this report must be submitted to the EHS within two months from the
date of Permit issue.
To complete this stage the following steps must be completed:
Step 1 – Designing an Investigation to Collect Reference Data (if required)
Step 2 – Designing the Monitoring Programme
Step 3 – Designing an Information and Data Management and Reporting

Programme
Step 4 – Reporting
A summary of the objectives of an SPMP is outlined in Box 7.
The design of the SPMP, submitted in pursuance of a Permit condition, must contain
the level and scope of information as indicated by this guidance and relevant template.
29
Box 7
The objectives of a Site Protection and Monitoring Programme (SPMP)
The SPMP has a number of purposes:
• To ensure (as far as is practicable) that pollution prevention measures are sufficient to prevent
the emission of pollutants to land.
• To demonstrate and maintain the effectiveness of the pollution prevention measures at the site
throughout the life of the installation.
• To ensure adequate maintenance, inspection and testing of infrastructure to demonstrate its

effectiveness throughout the life of the installation.
• Where necessary to collect Reference Data for substances in use at the installation for which
pollution is ongoing or where there is a reasonable possibility of such pollution occurring.
• Where necessary to monitor land and/or groundwater to ensure pollution prevention measures
are effective and to provide warning of the failure of pollution prevention measures.
• To record the results of the above to demonstrate the land at the installation is in a satisfactory
state for the purposes of surrendering a permit.
Step 1 – Designing an Investigation to Collect Reference Data
Key Tasks
• Review the CSM and describe the fate and transport of pollutants in the subsurface for
each potentially polluting activity of the installation identified in Stage 1.
• Review any existing site investigation reports and data for the area of the installation.
• Design an investigation and environmental monitoring programme to collect Reference

Data to quantify ground conditions at the installation.
5.2.1 Introduction
The objective of this Step is to complete the design of an intrusive investigation

required to collect Reference Data. This will only be required from zones of the site
where the assessment of the likelihood of pollution, undertaken in Stage 1 Step 4,
indicates that there is a “reasonable possibility” that pollution of the land will occur.
The Operator can omit this step where the assessment of the likelihood of pollution
indicates that there is “little likelihood of pollution”.
The setting of Reference Data will require the collection of soil and groundwater
samples and subsequent chemical analysis. The Operator will be required to provide
actual quantified concentrations of polluting substances in the land that could be
released by the installation. At Permit surrender this information, along with other
monitoring data, will be used to assess whether pollution of the land has occurred and
will provide information on appropriate restoration levels. A full definition of what is
required by way of Reference Data can be found in Appendix A
30
If intrusive investigations are to be undertaken then this is likely to be the most cost-
effective time to install long term environmental monitoring facilities, avoiding as much
as possible, the costs of re-mobilisation of people and plant. Section 5.3 discusses the
design of environmental monitoring facilities and programmes.
Detailed guidance on designing an intrusive investigation can be found in references 7

to 18 and 22 to 25.
5.2.2 Review Conceptual Site Model
The location of potential (or actual) sources of emissions will be identified in the ASR.
In order to design a suitable and robust investigation and monitoring programme the
likely fate and behaviour of the substances in the ground must be understood. Box 8
contains factors that could affect the distribution of pollutants in the ground arising from
a point source emission.
It is also important at this stage to identify any uncertainties or assumptions within the
initial CSM provided as part of the ASR that may have a bearing on the pollutant
distribution at the installation.
¾ For instance the CSM may have assumed that a clay layer exists beneath the
site which would act as a barrier to the downward migration of pollutants to the
water table. If this is a significant factor in the potential contaminant distribution
beneath a site then investigations may need to include determining the
existence, thickness, nature and extent of the clay layer.
¾ Any intrusive investigations should also be designed to avoid creating

preferential pathways for pollutant migration and possibly exacerbating existing
pollution. In the previous example, for instance, designing a borehole incorrectly
could compromise the effectiveness of the clay as a barrier to pollutant migration
by puncturing it, allowing liquid pollutants to flow around the outside of the
borehole.
The importance of a thorough and robust CSM as part of the ASR cannot be stressed
enough.
From this review the potential distribution of pollutants in the subsurface beneath the
installation can be described. This should not only include the likely extent but also the
phase the pollutant is in, e.g. dissolved in groundwater, attached or sorbed to soil
particles, as a free-phase liquid floating on the water table or pooling at the bottom of
an aquifer
An investigation can then be designed to characterise pollutant distribution, resolve any

relevant uncertainties in the CSM and collect Reference Data for the installation.
Box 8
Examples of factors that affect the distribution of a substance in the land
Characteristics of the Source
• Mode of release e.g. single incident leading to catastrophic loss of containment or

released as a slow leak;
• Mass of substance released;
• Depth at which substance is introduced into the land;
• Time since incident occurred / leak started.
31
Characteristics of the Substance
• Solubility in water;
• Vapour pressure;
• Viscosity;
• Density;
• Affinity to soil particles, organic matter (sorption);
• Propensity to undergo biological, chemical and thermal breakdown.
Characteristics of the Subsurface
• Porosity;
• Permeability;
• Depth to groundwater, groundwater table orientation, seasonal variation
• Natural or man-made barriers to contaminant migration (e.g. clay layers, foundations)
• Natural or man-made preferential pathways for contaminant migration (e.g. gravel layers,
gravel backfill around underground services, fractures);
• Sorptive capacity (e.g. clay content, organic content, geochemical characteristics);
• pH and redox potential.
5.2.3 Designing Intrusive Investigations to Collect Reference Data for a Site
It is not the intention of this document to provide technical guidance on designing and
undertaking land contamination investigations. Relevant guidance is referenced within
this document. This Section and Section 3 of Reporting Template 2 provide a
framework for the design of intrusive investigations to collect Reference Data. This
Section should be considered with the guidance on designing monitoring programmes
in Section 5.3 below.
The investigation should be designed:
• to collect Reference Data concentrations at the installation for land and

groundwater in terms of the potentially polluting substances identified in the
ASR;
• to provide sufficient / additional data to allow the finalisation and refinement of
the design and installation of monitoring locations throughout the life of the
Permit.
It may be necessary to phase the investigation with a view to collecting the most
relevant and cost effective data for a site. Phasing of an investigation is more likely to
be required on large complex sites with a history of pollution incidents and numerous
potentially polluting activities.
The use of on-site testing and analysis tools providing real-time data during an
investigation is encouraged. Using a tiered investigation in such a way can lead to
lower overall investigation costs, but provide higher quality investigations. (Ref 18
and 29)
Quality assurance and quality control are key to collecting robust, reliable data.
Chemical analysis of samples should preferably be undertaken by laboratories that are
accredited under the Monitoring Certification Scheme (MCERTS). The Design SPMP
Template has been formatted so that the QA/QC requirements for the investigations,
analyses and reporting of results are properly designed and recorded.
32
Design SPMP
Template 2 – Collection of Reference Data Required
3.0 Intrusive Investigation to Collect Sets out and justifies the design of the
Reference Data required intrusive investigations for the EHS
3.1 Investigation and Sampling Strategy to approve.
3.2 Sample Locations
3.3 Analytical Strategy
5.3 Step 2 – Designing the Monitoring Programme
Key Tasks
• Design the Environmental Monitoring Programme
• Design the Infrastructure Monitoring Programme
5.3.1 Introduction
For the purposes of this guidance the Monitoring Programme is defined as a

combination of Environmental Monitoring and / or Infrastructure Monitoring.
Environmental Monitoring is defined as the collection of physical samples or data

relating to the presence and / or concentration of potentially polluting substances in, on
or under land and within groundwater.
Infrastructure Monitoring is defined as the use of a programme of integrity testing,

inspection and maintenance to prove the continued integrity of pollution prevention
infrastructure at an installation.
5.3.2 Designing the Environmental Monitoring Programme
On-going environmental monitoring may be required as part of an SPMP. At

installations where on-going monitoring is not required the Operator may wish to
undertake environmental monitoring at an installation for other purposes, e.g. good
practice, where there is actual or potential contaminant migration beneath an
installation from an adjacent site.
It is therefore in the Operator’s interest to monitor for substances in the land to

demonstrate that they did not cause pollution. This is because at Permit surrender,
unless it can convince the EHS otherwise, the Operator will be considered responsible
for any pollution on the site that was not identified by the original application or SPMP.
5.3.2.1 Define Objectives
The objectives for monitoring land and groundwater at an installation are shown in
Box 9.
33
Box 9
Objectives of monitoring land and groundwater at an installation
• To monitor the effectiveness of infrastructure and management procedures and provide

a warning of loss of containment.
• Defensive monitoring of a sensitive receptor (e.g. monitoring up-gradient of a borehole

used for potable supply on-site)
• To assist at Permit Surrender by:
¾ determining the movement of pollutants onto or off the site of an installation.
¾ determining the movement of pollutants within a site.
¾ providing data on long term trends.
5.3.2.2 Designing the Environmental Monitoring Infrastructure
It is suggested that environmental monitoring infrastructure be installed during

investigations to collect Reference Data. This would be based upon the CSM.
Following any round of investigation, additional information will have been collected
which should be used to refine CSM and possibly amend the design, location or
number of environmental monitoring points.
The following should be considered in the design of environmental monitoring

infrastructure:
• The suitability of any existing environmental monitoring infrastructure;

• The location of sources and the nature of any potential loss of containment;
• The nature of the polluting substance (see Box 8) especially the phase (liquid,
dissolved, emulsified, vapour etc) it is in;
• The fate and transport of the pollutant (when selecting the design and location of
infrastructure, e.g. preferential pathways in the sub-surface for pollutant
migration, partitioning between soil / water / vapour etc).
Record the design of the environmental monitoring infrastructure in Section 4.2 of

Reporting Templates 2 or 3.
5.3.2.3 Designing the Environmental Monitoring Schedules and Protocols
The environmental monitoring programme should include schedules and protocols

covering the following issues:
• The frequency and timing of monitoring;

• An emergency monitoring plan should pollution be identified;
• Sampling protocols (including collection, preservation, handling and storage);
• Analytical suites;
• Analytical protocols (including sample preparation and analysis);
• Quality Control and Quality Assurance of the process of sample collection and
analysis covering:
34
¾ Personnel roles and responsibilities

¾ Training of personnel
¾ Sampling and analysis validation using duplicate samples, sample and analytical
blanks etc
¾ Programmes for the inspection and maintenance of monitoring infrastructure
These protocols should be reproduced in Appendix E1 of Reporting Templates 2 or 3.

The environmental monitoring program should be summarised in Section 4.3 of the
Template.
5.3.3 Designing the Infrastructure Monitoring Programme
The purpose of the infrastructure monitoring program is to demonstrate the

effectiveness of pollution prevention measures at the site throughout the life of the
Permit. This occurs through a process of planned inspection, testing and maintenance
of infrastructure.
The infrastructure monitoring programme must also include a system for the regular
assessment, recording and reporting of monitoring results. Reference 32 contains
examples of check-lists and logs for the inspection, maintenance and repair of
infrastructure and is available from the DEFRA website.
Systems may already be in place at an installation that cover some or all of the
requirements of an SPMP. These may include:
¾ An EMS to ISO:14001 (or similar accredited scheme);

¾ A Planned Preventative Measures and Maintenance Programme;
¾ An inspection and testing programme compliant with appropriate industry
standards;
¾ An inspection, testing and maintenance programme in accordance with
infrastructure manufacturers recommendations;
¾ An inspection, testing and maintenance programme to comply with Health and
Safety Regulations.
If a condition requiring the collection of Reference Data IS NOT included in the Permit
then a case has been made that existing or proposed testing, maintenance and
monitoring procedures are sufficient to ensure there is little likelihood that pollution or
leaks to land will occur during the future life of the installation.
In this case the Design SPMP should contain a statement to the effect that:
1 Such procedures will continue during the life of the Permit, and
2 That procedures will be subject to review and modification following changes to
infrastructure, working practices or any guidance /statutory requirement the
procedure was based upon.
3 The SPMP should also include systems for the regular assessment, recording
and reporting of monitoring results for the purposes of demonstrating continued
compliance with Permit conditions and for the purposes of applying to surrender
a Permit.
If a condition requiring the collection of Reference Data IS included in the Permit (i.e. a
reasonable possibility exists for current or future pollution of the land from the
installation) then the following needs to be taken into consideration within the Design
SPMP:
A written scheme describing how techniques relied on for protection of the land are to
be monitored and maintained shall be prepared and should contain:
35
• Identification of items of plant or equipment within the installation that may

contain and/or transport substances, which if released may lead to pollution of
the land. (Primary containment)
Examples:
- Fixed Storage vessels
- Pipe runs and associated pumps, valves, flanges and fittings
- Process plant and equipment
- Drainage systems
- Raw material and final product packages
• Identification of plant, equipment or infrastructure within the installation that are

intended to prevent pollutants being released to land when there has been a loss
of containment. (Secondary containment)
Examples:
- Bunds
- Catch pits
- Impermeable hard-standing and kerbs
- Interceptors
• Identification of protective devices, designed to bring a failure of pollution

prevention techniques to the attention of the Operator, to shut down equipment
in the event of failure or to relieve the impact of abnormal operations.
Examples:
- Level measurement devices
- Alarms
- Automatic shut offs
- Leak detection systems
- Corrosion detection systems
• Identification of other techniques relied on to prevent a loss of containment of

substances that may lead to pollution of the land.
Examples:
- Security arrangements
- Off loading procedures
- Accident responses
- Inventory control
- Environmental Management Systems
• Identification of any appropriate standards used to ensure the techniques

identified for the protection of the land are designed, installed, monitored and
maintained to ensure the technique maintains its functional capability.
Examples:
- British Standards
- American Petroleum Institute Standards
- OFTEC Standards
- CIRIA Standards
- CEN Standards
- ISO Standards
- Manufacturers Recommendations
- Pollution Prevention Guidelines
• Details of any examination required, including inspection and testing, to ensure

any techniques, plant, equipment or infrastructure is maintained to an
appropriate standard.
Examples:
- Preventative maintenance schemes
- Statutory inspection schemes
- Manufacturers recommendations
- Installation inspection schemes
36
• Details of the maximum interval between examinations of techniques.

Examples:
- Statutory intervals
- Manufacturer’s recommendations
- British Standards
- EMS/QMS requirements
• Details of studies to identify those critical techniques that if modified or repaired

should be examined by a suitably trained person before being relied upon for
protection of the land.
Examples:
- Hazard/Environmental and Operability studies
- Failure mode analysis
- Fault/Event tree analysis
Design SPMP
Template 3 – Collection of Reference Data NOT Required
4.0 Monitoring Programme Sets out and justifies the required Monitoring
4.1 Objectives of the Monitoring Programme Programme for the site
4.2 Environmental Monitoring Infrastructure
4.3 Environmental Monitoring Programme
5.4 Step 3 – Designing an Information and Data Management and Reporting

Programme
Monitoring results will form a major part of the assessment that has to be submitted
with an application to surrender a PPC Permit. The operation of a robust SPMP is likely
to generate large volumes of data in the form of routine infrastructure monitoring and
analytical records.
The purpose of the Information and Data Management System and Reporting
Programme is to record this data, or to record summaries of the data.
The system should be designed to record data so that:
• The data is easy to understand and it is obvious what the data recorded relates
to and means;
• It is easy to query (having regard to data queries that are likely to be run during
operations and for the purposes of applying for surrender);
• It is easy to maintain and update (data entry);
• Where feasible, automatic data quality checks occur and non-compliant data is
flagged up for quality control checks and action.
Procedures should be developed covering the following issues:
• Data management and storage of relevant reports or summaries of reports for

the life of the installation;
• Clearly documented procedures and management responsibilities for reporting
and acting upon test and inspection failures;
• Regular reviews of the monitoring programme;
• Regular reporting of data both internally and to the EHS;
• Regular assessment of monitoring data to cover the following:
¾ Determining trends in pollutant concentrations
¾ Trigger concentrations for further assessment and action
37
• Responsibility for ownership of the data
These procedures should be reproduced in the relevant Sections of Appendix I of

Reporting Templates 2 or 3.
Design SPMP
Template 3 – Collection of Reference Data NOT Required
4.0 Monitoring Programme Sets out and justifies the monitoring and
4.5 Assessment and Reporting Procedures reporting procedures
The Design SPMP document must be submitted to the EHS within two months from the
date of the Permit issue and should provide a framework for any investigations to
collect Reference Data.
Templates for the production of the SPMP design report are available. These templates
have been designed to help the Operator by clearly setting out the EHS's expectations
for reporting.
Where Reference Data is required to be collected this must be reported to the EHS
within six months from the date of permit issue. For other monitoring the design
document must include a timetable and schedule for the implementation and reporting.
Two separate templates have been provided, one for those installations that require
Reference Data to be collected:
Scope and Design of a Site Protection and Monitoring Programme for

Installations Requiring Reference Data to be Collected
The other is for those installations that do not require Reference Data to be collected:
Scope and Design of a Site Protection and Monitoring Programme for

Installations that DO NOT Require Reference Data to be Collected
38
6.0 Stage 3 – Implement the Site Protection and Monitoring Programme
6.1 Introduction
This stage describes the implementation of the SPMP submitted to the EHS.
At installations where Reference Data does not need to be collected the timescale for
the implementation of the SPMP will be set out in the design document of the
programme.
However, at installations where Reference Data is required to be collected the results

must be submitted to the Agency within six months from the date of Permit issue.
To complete this stage the Operator will be required to undertake the following steps:
Step 1 – Undertake the first phase of the SPMP

Step 2 – Amend the SPMP as required
Step 3 – Reporting
6.2 Step 1 – Implementing the First Phase of the SPMP
Key Tasks
• Undertake investigations ensuring compliance with the QA/QC Plan
• Record the results of the investigations in a clear and structured way
• Undertake assessments of the data
• Revise the CSM
• Identify sources of any pollution, and state uncertainties and unknown sources
• Develop the summary of Reference Data
The investigations to collect Reference Data should take place in full accordance with
the design in the SPMP document. The EHS recognises, however, that conditions at
the site may necessitate amendments, for instance difficult ground and obstructions.
¾ Where any amendments are minor (for instance moving a borehole to an

adjacent location due to ground conditions) then such details should simply be
recorded (along with the justifications required) in the relevant Section of the
completed SPMP Template.
¾ Where amendments are more significant (for instance removing an investigation

location or otherwise reducing the sampling and analytical effort from that agreed
in the Design SPMP) they must be agreed in writing with the EHS before the
completed SPMP is submitted.
Reporting of the implemented SPMP should only contain the results of the
investigations and any amendments to the investigations and should not reproduce the
procedures, protocols, etc agreed in the Design SPMP.
39
6.3 Step 2 – Implementing the Remaining Part of the Site Protection and
Key Tasks
• Consider the assessment of the CSM and other collected data

• If required amend later phases of the ongoing SPMP
The purpose of this step is to finalise the ongoing Monitoring Programme following the
first phase of implementation for formal agreement with the Agency.
The proposed Monitoring Programme should be reviewed in light of findings and

actions from any investigations to collect Reference Data and any other collected data.
There may be a number of reasons to amend the design of the Monitoring Programme
following any investigations:
• The number and / or location of Environmental Monitoring points may have

changed due to: operational constraints, previously unknown services, sub-
surface obstructions etc.
• Intrusive investigations may have identified errors / misconceptions in the original

CSM on which the Monitoring Programme was based. For instance the
orientation of a water table may be different to that originally conceptualised
necessitating a change to the number and / or location of Environmental
Monitoring points for plumes down gradient of potentially polluting operations.
At some sites pollution may be identified in the collected Reference Data, if this is the
case further actions maybe required. Guidance on what to do in these situations is
provided in Appendix B.
In addition, pollution may also be identified in the data collected during the undertaking
of long term monitoring as part of an SPMP. Further guidance for these situations is
provided in Appendix C.
Two templates are available for the reporting of the first phase of the SPMP.
For sites where there is the need to collect Reference Data:
Template 4 – First Phase Reporting of the Site Protection and Monitoring

Programme for Installations where Reference Data is Required
For sites where the collection of Reference Data is not required:
Template 5 – First Phase Reporting of the Site Protection and Monitoring

Programme for Installations where Reference Data is NOT Required
Further requirements on reporting the results of an Investigation to Collect Reference

Data is provided in Box 10.
40
Box 10
Reporting Requirements Where Reference Data is Required
It should be noted that Reference Data is more than just the summary statement contained in
Appendix G2 of the Final SPMP Template. Reference Data include the revised conceptual site model,
borehole and trial pit logs etc, observations and other physical ground condition records as well as the
full data set for all analyses.
Whist monitoring of ground and groundwater may occur during the life of the permit, it is predominantly
against the Reference Data that the installation will be judged at surrender to determine satisfactory
state. It is therefore vital that all investigation, sampling and analysis methods are clearly documented in
the relevant appendices of either the scoping or completed SPMP Template so that valid comparisons
can be made to any investigations at surrender.
The following bullet points provide further guidance on reporting the results of investigations
and reporting Reference Data:
• A Statement of Reference Data (SRD) is required for each zone of the site identified in the ASR as
having a reasonable possibility of being polluted by the installation now or in the future. It:
¾ Must describe the condition of all soils / subsoils and associated groundwaters (where
appropriate) beneath that zone;
¾ Need only consider those substances identified as being potentially polluting that are stored,
handled, transferred, used or produced within that zone; and
¾ Should be accompanied by relevant analytical data that has been collected using appropriate
techniques.
Further guidance on and a description of Reference Data can be found in Appendix A.
• PPC does not consider whether the condition of the site is acceptable, it seeks to establish a
reference against which any deterioration in condition can be assessed. Therefore:
¾ Undertaking an assessment of the risk from any identified pollution is not required within an
SPMP.
¾ An explicit factual statement of the current condition of the site is required;
¾ Quantification of levels of pollution is required for those substances that may be added to by the
operation of the installation at the site.
Detailed guidance on intrusive investigation can be found in references 7 to 18 and 22 to 25.
41
References
1 Department of the Environment, Transport and the Regions, “The Pollution Prevention
and Control (England and Wales) Regulations 2000, Statutory Instruments 2000
No. 1973
2 Environment Agency, “Integrated Pollution Prevention and Control, Part A(1)

Installations: Guide for Applicants”, Version 2, December 2000
3 Water Resources Act 1991
4 Department of the Environment, Transport and the Regions, “Environmental Protection

Act 1990: Part IIA Contaminated Land”, Circular 02/2000, March 2000
5 Groundwater Regulations 1998
6 Department of the Environment (1994) CLR 2. "Guidance on the Preliminary Site

Inspection of Contaminated Land". Report by Applied Environmental Research Centre
Ltd. Volumes 1 and 2.
7 Department of the Environment (1994) CLR 3. "Documentary Research on Industrial

Sites". Report by RPS Group.
8 Environment Agency (2001). "Guide to Good Practice for the Development of

Conceptual Models and the Selection and Application of Mathematical Models of
Contaminant Transport Processes in the Subsurface". National Groundwater and
Contaminated Land Centre Report NC/99/38/2.
9 Environment Agency (2001), "Assessment and Management of Risks to Buildings,

Building Materials and Services from Land Contamination". R&D Technical Report P5-
035/TR/01
10 Department of the Environment (1995) Industry Profile Range (a range of 48

publications covering contaminant profiles from different industrial processes and land
uses).
11 British Standards Institution (2001), “Investigation of Potentially Contaminated Sites”,

Code of Practice, BS 10175.
12 Environment Agency (2001), “Secondary Model Procedure for the Development of

Appropriate Soil Sampling Strategies for Land Contamination”, R&D Technical Report
P5-066/TR.
13 Department of the Environment (1994) CLR4. "Sampling Strategies for Contaminated

Land"
14 ISO FDIS 10381-1 Soil Quality Part 1: Guidance on the Design of Sampling
Techniques
15 ISO FDIS 10381-2 Soil Quality Part 2: Guidance on Sampling Techniques
16 ISO FDIS 10381-3 Soil Quality Part 3: Guidance on Safety
42
17 ISO FDIS 10381-4 Soil Quality Part 4: Guidance on the Procedure for the Investigation
of Soil Contamination of Urban and Industrial Sites.
18 Environment Agency (2001), “Technical Aspects of Site Investigation”, 2 Volumes, R&D

Technical Report P5-065/TR.
19 British Standards Institution (1999), “Site Investigations”, Code of Practice, BS 5930.
20 Construction Industry Research and Information Association (1995), “Methane

Investigation Strategies”, Report 150.
21 Construction Industry Research and Information Association (1993), “The

Measurement of Methane and Other gases from the Ground”, Report 131.
22 Construction Industry Research and Information Association (1995/6), “Remedial

Treatment for Contaminated Land”, Special Publications 101 - 112, Twelve Volumes,
CIRIA (London).
23 Health and Safety Executive (1991), “Protection of workers and the general public
during development of contaminated land”, HS(G) 66.
24 Construction Industry Research and Information Association (1996), “A guide for safe
working practices on contaminated sites”, Report 132.
25 Department for Environment, Food and Rural Affairs & the Environment Agency,
“Handbook of Model Procedures for the Management of Contaminated Land” CLR 11
(in preparation)
26 Environment Agency (2002). "Non intrusive investigation techniques for groundwater

pollution studies". R&D Technical Report P403.
27 Environment Agency (2002). "Guidance on the selection of non-intrusive techniques for

groundwater pollution studies". R&D Technical Report P404.
28 Environment Agency, “Performance Standard for Laboratories Undertaking Chemical

Testing of Soil (version 2 –February 2003)”, EAS/2703/1/6
29 Environment Agency, "Application of Commercially Available and Emerging Innovative

Techniques for the Characterisation of Land Contamination" (in preparation), NC/02/23.
30 Environment Agency (2001) "Guidance on the Monitoring of Landfill: Leachate,

Groundwater and Surface Water", R&D HOCO_232.
31 Environment Agency (2001) "Review of Ecotoxicological and Biological Test Methods

for the Assessment of Contaminated Land" R&D Technical Report P300.
32 Department for Environment, Food and Rural Affairs (2002) “Code of Practice for Use
of Solvents”
33 Environment Agency “Preventing Pollution at Industrial Sites” Pollution Prevention

Guidance Note (PPG) 11
43
34 Environment Agency “Managing Firewater and Major Spillages” Pollution Prevention

35 Environment Agency “Pollution Incident Response Planning” Pollution Prevention

36 Environment Agency “Storage and Handling of Drums and Intermediate Bulk

containers” Pollution Prevention Guidance Note (PPG) 26
44
APPENDICES
Appendix A What are Reference Data ?
Appendix B Action to be taken if Pollution is Identified in the

Reference Data
Appendix C Investigating and Remedying Pollution Identified

During the Operation of the Site Protection and
Monitoring Program
Appendix D Glossary
45
APPENDIX A
What are Reference Data?
An Operator of a Part A Installation or Part A Mobile Plant may be required, as part of the
SPMP, to determine Reference Data for the installation.
In conjunction with long term monitoring data, the Reference Data will be used to set the
condition of the installation against which the restoration requirements at Permit surrender will
be established. Any additional pollution must be remediated back to the levels shown in the
Reference Data.
So what are Reference Data?
• Reference Data describe the quality of the land at and beneath the installation with
respect to the substances used, manufactured, stored or transported under the terms
of a PPC Permit.
¾ Land in this document refers to both soils (including made ground and natural
geological strata) and any groundwaters.
• As such Reference Data would normally be described in terms of concentrations (mass

per unit volume) in soil or water. e.g.
¾ 10 mg/kg Benzene in made ground

¾ 20 ug/l Benzene in groundwater
• Due to the inherent variability of soils and groundwater and the spatial variability of the
distribution of pollutants in environmental media it would be normal to present the
results of a statistically valid number of samples to describe Reference Data for an
installation, unless Reference Data are zero.
• Pollution at a site is likely to relate to point source discharges and the variation of
pollutant concentration across the site will reflect this. It will be a function of the location
of the source, the environmental fate and behaviour of the substance and the
environmental setting of the installation.
• As Reference Data are set to provide a comparison for surrender they must be of a
standard to make such a comparison possible and meaningful. The site should be split
up into a series of relevant activities or zones where conditions at the installation are
likely to be similar.
• Reference Data can be based upon intrusive investigation and subsequent sample
analysis or upon desk study information.
• Reference Data must be set only for those zones of the installation that have
demonstrated a reasonable possibility of pollution. Within each zone concentrations
must be set for each different environmental media encountered.
• Although a summary of Reference Data should be produced, the full data set,
investigation / inspection (etc) observations and interpretations and the conceptual site
model are all part of the Reference Data. They all provide data on the condition of the
land and will be used to assess trends in long term monitoring and satisfactory state by
the Agency upon receipt of an application to surrender a Permit.
46
APPENDIX B
Action to be taken if Pollution is Identified in the Reference Data
Should the intrusive investigations to collect Reference Data, (including the first round of
monitoring) identify pollution then the emergency monitoring plan (as part of the
Environmental Monitoring Programme) may have to be enacted. This Appendix and Boxes B1
to B3 provide the rationale and justification for enacting Emergency Monitoring Plan under
such circumstances.
It is reiterated that only those potentially polluting substances used or produced (or are likely
to be used or produced in the future) at the installation will have to be investigated. At
locations where it has been assessed that there is a reasonable possibility of releases
occurring. Box B2 details the categories of sources of pollution that may be found at an
installation.
Therefore if pollution is discovered it is logical to assume that the source is the

currently permitted activities (Type D), unless there is evidence to show that the source is
not the currently permitted activities (i.e. Types A, B or C in Box B2).
The PPC Regulations only relate to additional pollution and not to that existing when
Reference Data is collected, i.e. only a Type D source is regulated under the PPC Permit.
The emergency monitoring plan should be enacted unless the Operator could demonstrate to
the Agency's satisfaction that the source is not from currently permitted operations.
The ASR and investigations to collect Reference Data may have provided sufficient
information to identify a source or the Operator may wish or need to amend the SPMP by
augmenting it with additional intrusive or other investigations.
Appendix C provides guidance on actions to be taken if increasing levels of pollution are

identified beneath an installation during the life of a Permit.
The Operator may have to make a further decision as to how to respond to pollution identified
when collecting Reference Data:
¾ They can rely upon the Infrastructure and Environmental Monitoring (including the
Emergency Monitoring Plan) in the SPMP to determine the source or prove the integrity
of their infrastructure, or
¾ They could undertake additional investigations to determine the source of the pollution.
Waiting on the results of monitoring to determine trends in pollutant levels, to establish

whether they are causing pollution, could result in having to undertake additional investigation
and subsequent remediation of the land or groundwater identified in the Reference Data.
That is the pollution added during the monitoring period. Box B3 provides an example.
47
Box B1
Justifications for an Emergency Monitoring Plan
If pollution exists within land or groundwater then the proposed method(s) of assessing monitoring data will
have to take this into account. Even if no further releases occur since collecting Reference Data, the
environmental monitoring results will vary between monitoring events at the same location.
Differences in concentrations of pollutants in soil between different sample locations can be great even
over small distances. There can also be changes in soil concentrations at the same location over time,
caused by leaching of pollutants down through the unsaturated zone, sorbtion-desorbtion processes or
biodegradation of organic substances as well as additional emissions.
The concentration of pollutants in groundwater at an environmental monitoring location can similarly vary
due to a number of reasons as well as additional emissions. Migration of contaminants within groundwater
(a plume of pollution) could bring groundwater with a higher concentration to the monitoring borehole.
Rising groundwater can flush additional pollutants from the unsaturated zone.
Sampling and analytical procedures can introduce bias and "errors" in to environmental monitoring results
(so called uncertainty).
For these reasons the frequency of environmental monitoring may have to increase to that
identified in the emergency monitoring plan within the Design SPMP in order to determine
whether ongoing pollution is occurring, or whether increases in concentrations are due to
processes other than the release of substances to land.
Box B2
Potential types of sources of pollution identified during investigations to collect Reference Data for
an Installation
A) The source of the pollution was historic activities undertaken at the site of the installation that do
not occur under the terms of the permit.
B) The source of the pollution is outside the area of the installation and has migrated to beneath the
installation. The source could be an on-going or historic activity.
C) The source of the pollution was from activities that occur under the terms of the permit, but due to
changes or improvements to management practices or infrastructure the emissions have ceased.
D) The source of the pollution is from permitted activities and that source is on-going leading to
pollution of ground or groundwater in contravention of the PPC Regulations.
48
Box B3
Example of additional investigations
A bulk storage tank's contents are transferred to process areas via an underground pipe
system. The tank sits within a suitably sized bund that also encompasses the fill points. The
tank is filled by road tanker that parks upon a concrete apron draining to a sealed sump.
Testing and inspection of the bund, sump, tank and pipe occurred during investigations to
collect Reference Data. Pressure testing of the underground pipe system and stock
reconciliation could only provide an accuracy of >10 litres per day of product. Intrusive
investigations of the land were undertaken in suitable locations to set Reference Data for the
substance in the tank and pipe work and elevated levels of that substance were identified
in the soil and groundwater.
During the intrusive investigation boreholes were finished with groundwater monitoring
installations and regular monitoring was instigated within the SPMP. However the ASR's
conceptual site model identified that the concrete apron and sump for the tanker parking had
only been installed 6 months before applying for a Permit and that there were records of
several spills to land from tankers prior to this.
The CSM was reviewed and it was recognised that the groundwater level beneath the site
would fluctuate significantly throughout the year. This would lead to fluctuating levels of the
substance in the groundwater and hence concentrations in the monitoring results even
without any further emissions. It would therefore take a number of monitoring events, possibly
over a year, to establish whether trends in the monitoring data indicated an ongoing pollution.
By that time a large volume of the substance could be released which, under the PPC
Regulations, would need to be remediated.
The Operator could either wait to see if the monitoring identified increasing levels of pollution
or they could instigate further investigations to identify the source at the time Reference Data
was collected.
The PPC Regulations cannot be used to require the Operator to undertake investigations to
identify the source unless or until ongoing, additional pollution is identified. The Regulations
require that any additional pollution is remedied as soon as practicable, and the presumption
is against waiting to deal with it upon surrender. There may be major costs involved
remediating >12 months of pollution, not only remedial costs but also in terms of lost
production through any disruption such works may cause and damage to corporate image.
49
APPENDIX C
Investigating and Remedying Pollution Identified During the Operation of the

Site Protection and Monitoring Programme
Introduction
Should pollution be identified during the implementation of the SPMP that has occurred or
been added to since collecting Reference Data for an installation then additional works are
necessary to:
• Identify the source, or prove the source is not from the currently permitted installation;
• Remediate to levels shown in the Reference Data .
Guidance on identifying sources and remediation is contained in this Appendix.
Operators are required to inform the EHS immediately of any breach of Permit condition. The
EHS would require Operators under such conditions to facilitate a prompt and satisfactory
resolution to a pollution problem. The guidance in this Appendix is included to assist
Operators to comply with these obligations. The EHS would be involved in discussions and
consultations if this situation arises.
When additional investigations are undertaken the EHS expects the same level of quality
assurance and quality control as is inherent in the SPMP. Any document produced would
form an addendum to the SPMP. It would be used as part of the assessment by the EHS
upon receipt of an application to surrender a PPC Permit.
Identifying Elevated Levels of Substances
It is necessary to determine whether the concentration of substances in the land represents

pollution by those substances.
Potentially polluting substances may already exist in the ground at background concentrations
if they are naturally occurring substances. Man-made, organic substances should not exist in
the land at any concentration except as a result of pollution.
For naturally occurring substances, the first step is to identify the concentration range
expected if there were no human activity impacts (i.e. background levels) and compare that to
levels found at the installation. Background levels could be determined from the analysis of
environmental media in areas of the installation where those substances were never used
and could not have migrated to, or through the use of literature sources. Background
concentrations will vary for different strata, made ground and groundwaters and so careful
consideration must be given to the relevance of literature sources to conditions at the
installation.
Pollution Identified in the Reference Data
Box B2 in Appendix B details the potential types of sources of land or groundwater pollution at
an installation.
Ideally investigations and assessments undertaken to collect Reference Data will have been
sufficient to identify the source of any elevated levels and this step may simply consist of:
• Reporting the source along with the reasoned assessment and supporting data for those
cases described by A), B), and C) in Box B2.
• Identifying the source and reason for the emission from the permitted activity (D) in Box
B2) - In this instance all such sources should be considered.
50
However if the source cannot be attributed then additional investigations will be required as
detailed in the following Sections.
Undertake Additional Investigations to Identify the Source of Elevated Levels

of Substances and / or Characterise the Extent of Pollution
Key Tasks
• Design of investigations to identify unknown sources of pollution.
• Undertake investigations, assess and report findings.
• Revise Conceptual Site Model and Reference Data if appropriate.
Whilst the PPC Regulations do not control any pollution existing before a Permit was issued
or pollution arising from a non-permitted activity outside the installation boundary, any
increase in pollution identified since the collection of Reference Data will be attributed to the
installation. Unless the Operator can demonstrate to the EHS's satisfaction that the source is
not from the installation.
If it is known that the source is as a result of the permitted activity then additional
investigations may still be required in order to characterise the extent of the pollution and
collect data to design an effective remediation scheme.
Investigations additional to that undertaken to collect Reference Data may include for
instance:
• Additional desk based study:

¾ collecting historic and adjacent land use data;
¾ further assessment of site records;
¾ interviewing workers;
¾ further assessment of the records of relevant public bodies, etc.
• Additional intrusive investigation:

¾ to delineate the extent of the pollution;
¾ to age or fingerprint the original source;
¾ to collect further rounds of monitoring data to establish trends of pollutant levels,
etc.
Assess the Results of the Investigations and Report Findings
The additional data collected should be assessed against the scenarios contained in Box B2.
If a source is confirmed as not coming from the currently permitted activities then the results
of the investigations and assessments should be reported within the SPMP. The Reference
Data for the site should be updated with this information.
If a source is confirmed as coming from the installation then the Operator shall move
immediately to remediation design and implementation. This additional information shall
not amend or update the Reference Data for the installation.
51
Design Remediation Measures and an Improvement Plan for Approval of the

EHS
Key Tasks
• Develop, agree and implement an Improvement Plan.
• Define Remediation Objectives

¾ Consider the broad remediation approach (e.g. removal or treating pollutants)
necessary for restoring sites polluted under a PPC permit;
¾ Define the objectives for remediation in relation to each relevant substance and
area.
• Evaluate & Select Remediation Methods

¾ Identify and shortlist potential remediation treatments;
¾ Evaluate the potential options;
¾ Select the preferred option(s);
¾ Develop an outline design for the proposed remediation strategy;
¾ Consult the EHS on the proposed strategy.
Develop, Agree and Implement and Improvement Plan
If activities at the installation are causing pollution then actions must be taken, as soon as is
reasonably practicable, to prevent any further emissions and remediate to Reference Data
levels.
Any additional pollution caused between the collection of Reference Data and the end of
emissions to the land must be remediated. The timing, extent and nature of this remediation
must be agreed with the EHS on a case-by-case basis.
Defining Remedial Objectives
The Practical Guide to Integrated Pollution Prevention and Control [Reference 16] sets out a
hierarchy of approaches to remediation under PPC as follows:
1. Treat or remove the pollution.

2. Immobilise the pollution.
3. Mitigate the effects of the pollution.
Note that the EHS also has powers to require any pollution from permitted activities
(where contravention of a Permit condition has occurred) to be remedied
(Regulation 26). Remedying the effects of pollution could, for example, involve
restocking a river which has received discharges of polluted groundwater or the
replanting of landscape areas that have been damaged through the airborne deposition
of polluted soil or dust.
Ideally, remediation should aim to treat or remove pollutants to achieve the levels identified in
the Reference Data for the installation. Only if it can be shown that it is not reasonable or
practicable to treat or remove the pollution should immobilisation techniques be considered.
Similarly, actions to mitigate the effect of the pollution (i.e. reduce the degree or severity of
impact) should only be considered if it is not reasonable or practicable to fully achieve
Reference Data levels using treatment/removal techniques. In the event that it is not feasible
to apply any of the above approaches, Operators should implement monitoring measures to
track the condition of the land until it is reasonable and practicable to implement remediation
52
or a ‘satisfactory state’ is otherwise achieved, for example through natural attenuation

processes.
The overriding objective is to return the land to the same state as it was when the Permit was
issued. This broad objective should be translated into a series of substance-specific
remediation objectives typically expressed in terms of the concentration (or amount) of the
substance(s) that should not be exceeded in soil or groundwater following remediation.
Remediation objectives should be defined by measured concentrations of the substances as

established by the Reference Data.
Note that for some remediation methods (typically those involving the containment or
immobilisation of polluted material), objectives may be better expressed in terms of the
physical or other characteristics of components of the method. For example, it might be
appropriate to define limits on the permeability of an in-ground barrier system or the leaching
behaviour of a solidification agent such that the quality of groundwater in contact with the in-
ground barrier or solidified material achieves the levels identified in the Reference Data.
Evaluating and Selecting Remediation Methods
A number of different methods or combination of methods are potentially available to deal

with polluted soils and groundwaters.
All methods have specific capabilities and limitations in terms of:
• Applicability (to the specific substances and media to be treated);

• Effectiveness (in achieving a specified end-point);
• Durability (in terms of remaining effective over the long-term, see below);
• Practicability in relation to :
¾ Site constraints (e.g. space, access, topography, services);
¾ Regulatory constraints (e.g. permission to set-up and/or operate the works, may
require a variation to the Permit);
¾ Time scale (e.g. time to achieve the required end-point or otherwise be
effective);
¾ Commercial availability;
¾ Health & safety and environmental risks during implementation;
• The wider environmental impacts of their implementation.
More detailed information on the technical and scientific basis of different remedial methods,
applicability to particular substances and key limitations can be found in References 13, 17,
20 and 21. Advice on monitoring techniques can be found in References 7, 22 and 23.
Note that additional work (e.g. supplementary site investigation or treatability studies) may be
needed to fully evaluate potential remediation methods. Supplementary investigations may be
required to develop and cost a detailed design and to check whether and to what extent site
specific factors may reduce effectiveness (e.g. permeability of the ground, presence of
substances inhibitory to biological action).
Treatability studies may be required for collecting information prior to making a final selection
of options. They may be used to:
• Determine the likely effectiveness of the remediation;

• Collect information to develop an effective treatment design;
• Estimate time scales for achieving the standard of remediation;
• Identify lines of evidence to verify the remediation.
Once sufficient information is available to make an informed selection, Operators should carry
out a structured analysis of options against clearly defined technical criteria, and estimate
53
costs and benefits. The aim is to establish which method (or combination of methods)
represents the best overall balance between technical effectiveness, practicability, durability,
costs and benefits.
Undertake Approved Remediation Works
Key Tasks
• Implement the agreed remediation strategy and undertake verification work to show
that it has been effective.
• Prepare a remediation completion report for incorporation into the SPMP.
• Consult the EHS on the outcome of remediation.
Designing and Implementing Remediation Works
Once a proposed course of remediation action for any particular area of land occupied by the
installation has been identified and agreed with the EHS, Operators will need to consider:
1. Management of the remedial works:- identifying both general and specific site
management objectives for the implementation of the remediation strategy.
2. Design and procurement:- confirming that the remedial works have been designed and
specified in sufficient detail for the strategy to be implemented. Precautions need to be
considered to protect health and safety, and the environment, during the
implementation of the works.
3. Implementation and validation:- the measures (e.g. monitoring programme for the
remediation ) that are to be put into place to show that remedial works have achieved
their objectives over a specified period of time and, where necessary given the nature
of the action taken, over a longer-term.
4. Ongoing monitoring and maintenance:- documenting the purpose and aims of ongoing
monitoring and maintenance.
References 13 and 17 to 21 contain detailed advice the above aspects.
Operators should also make appropriate financial and time provision for:
• Obtaining all necessary regulatory permissions to set-up and operate the remediation
strategy (e.g. waste management licences, mobile plant licence, etc.);
• Contingencies in the event that remediation fails to meet its objectives, necessitating
additional work, or is otherwise delayed or varied;
• Disruption to normal operations at the installation.
Verification of Remediation
Note. The EHS’s approach is that “verification” considers the effectiveness of a

treatment on a site specific basis, whilst “validation” considers the suitability of a
process for a specific application and is based on the experiences for specific
treatments within a number of projects.
Verification is a key component of the quality management of remediation projects. It

demonstrates that remediation work achieves its objectives over a specified timeframe. In
considering a verification programme it is necessary to include:
54
• The monitoring programme (including. sampling, field measurements and analytical

measurements) required to provide the necessary data to demonstrate the progress of
the treatment and compliance with the remedial objectives;
• The basis upon which verification is to be judged;
• Quality assurance and control procedures relating to the verification testing;
• Levels of data accuracy and precision required by the EHS, Operator, and / or other
stakeholders;
• The extent to which sampling techniques are thought adequate to ensure that a sample
is representative;
• The extent to which contamination data from a small number of samples is judged to be
spatially or temporally representative of the “real” situation.
All proposed verification work should be set out in a written specification or method statement.
This should assign clear responsibility for the work, set out the methods to be used (including
sampling and testing requirements) and specify reporting requirements.
More detailed guidance on the validation of remedial action is given in References 13 and 19.
Reporting the Remediation Work
It is essential that Operators produce accurate, reliable and unambiguous factual reports on
any remediation work carried out. The report should contain sufficient information for
someone unconnected with the work to easily establish what the work involved and whether it
was technically valid.
Thus the factual content of remediation reports should include a full account of:
• The rationale for remedial objectives and design of the works including the reasoning
for selecting the methods adopted;
• An updated conceptual site model;
• The responsibilities of all those involved (e.g. project managers, advisors and
contractors);
• How the work was carried out (e.g. methods and programme);
• The final condition of the land;
• Verification programme, methods and findings;
• Any monitoring, inspection and maintenance work and outcomes.
55
APPENDIX D
Glossary
Application Site Report (ASR) A report on the condition of land at the time an application is
made for permission to operate an installation or mobile plant.
Conceptual Site Model (CSM) A textual and/or graphical representation of the relationship(s)
between pollutant source(s), pathway(s) and receptor(s).
Containment In the context of pollution prevention, a physical structure (e.g.

vessel or bund) or barrier (e.g. a concrete hardstanding) used to
contain substances used in the installation and to prevent their
uncontrolled emission into the environment.
Closure Site Report (CSR) A report on the condition of land at the time of definite cessation
of permitted activities and an application is made for the
surrender of a Permit to operate an installation or mobile plant.
Durability In the context of a remediation method, the ability to perform as

designed over a specified period of time.
Effectiveness In the context of a remediation method, the ability to achieve the

required remediation objective or end-point.
Emergency Monitoring Plan A formally agreed, quality assured and quality controlled plan for
environmental monitoring at an installation following a release of
polluting substances to land, or the identification of pollution
during the routine environmental monitoring programme. The aim
of the plan is to identify the source of the pollution, characterise
the extent of the pollution and to collect data to facilitate any
necessary remediation to return the site to a satisfactory state.
Emission In relation to Part A installations, the direct or indirect release of

substances, vibrations, heat or noise from individual or diffuse
sources in an installation into the air, water or land.
In relation to Part A mobile plant, the direct or indirect release of

substances, vibrations, heat or noise from the mobile plant into
the air, water or land.
Environmental Management A documented structure that allows for the monitoring and
System (EMS) assessment of environmental impact with the objective of
continuously improving environmental performance.
Environmental Monitoring A formally agreed, quality assured and quality controlled

Programme programme of monitoring of land and / or groundwater during the
operation of a PPC Permit.
Failure Mode Analysis Technique to assess the likelihood and means of failure of
equipment.
Fault / Event Tree Analysis Technique to predict the likely events or combination of events
that will lead to an unacceptable outcome.
Hazard / Environmental and Technique to assess the outcome of deviations to normal process
Operability Studies operations.
56
Infrastructure Monitoring A formally agreed, quality assured and quality controlled

Programme programme of testing, inspection and maintenance of plant and
pollution prevention infrastructure to demonstrate continued
integrity and performance to design criteria.
Immobilisation technique Remediation methods that contain or encapsulate substances in

polluted media.
Monitoring Programme A formally agreed, quality assured and quality controlled

programme combining Environmental and Infrastructure
Monitoring Programmes.
Operation The combination of a substance (and its properties), the

containment measures used to hold it and related operations (e.g.
filling of a storage tank from a road tanker).
Operational Group A group of related operations involving the handling of a

substance that collectively comprise a complete stage in a
production process or service activity.
Pollutant Any substance, vibration, heat or noise released as a result of

such an emission (see Emission) which may have such an effect
(see Pollution).
Pollution Emissions as a result of human activity which may be harmful to

human health or the quality of the environment, cause offence to
any human senses, result in damage to material property, or
impair or interfere with amenities and other legitimate uses of the
environment. (Regulation 2(1) of the PPC Regulations).
Practicability In the context of a remediation method, the extent to which it is

possible to successfully implement the method given site,
regulatory, timescale, commercial availability, health and safety
and environmental protection constraints.
Quality Assurance Documented procedures of quality controlled methods.
Quality Control Actions, methods or techniques employed to ensure a quality

product. In relation to monitoring or analysis this is to ensure
accuracy and reproducibility of results.
Reference Data The condition of the land, with respect to potentially polluting
substances, which is set within the SPMP consisting of quantified
data (See Appendix A for further explanation).
Risk assessment The process of assessing the hazards and risks associated with a
particular site or group of sites.
Remediation In the context of PPC, action taken to return land to a ‘satisfactory

state’.
Satisfactory state The condition of the land occupied by an installation or mobile

plant when the Permit was issued.
SPMP Site Protection and Monitoring Programme.
57
Substance Includes any chemical element and its compounds and any
biological entity or micro-organism, with the exception of
radioactive substances within the meaning of Council Directive
80/836/Euratom, genetically modified micro-organisms within the
meaning of Council Directive 90/219/EEC and genetically
modified organisms within the meaning of Council Directive
90/220/EEC.
Supplementary investigation Investigation carried out subsequent to a main investigation for

the purpose of refining the characterisation of the sub-surface at
a site, to further delineate the distribution of pollution.
Targeted sampling Sampling that is specifically targeted at the location(s) of known

or suspect sources of pollutants.
Validation The process of obtaining information which demonstrates that

remediation has achieved its specified objectives.
Zoning The process of delineating one or more parts of a site that justify
different or specific approaches to sampling on the basis of
existing or future conditions.
58
IPPC H7 (Reporting Template 1)
Integrated Pollution Prevention and
Control (IPPC)
Template for an
Application Site Report in PPC
Applications
H7 Reporting Template 1
INTRODUCTION
This document presents a reporting template for applicants to use when preparing a PPC
Application Site Report. It is designed to assist applicants with the submission of the correct
information in a suitable format to the Environment and Heritage Service (EHS) and should
be completed in full.
This template has been prepared assuming that the Applicant will use a suitably qualified
third-party to assist in the preparation of the Application Site Report. Where this is not the
case it is acceptable for the information required to be cross-referenced to other parts of the
application.
Where there are deficiencies or uncertainties in the information provided in the application,
these should be clearly marked and annotated to indicate where further data gathering may
be required. It must be used in conjunction with the following guidance document:
Guidance on the Protection of Land Under the PPC Regime: Application Site Report
and Site Protection and Monitoring Programme
NOTES ON THE USE OF THE TEMPLATE
In the template, those parts written in italics and enclosed in square brackets ( i.e. [italics] ),
indicate where relevant information and or assessment is required to be entered. In entering
this information the italics should be deleted along with the brackets or written over and the
text reformatted to normal style.
Where text in italics appears prefixed with the word “Note” in bold ( i.e. [NOTE: italics] ) this
provides guidance on filling in the relevant [italics] part. On completion of the [italics] part the
[NOTE: italics] should be deleted from the final report prior to submission.
59
APPLICATION SITE REPORT
FOR PPC APPLICATION
[Installation name, operator name]
[Date]
60
Contents
Summary
1.0 Introduction
1.1. Site Location
1.2. Details of Installation
2.0 O
bjectives
3.0 Site Setting and Sources of Desk Study Research Information
3.1. Introduction
3.2. Environmental Consents, Licences, Authorisations, Permits and Designations for
the Site and Surrounding Area
3.3. Geological and Hydrogeological Data
3.4. Site Operational Records, Emergency Response Records and Records of any Land
Pollution Incidents in the Vicinity of the Site
3.5. Existing Site Investigation and Assessment Reports
3.6. Other Information
4.0 Site Reconnaissance
4.1 Introduction
4.2 Storage Tanks and Associated Pipe Work
4.3 Concrete Hardstanding and Bunds
4.4 Vegetation
4.5 Surface Water Features
4.6 Nature of the Storage and Handling of Materials
4.7 Surface Water and Foul Drainage
4.8 Other Indicators
5.0 Assessment of Land Pollution Potential
5.1 Polluting Substances and Relevant Activities
5.2 Preventative Measures
5.3 Assessment of the Likelihood of Land Pollution
6.0 Conceptual Site Model
6.1 Geology and Hydrogeology
6.3 Results of Previous Investigations/Assessments
6.4 Other Receptors
6.5 Land Pollution History
6.6 Site Zoning
6.7 Summary of Conceptual Site Model
6.7.1. Introduction
6.7.2. Graphical Representation of the Site
6.7.3. Uncertainties in the CSM
61
References
Appendix A - Figures and Maps
A1 Site Location Plans

A2 Geological Maps and Cross Sections
A3 Site Layout Plans
A4 Site Drainage Plans
A5 Plans Showing the Location of Sensitive Receptors
A6 Plans Showing the Location of Contaminant Sources
A7 Plans Showing Zones
Appendix B - Site Reconnaissance
B1 Figures
B2 Photographs
B3 Relevant Test Certificates
Appendix C - Desk Study Information
C1 Environmental Consents, Licences, Authorisations and Permits for Site and

Surrounding Area
C2 Geological and Hydrogeological Data
C3 Hydrological Data
C4 Site Operational Records, Records of any Land Pollution on Site
C5 Existing Site Investigation, Assessment and Remediation Records
C6 Other Information
Appendix D - Data Assessment
D1 Potentially Polluting Substances

D2 Assessment of Land Pollution Potential
Appendix E - Conceptual Site Model
E1 Tabular
E2 Graphical
62
Summary
This document represents the Site Report for [name installation] submitted as part of an application to
the EHS [Reference Number, where known at this stage..........] for a permit to operate an installation
under Regulation 10 of the Pollution Prevention and Control Regulations ( Northern Ireland) 2003.
Records of the site and surrounding areas have been reviewed [along with operational site records] in
order to describe the condition of the site and, in particular, to identify any substance in, on or under
the land that may constitute a pollution risk to the land. Pollution prevention measures have been
identified and an assessment of pollution potential to land has been undertaken.
63
1.0 Introduction
[Enter details of persons and / or companies undertaking the assessments for the applicant and
any other additional details.]
1.1. Site Location
The installation is located at [ADDRESS plus any further relevant location descriptor]. The
centre of the site is at National Grid Reference [8-figure grid reference ]. The site covers an
area of [...] Ha and can be seen in Figure 1 of Appendix A1.
[Describe features around the site of the installation, e.g. To the North of the site...(include brief
descriptions of land use, geographical or topographical features of note)]
1.2. Details of Installation
[Briefly describe the operations to be conducted under the permit referencing specific sections
of the permit application.]
[Identify any planned changes to operational layout or processes]
64
2.0 Objectives
The objectives of this report are:
To satisfy the requirements of the PPC Regulations at time of permitting by:
♦ Identifying the environmental setting and land pollution history of the site;
♦ Identifying activities that will be conducted at the installation that may lead to land
pollution;
♦ Identifying and assessing the preventative measures that are in place to protect the land;
and
♦ Assessing whether there is:
1. little likelihood that land pollution or leaks to land will occur during the future life of
the installation;
or there is:
2. a reasonable possibility that there is potential for current or future pollution of the
land from the installation.
♦ [To also satisfy the requirements of (insert other objectives if appropriate)]
[NOTE: Delete as applicable.]
65
3.0 Site Setting and Sources of Desk Study Information
[NOTE: Please refer to Stage 1 Step 1 of the Guidance]
3.1. Introduction
The following sections detail the sources of desk study information searched in order to
describe the condition of the installation and, in particular, to determine the potential for
substances to be present in, on or under the land associated with present and past uses of the
site and its surrounding areas.
[NOTE: It must be noted that this is not an exhaustive list and other sources of information may
exist that have relevance to your site. Such information should be detailed in Section 3.6 below
and collated in Appendix C6. As the text below is not an exhaustive list it is also not an all
inclusive list of data sources. The applicant will need to balance the resources available for this
data collection with the need to collect enough information at their site.]
3.2 Environmental Consents, Licences, Authorisations, Permits and Designations

for the Site and Surrounding Area
The [named organisation] was requested to provide records of any Discharge Consents, Waste
Management Licences, Abstraction Licences, IPC Authorisations, PPC Permits and Land
Drainage Consents for the site and within ... metres of the site boundary.
The [named organisation} was requested to provide details of any Trade Effluent Consents for
the site.
The [named organisation] were requested to provide details of any Nature Conservation
Designations for the site and within 10 kilometres of the site boundary. The locations of
Designated Sites within the vicinity of the site are shown in Figure[s] [x] on Figure A5.
Their responses are contained in Appendix C1.
3.3 Geological, Hydrogeological and Hydrological Data
Geological and hydrogeological information for the site was obtained from the following sources
and is reproduced in Appendix C2, and a geological map is included as Figure 1 of
Appendix A2.
3.4 Site Operational Records, Emergency Response Records and Records of any
Land Pollution Incidents in the Vicinity of the Site
[Operational records from the site have been reviewed and are summarised in Appendix C4.
Records of any spills or discrepancies in stock control of potentially polluting substances have
been identified and their significance assessed. A chronology of the installation of suitable
pollution control measures has been produced with reference to the dates of any incidents
involving the loss of containment or the release of potentially polluting substances to land.]
[NOTE: Basically were the pollution prevention measures that exist now, in place and effective
at the time of any incidents? Existing installations only]
The [named organisation] was approached to provide records of any land pollution incidents
associated with the site and within […] metres of the site boundary, the response to which is
also included within Appendix C4.
Site operational layout plans, including the location and nature of underground services and
pipelines are shown on Figure[(s) 1 to x] in Appendix A3.
66
The location of bulk storage tanks and raw materials / product storage areas are shown on
Figure[/s x to x] in Appendix A6.
Site foul and surface water drainage plans are included as Figure[(s) 1 to x] in Appendix A4.
3.5 Existing Site Investigation and Assessment Reports
There has been no previous relevant site investigation or assessment undertaken at this site.
or
The following investigation[s] and assessment[s] [has/have] been undertaken on the site and
[is/are] reproduced in Appendix C5.
[Date…, Report Title…, Authors…, Reason for the investigation / assessment…]
[The aerial extent of the investigations in relation to one another] or [The extent of this
investigation] with respect to the area of the site is shown on Figure 1 of Appendix C5.
3.6 Other Information
The following additional sources of information have been queried and the results are shown in
Appendix C6.
[List additional sources of information]
67
4.0 Site Reconnaissance
[NOTE: Please refer to Stage 1 Step 1 of the Guidance]
4.1 Introduction
The site reconnaissance was undertaken on [dates] by [company or particular employees of

applicant] on the area shown on Figure 1 of Appendix B1.
The purpose of the reconnaissance was to inspect the site and surrounding area for indicators
of potential land pollution. Site infrastructure was visually inspected [and in some cases
physically tested] to assess its competence and potential to cause or have caused releases to
land.
The following site features were inspected and as a result any indicators of potential areas of
land pollution are shown on Figure[(s) 2 to x] of Appendix B1. Photographs of features are
included in Appendix B2.
4.2 Storage Tanks and Associated Pipe Work
[List storage tanks and include a description of:

¾ The contents, volume and condition;
¾ The nature and mode of any fill and draw lines and points;
¾ Whether they are above or below ground;
¾ The nature, method and frequency of integrity testing;
¾ The nature and integrity of any secondary or tertiary containment features and evidence
that, where available, they are impervious to the substance stored in the tank or tanks;
¾ Evidence of loss of integrity or spillage such as staining;
¾ Any other relevant observations.]
The locations of the tanks and pipe work are shown in Figure[(s) x] in Appendix B1.
[NOTE: Each tank should be clearly identified in the above list. The Figure(s) should be at a
scale such that individual tanks are clearly identifiable.
Where visual evidence suggests secondary containment may be compromised, for instance
cracking of bund floors or walls, it is strongly suggested that tests be carried out to assess their
significance.]
4.3 Hardstanding and Bunds
[Detail the integrity of areas of hardstanding and bunds (not covered in Section 4.2 above) that
provide a barrier to the downward percolation of substances. This should include process
areas, transfer areas, drum or waste storage areas etc.
This should include:
¾ The nature and frequency of integrity testing;

¾ Areas of cracking or other damage;
¾ Whether they have been treated to be impervious to any substance that might be spilt
upon it in any significant quantity;
¾ Gradient / falls of hardstanding surfaces and ultimate fate of any run-off.]
4.4 Vegetation
[This section should provide a description of vegetation cover on the site and its immediate
surroundings for the area shown on Figure 1 of Appendix B2. It should include details of any
visual evidence of "stress" in vegetation on the site and surrounding areas. It is recognised that
68
on many sites there may be little or no vegetation due to the extent of hardstanding and
infrastructure. In such cases a statement to this effect would suffice.
Particular attention should be paid to the presence or absence of vegetation, the type and
diversity of vegetation, the health of the vegetation and the presence of any indicator species
tolerant to extreme soil conditions.]
[This section should include a description of any surface water features including such things
as evidence of discolouration and films, turbidity, odour, vegetation die-back, unusual or
impoverished benthic communities.]
4.6 Nature of the Storage and Handling of Materials
[This section should describe any activities or procedures noted during the site reconnaissance
that could have or may lead to the loss of substances to the land, such as:
¾ The handling and storage or substances outside areas of hardstanding;

¾ Inappropriate drainage around vehicle fuelling areas;
¾ Unprotected bunds and tanks in vehicle manoeuvring areas;
¾ Insufficient space for the safe storage and transfer of drums by fork lift leading to the
potential for accidents.
Where no such activities noted at the installation then a statement to this effect would be
sufficient.]
4.7 Surface Water and Foul Drainage
[This section should include details of the inspection of drainage at the site such as:
¾ The location of soakaways;

¾ The location of interceptors and other land pollution control measures;
¾ The location of surface water and foul drainage;
¾ Details of CCTV or other testing undertaken upon it.]
4.8 Other Observations
[This section should detail any other observations of relevance from the site reconnaissance.]
69
5.0 Assessment of Land Pollution Potential
[NOTE: Please refer to Stage 1 Steps 2, 3 and 4 of the Guidance]
5.1. Polluting Substances and Relevant Activities
A list of all substances used, stored, manufactured (or waste by-products from the
manufacturing process) is contained in Appendix D1. An assessment of their pollution potential
has been made based upon their properties, toxicity and volume stored, used or manufactured.
Those substances thus identified in Appendix D1 have been taken forward to 5.2 below.
[NOTE: The first step in assessing polluting potential therefore is simply to confirm what
substances are present at the installation, making brief notes on the volumes stored
environmental properties (including toxicity, fate and behaviour) and assessment whether if
released would pollute land and/or groundwater.
From the desk study data collection the applicant must also list polluting substances that may
already be in or under the land, no quantification is required.
The applicant also needs to present the information on potentially polluting substances based
on the zoning of the site and the concept of relevant activities as explained in the guidance.
The applicant should introduce the work undertaken in this section and list the sources of
information consulted in undertaking this activity. The results should be tabulated and
presented in Appendix D1.]
5.2. Preventative Measures
The pollution preventative measures (physical infrastructure and those relating to testing,
inspection and maintenance) for each relevant activity associated with the potentially polluting
substances have been identified and their extent and condition assessed. The results of this
work are shown in Appendix D2.
Plans showing the location of these activities are shown in Appendix A6 and A7.
[NOTE: In accordance with the guidance the applicant needs to state the preventative
measures associated with each of the relevant activities.
The guidance introduces the terms primary, secondary and tertiary containment and check
monitoring to assist in undertaking this activity.
information consulted in undertaking this activity.
The example Table D2A and D2B have relevant activities numbered. Plans in Appendix A6 and
A7 should be similarly numbered (or other identifier used in Appendix D2) and be at scale such
that features of the relevant activity that would have an effect on the nature and location of any
land pollution can be clearly discerned]
5.3. Assessment of the Likelihood of Land Pollution
Appendix D2 contains an assessment of the likelihood of land pollution from the installation.
[For all relevant activities at the installation there is little likelihood that land pollution or leaks to
the land will occur during the future life of the installation. It is the conclusion of this report that
reference data for the site does not need to be collected]
[NOTE: or]
70
[The assessment has identified relevant activities where there is a reasonable possibility that
there is or will be current or future pollution of the land from the installation. Reference Data will
be collected and reported within 6 months of the issue of a permit for the installation]
[NOTE: Delete as applicable. Using TABLES 2A and 2B in the guidance the applicant needs
to undertake the assessment of the likelihood of land pollution.
information consulted in undertaking this activity and summarise the areas of the site where the
assessment indicates there is the reasonable possibility of land pollution.
An example table is provided in this template.
The tabulated results should be presented in Appendix D2.
The applicant must supply a site drawing, to a suitable scale and detail, indicating the areas of
the site that present a “reasonable possibility” of pollution to the land and therefore will require
reference data to be collected within six months after a Permit has been issued. ]
71
6.0 Conceptual Site Model
[NOTE: Please refer to Stage 1 Steps 1 and 5 of the Guidance]
6.1. Geology and Hydrogeology
The geological sequence beneath the site is as follows:
[List geological sequence from surface down
1 e.g. Made ground
2 e.g. River Terrace Deposits (mainly gravels)
3 e.g.]
This can be seen in plan form in Figure 1 and in cross-section in Figures [2 to X] in Appendix
A2.
[6.1.1 e.g. Made Ground
This and succeeding sections should describe the extent, thickness, and characteristics of the
individual geological units listed above. The hydrogeological characteristics of the units must be
described.
Characteristics should include:
¾ The standard British Geological Survey stratigraphy.

¾ The presence and nature of any groundwater (including orientation of water table and
hydraulic gradient, groundwater / surface water interactions).
¾ Any other characteristics that may have a bearing on the mobility and degradation of
pollutants identified in Tables 1 and 2 above.
6.1.2 e.g. River Terrace Deposits (Mainly Gravels)]
6.2. Surface Water Features
The surface water features in the vicinity of the site are shown on Figure [x] of Appendix A5 and
are as follows:
[List surface water features. For watercourses include flow direction and details of any
culverting.]
Surface water drainage for the site is shown on Figure [x] of Appendix A4.
Groundwater beneath the site [is / is not] in hydraulic continuity with [name surface water
feature. Describe extent of groundwater / surface water interactions or best level of current
understanding, including areas of uncertainty.]
6.3. Results of Previous Investigations/Assessments
[Briefly outline the scope of the investigations referencing source material within Appendix C5.
Substances analysed for should only cover those substances and environmental media
identified in Appendix D1 and D2.
The laboratory or laboratories that undertook the analysis should wherever possible be UKAS
Accredited for those analytical techniques. Copies of the accreditation's, valid for the time of
analysis should be included in Appendix C5.
72
It is not good practice to present only summaries of the data set. The full data set should be
included in Appendix C5.]
6.4. Other Receptors
[NOTE: Include information on other sensitive environmental receptors identified through the
desk study research and/or site reconnaissance]
6.5. Land Pollution History
[NOTE: Detail any land and/or groundwater pollution events as identified through desk study
research and/or site reconnaissance associated with the activities of the site.]
6.6. Site Zoning
The site [has / has not] been divided into a series of zones based upon the site setting and the
possible (and actual) location of potentially polluting substances. These zones are shown on
Figure [x] of Appendix A7. Pollutant sources within each zone are shown as Figures [x to x] of
Appendix A7. Table 2 below has been split up on the basis of these Zones.
[List Zones with a description of each zone and the reason for its delineation.]
6.7. Summary Conceptual Site Model (CSM)
6.7.1. Introduction
The findings of the desk study and site reconnaissance (detailed above) have been used to
develop the conceptual site model (CSM) for the site. Uncertainties in the CSM are identified
and their significance discussed.
[NOTE: All of Section 6.0 of this report contributes to the overall Conceptual Site Model for the
site. This section requires a summary of the data in terms of contaminant sources, pathways
and receptors. The CSM can be in both tabular and / or graphical form and should be
presented in Appendix E. Detailed information on the requirements of A CSM can be found in
the Guidance. Applicants should refer to that document in the first instance. ]
6.7.2. Graphical Representation of the CSM
Graphical representations of the CSM have been produced and are shown in Appendix E2.
[NOTE: Graphical representations are a powerful communication tool and should be used
where possible in conjunction with supporting text. The Guidance provides an example of a
Conceptual Site Model for a particular zone of a site]
6.7.3. Uncertainties in the CSM
In developing the conceptual model for the site the following assumptions have been made:
[List assumptions, this could include for instance:
¾ Assuming a low permeability layer exists beneath the site isolating an Aquifer from any
potential pollutant sources on site.
¾ Hydrogeological conditions beneath the site (assuming depth to water table, permeability
of strata etc).
¾ Using values for environmental parameters from literature sources rather than
determining site-specific values.
The significance of these assumptions with respect to the likely fate and behaviour of the
substances identified needs to be discussed.]
73
Appendix D2 Assessment of the Likelihood of Land Pollution
Table D2A Assessment of the Likelihood of Land Pollution
Site Operation or Substance Relevant Activity Potential for 1. Records of pollution 2. Existence of Nature of Primary Testing and Inspection of Nature of Columns
Site Zone Pollution from the pollution Containment Primary Containment Secondary continue
relevant activity prevention Containment on to
measures table 2B
Name Unit Name substance, Detail the Detail the failure Detail any incidents of Do pollution Detail the nature of the Provide details of a Detail the nature
Ope ration and provide CAS RN if relevant activity mechanism and pollution or s pills from prevention storage vessel, including testing and ins pection of the secondary
refer to the appropriate as well for each potential pollution the relevant activity. measure exist volume, location and programme or reference containment.
relevant section as manufacturers substance where arising from the This can be based on for each provide unique reference to a separate document,
of the Permit Site product name. the location, loss of primary visual assessment during element of the number and indicate which e.g. pressure tests, leak
Report Volume stored. For pollution risk or containment site reconnaissance, relevant site plan it is shown on tests, material thickness
containing its mixtures provide pollution installation or other activity ? checks etc.
description breakdown of prevention records and data sources.
polluting substances measures differ Have measures been put
and percentage by in place to ensure no
volume. further pollution
incidents?
A) Factory Kerosene 1. Delivery by Spillage from road No evidence/records of Yes Road Tanker Compliant to British Site drains
heating and road tanker on spills or leaks Standard and DOT discharge to oil
steam tanker to installation roads Regulations interceptors prior
generation by installation entering road to soakaways
boiler using fuel drainage and
oil hence soakaways
2. Road Spillage from road Visual inspection Yes Road Tanker Compliant to British Tankers park
tanker off- tanker or delivery indicates land impacted Standard and DOT when filling tank
loading pipework to land with heating oil Regulations on Impermeable
pavement with
kerbs and falls
to underground
sealed tank of
30 cubic metre
capacity
Storage Failure of No evidence/records of Yes 200 cubic metre floating None Earth Bund
containment spills or leaks roof tank (ref A1 figure 3) containing tank
leading to spillage and fill point
to land
Fuel supply to Failure of Leaking underground No Underground steel Annual pressure test None
boiler plant underground pipe discovered during pipeline (ref A2 figure 3)
pipeline between general maintenance
the oil storage tank works in service trench
and boiler plant in 1999, pipe repaired.
leading to loss of
product to land
Boiler plant Spillage within No evidence/records of Yes Boiler Plant (ref A3 figure 6 monthly maintenance Kerbed concrete
boiler room to land spills or leaks 3) and inspection floor with no
or site drainage programme surface drainage
74
Table 2B Assessment of the likelihood of land pollution, continued
Continued Testing and Inspection of Nature of Testing and Inspection of 3. Adequacy of pollution 4. Are the 5. Is there an The assessment on the likelihood of pollution
from table Secondary Containment Tertiary Tertiary Containment prevention measures proposed adequate and hence the need to collect reference samples
2A Containment Yes/No Integrity documented will be made on the questions set in the GREEN
testing of manage ment columns on this table and supported by the
pollution system to information provided.
prevention demonstrate To make the case that there is little likelihood of
measures operator pollution the Applicant will need to provide the
Adequate manage ment and following ans wers:
Yes/No competence with Green Column 1 - No past pollution incidents or
the relevant spillages
activity? Green Column 2 - Yes pollution prevention
Provide details of a testing and Detail the nature Provide details of a Do the pollution prevention measures exist for each relevant activity
inspection programme or reference of the tertiary testing and ins pection measures and testing and Green Column 3 - Yes pollution prevention
to a separate document, e.g. Containment programme or reference inspection programme measures are adequate
pressure tests, leak tests, material to a separate document, comply with the indicative Green Column 4 - Yes adequate integrity testing
thickness checks etc. e.g. pressure tests, leak require ments set out in Box 5 undertaken or proposed
tests, material thickness ? Green Column 5 – Yes there is an adequate
checks etc. If yes then justify how. manage ment system
IF THE ABOVE CRITERIA CANNOT BE
SATISFIED THEN THERE IS THE
REASONABLE POSSIBILITY OF
POLLUTION AND THE OPERATOR WILL
NEED TO COLLECT REFERENCE DATA IN
THE SITE PROTECTION AND
MONITORING PROGRAMME
Little Likelihood of Reasonable Possibility
pollution ? of Pollution ?
6. Interceptors visually None None Yes Yes Yes
inspected monthly and
following any notified spill as
part of EMS ref x.x a -
7. High level alarm to notify None None No Yes No
need for emptying. No
Integrity testing
- a
8. None None None No No No
- a
9. None None None N/A Yes No
- a
10. Design quality assurance and None None Yes: Requirements of Yes Yes
inspection and monitoring surfacing in section 2.2.5 of
programme as part of EMS
ref x.x
the Sector Guidance
complied with as part of a -
EMS
75
and Control (IPPC)
Template for
Design of a
Site Protection and Monitoring
Programme for Installations
Requiring Reference Data to be
Collected
INTRODUCTION
This document presents a reporting template for Operators to use when preparing a
Site Protection and Monitoring Programme (SPMP) for Installations that require
reference data to be collected. It is designed to assist Operators with the
submission of the correct information in a suitable format to the EHS and should be
completed in full.
Where there are deficiencies or uncertainties in the information provided these

should be clearly marked and annotated to indicate where further data gathering may
Guidance on the Protection of Land Under the PPC Regime: Application Site
Report and Site Protection and Monitoring Programme
In the template, those parts written in italics and enclosed in square brackets (i.e.
[italics] ), indicate where relevant information and or assessment is required to be
entered. In entering this information the italics should be deleted along with the
brackets or written over and the text reformatted to normal style.
Where text in italics appears prefixed with the word “Note” in bold ( i.e. [NOTE:
italics] ) this provides guidance on filling in the relevant [italics] part. On completion
of the [italics] part the [NOTE: italics] should be deleted from the final report prior to
submission.
76
DESIGN OF A
SITE PROTECTION AND MONITORING PROGRAMME
FOR [installation name, operator]
REQUIRING REFERENCE DATA TO BE COLLECTED
[Date]
77
Contents
Summary
1.0 Introduction
2.0 Objectives
3.0 Intrusive Investigation to Collect Reference Data
3.1 Investigation and Sampling Strategy
3.1.1 General
3.1.2 Constraints on Investigations
3.1.3 Soil Investigation and Sampling Techniques and Protocols
3.1.4 Groundwater Investigation and Sampling Techniques and Protocols
3.1.5 Soil-Gas and Vapour Investigation and Sampling Techniques and
Protocols
3.1.6 Surface Water Investigation and Sampling Techniques and Protocols
3.1.7 Infrastructure Investigation and Sampling Techniques and Protocols
3.2.1 Zone 1
3.2.2 Zone 2 etc
3.3.1 Justification of Analytical Suites
3.3.2 Justification of Analytical Field Techniques and Detection Limits
3.3.3 Laboratory Accreditation / Quality Assurance and Quality Control
4.0 Monitoring Programme
4.1 Objectives of Monitoring Programme
4.1.1 Objectives of Environmental Monitoring Programme
4.1.2 Objectives of Infrastructure Monitoring Programme
4.2.1 Location
4.2.2 Groundwater monitoring
4.2.3 Soil Vapour Monitoring
4.2.4 Soil Monitoring
4.2.5 Procedure for the Inspection and Maintenance of Environmental
Monitoring Infrastructure
4.3.1 Monitoring Frequency
4.3.2 Analytical Suites
4.4 Infrastructure Monitoring Programme
78
4.5 Assessment and Reporting Procedures
4.5.1 Assessment Procedure

4.5.2 Reporting Procedure
4.5.3 Recording and Data Management
5.0 Other Issues
6.0 References
7.0 Glossary
Appendices
Appendix A - Figures and Plans
Appendix B - Investigation and Sampling Protocols
Appendix C - Analytical Protocols and Laboratory Accreditation
Appendix D - Quality Assurance and Quality Control
Appendix E - Inspection and Monitoring Protocols
Appendix F - Other Issues
79
Summary
This document represents the Site Protection and Monitoring Programme (SPMP) for
[installation site] submitted to the Environment and Heritage Service in pursuance of
Condition 4.1.7 of the Permit No. [Reference Number] (the "Permit") authorising the operation
of [the installation name] (the "installation").
This document is required to be submitted to the Agency within 2 months of the date of issue
of the Permit.
An intrusive investigation is required to be undertaken to characterise substances identified

as being potentially present in, on or under the ground in the Application Site Report (the
"ASR") submitted with the Permit Application. This document also contains the scope of those
investigations to collect Reference Data and should be read in conjunction with the ASR for
the installation.
The Environmental Monitoring Programme for the installation is presented in Section 4 and
Appendices B to E. The results of routine monitoring will be collated into a Monitoring Report
and sent to the EHS by the 31st of January each year. The Monitoring Report will also contain
any recommendations for changes to the Site Protection and Monitoring Programme which
will be incorporated into the SPMP subject to the agreement, in writing, of the EHS. The
format of the Monitoring Report is given in Appendix E3.
The testing, inspection and maintenance programme for pollution prevention infrastructure at
the site (the Infrastructure Monitoring Programme) has been designed as detailed in Section
4.4 and Appendix E2.
80
1.0 Introduction
[Enter details of persons and / or companies undertaking the assessments for the
applicant and any other relevant additional details.]
1.1 Site Location
The installation is located at [ADDRESS plus any further relevant location descriptor].
The centre of the site is at National Grid Reference [8-figure grid reference]. The site
covers an area of [enter area] Ha and can be seen in Figure 1 of Appendix A1.
1.2 Details of Installation
[Briefly describe the operations conducted under the permit referencing specific
sections of the ASR and permit application.]
[Identify any planned changes to operational layout or processes].
2.0 Objectives
¾ To design investigations to collect Reference Data for the installation by:
♦ Obtaining sufficient information with respect to the site to allow the refinement of
the conceptual model of the site and its surroundings.
♦ [Determining whether sufficient data exists from investigation works undertaken

on the site to collect Reference Data and adequately describe conditions at the
site.]
♦ [Designing a robust and adequate intrusive investigation, which would allow the
collection of Reference Data for the Installation.]
¾ To design a monitoring programme for the installation to:
♦ [Monitor the effectiveness of pollution prevention infrastructure and provide early

warning of any release of polluting substances to ground or groundwater.]
♦ [To collect data on the condition of the ground at the installation to assist in the
permit surrender process.]
♦ [To provide defensive monitoring at site boundaries for pollutant migration onto
the site of the installation.]
♦ [To monitor the movement of pollutants in the ground and / or groundwater

beneath the site of the installation.]
¾ To review and if necessary amend the inspection, testing and maintenance programme
for pollution prevention infrastructure at the installation to ensure their continued
integrity.
¾ [To satisfy the requirements of (insert other objectives if appropriate)]
81
3.0 Intrusive Investigations
The objectives of the intrusive investigation are:
¾ To collect data to reduce the uncertainties in the conceptual model presented as

Section 6 of the Application Site Report (ASR) submitted with the permit
application.
¾ To collect sufficient data on the potentially polluting substances identified in

Table D2 of Appendix D of the ASR in order to set Reference Data for the site.
¾ [To install permanent monitoring points to facilitate operational monitoring in line

with the recommendations contained in Section 4 below.]
3.1.1 General
[Include details on:
¾ The proposed start and finish dates of the investigation or investigations.

¾ A brief description of the personnel on site and their roles.
¾ A brief description of the work that will be undertaken.]
[NOTE: This investigation should be based upon the preliminary zoning of the site (if
applicable) detailed in Section 6.6 of the ASR]
[Detail any potential constraints upon the nature, aerial extent, scope, timings etc of the
investigation(s). For instance health and safety considerations limiting investigation and
sample collection, requirements within operational areas, avoiding compromising
bunding and other pollution control measures, known or suspected location of
underground tanks and services. Refer to specific Figures in Appendix A1].
[NOTE: Consideration must also be given to sensitive receptors and circumstances, for
instance avoiding creating preferential pathways for contaminant migration by
incorrectly installing boreholes.]
[Detail the range of investigation and sampling techniques to be used in the

investigation to sample and characterise soils. For each technique detail the reason for
its inclusion with respect to the ability to collect representative data and samples for the
strata and possible pollutants found at and beneath the site identified in the CSM or the
ASR and to the constraints identified in 3.1.2 above.
Refer to the relevant sections of the QA/QC plan in Appendix D to detail the controls
and checks on the sampling, sample handling and transport.]
[NOTE: In this context soils is taken to include all solid materials, not including
infrastructure at and below surface including made ground and geological materials.]
[Standard operating procedures for the use of the different techniques to be employed
at the site should be referenced and reproduced in Appendix B1.]
82
[As 3.1.3 but for any groundwaters (and associated dissolved, emulsified or free-
product pollutants) beneath the site identified as a pathway and / or receptor within the
conceptual model for the site.
Standard operating procedures for the use of the different techniques as employed at
the site should be referenced and reproduced in Appendix B2.]

Protocols
[As 3.1.3 but for soil-gas and vapours beneath the site if volatile or semi-volatile organic
chemicals or biodegradable pollutants are identified beneath the site.
[NOTE: Whilst such investigation and sampling of soil-gas and vapours may not be
required to collect reference data for the site, such results can be used to screen areas
of the site for elevated pollutants and target further investigations.]
[As 3.1.3 but for any surface waters (and associated dissolved, emulsified or free-
product pollutants) on the site identified as a pathway and / or receptor within the
[As 3.1.3 but for the investigation and testing of any process and pollution control
infrastructure. Include details on the accuracy of any integrity testing procedure, e.g.
minimum leakage rate detectable using that technique.
[NOTE: For all the different media above, if no such investigation and sampling
occurred then delete the relevant section and renumber the Appendices accordingly]
Sample locations were chosen with reference to the sources, pathways and receptors
identified within the conceptual model for the site detailed in Section 6 of the ASR.
Sample locations were [surveyed in / located using OS Digital Data / Topographic

Survey / GPS] and have a horizontal accuracy of [X units] and a vertical accuracy of
[Y units].
[NOTE: Delete as applicable]
Sample locations for the site are shown on Figure [insert figure number(s)] of
Appendix A1.
Discussion of the selection, justification and design for each sample location with
respect to individual zones for the site are given in the following sections.
83
Samples have been referenced using the following classification system:
[Detail classification scheme]
3.2.1 Zone 1
The sample locations for Zone 1 are shown on Figure [insert figure number] of
Appendix A1.
Sample location BH101
[Identify investigation technique by referencing protocol in Appendix B. Detail the

justification of choice of sample location e.g.:
¾ Sample location forms part of a non-targeted sampling pattern for background

pollutant levels or for widespread but variable pollutant levels across the zone;
¾ Sample location forms part of a targeted sampling strategy for identifying
elevated levels of pollutants associated with a particular source identified in
Table G1 of Appendix G.
Discuss the choice of location, the number of samples, the depths of samples and the
environmental media sampled with respect to the conceptual model and particular
source-pathway-receptor relationships.]
Sample location BH102
[As above.]
[NOTE: Justifications can be given for groups of samples relating to particular sources
or SPR relationships or other reasons identified from the conceptual model rather than
on a sample by sample basis. Each sample relating to a group must be referenced in
the particular section of the text.]
3.2.2 Zone 2
Sample locations for Zone 2 are shown on Figure [insert figure number] of
Appendix A1.
Sample Location BH201
[etc]
The analytical suite for each Zone was chosen by reviewing Table D2 of Appendix D of
the ASR and is shown in Tables C1 to C[insert table number] of Appendix C1.
[The conceptual model for the site indicated the potential for contaminant migration of
[List substance(s) or refer to table inserted below] in groundwater from areas adjacent
to the site. As a result these have been added to the relevant Table in Appendix C1 for
both soil and groundwater.]
[Due to the hydrogeological conditions beneath the site identified within the conceptual
model, there is the potential for the migration in groundwater of potentially polluting
substances from zone(s) x] to zone(s) y]. As a result, substances identified in Table D2
of Appendix D of the ASR for zone(s) x] have been added to the relevant Table in
Appendix C1 for both soil and groundwater.]
84
[NOTE: Delete as applicable. Where many similar substances are present

consideration can be given to analysis for groups of substances or indicative marker
species.]
3.3.2 Justification of Analytical / Field Technique and Detection Limits
The laboratory analytical technique for each analysis is referenced in Tables C1 to C[X]
[and is reproduced in Appendix C2]
[NOTE: If the technique is UKAS accredited then it is sufficient to include the UKAS
reference number in the relevant column of Tables C1 to C[X] in Appendix C. If the
laboratory does not have UKAS accreditation then the analytical method summary,
method validation test data and the on-going quality control method statements should
be reproduced in Appendix C2.]
Where field testing of samples has occurred, the standard operating procedure is
referenced in Tables C1 to C[X] and reproduced in Appendix C2.
Detection Limits for each analytical and field technique are shown in Tables C1 to C[X].
The following sections provide a justification for choosing a particular technique for a
particular substance in a particular phase. The detection limits of a substance using
that technique is justified with respect to expected background concentrations and
likely pollutant distribution and concentration.
[NOTE: Choice of analytical technique and thus detection limits should be made on a
site-specific basis. It is a general rule that as one lowers the detection limits one
increases the cost of analysis. The EHS has not set specific detection limits for the
preparation of a Site Protection and Monitoring Programme as such levels would,
necessarily, have to be the most stringent to be protective of the environment in all
cases. Careful consideration should be given to detection limits and the operator or
their consultants may wish to liaise with the EHS prior to undertaking site investigations
or analysis to agree them. Too high a limit could mask environmentally significant
pollutant distributions at the site. A statement of Reference Data using too high a limit
could, allow an unacceptable deterioration in land quality (through operations allowed
under the permit) up to that level. In such circumstances the EHS may not accept this
Scope SPMP and modifications could be required.]
3.3.2.1 Substance A
[Justify the choice of analytical technique for all phases of the substance (i.e. free-
product, dissolved in porewater / groundwater / surface water, sorbed to soil / rock
matrix, soil-gas or vapour). Justify detection limits with respect to collecting reference
data for the site. Discuss any potential issues with interference of the analytical
technique from other substances identified in Table D2 of Appendix D of the ASR.]
3.3.2.2 Substance B
[etc]
3.3.3.1 Laboratory Accreditation
All laboratory analytical techniques undertaken are within UKAS Accreditation.
[NOTE: or]
Tables C1 to C[X] detail which analytical techniques are UKAS accredited.
85
The Laboratory's quality assurance procedures for the individual techniques

undertaken outside UKAS accreditation is reproduced in Appendix C2]
[NOTE: UKAS Accreditation is the UK's recognised laboratory quality assurance

scheme and use of such laboratories is strongly advised as best practice.]
3.3.3.2 Quality Control
Appendix D1 contains the sampling and analytical quality assurance and quality control
plan.
[NOTE: Quality Control is typically measured by a combination of analytical checks,

which should be instigated either internally by the laboratory, or externally by the
Applicant. Such checks include duplicates, sample blanks, spiked samples, certified
and laboratory reference materials and spiked sample recovery. However the Applicant
must decide between which level of QC is achievable in theory, and which is
practicable and desirable in practice (e.g. cost constraints).]
4.1 Objectives of the Monitoring Programme
[Detail the objectives of the Environmental Monitoring Programme for the Installation
(see Section 5.3 of the "Guidance on the Protection of Land under the PPC Regime:
Application Site Report and Site Protection and Monitoring Programme")]
[Detail the objectives of the Infrastructure Monitoring Programme for the Installation
4.2.1 Location
Figure[(s) X to X] of Appendix A1 shows the proposed location of monitoring points at

the installation.
[NOTE: Figures must be at a scale such that the location of monitoring points could be
accurately determined on the ground. As such a number of Figures may be needed for
large installations]
No on-going groundwater monitoring will occur at the installation during the life of the
permit.
[Justify the lack of groundwater monitoring at the installation, refer to specific sections
above or within the ASR]
[NOTE: or]
The proposed completion details of each groundwater monitoring installation are

contained in Appendix E1. Each monitoring point will be finished with a lockable cover
and is designed to prevent the ingress of surface water.
86
[NOTE: Construction of new boreholes allows monitoring points to be located and

designed specifically to meet the monitoring objectives. The method of drilling, lining
materials, screen design and sealing method should all be given careful consideration
to ensure the monitoring objective are met. An existing monitoring point should only be
included in the programme if its construction and geological details have been
determined from records or geophysical logging.]
[Justify the proposed location of all groundwater monitoring points with respect to
specific monitoring objectives, and specific sources or pathways for pollution migration]
No on-going soil vapour monitoring will occur at the installation during the life of the
permit.
[Justify the lack of soil vapour monitoring at the installation, refer to specific sections
[NOTE: or]
Proposed completion details of each soil vapour monitoring installation are contained in
Appendix E1. Each installation will be finished with a lockable cover and designed to
prevent the ingress of surface water.
[NOTE: Soil vapour monitoring will not give quantitative data on land or groundwater
quality. With careful design, location and a suitable monitoring programme, it may
provide useful defensive monitoring for volatile and semi-volatile organic compounds
giving warning of a loss of containment.]
[Justify the location of all soil vapour monitoring points with respect to specific
monitoring objectives, and specific sources or pathways for pollution migration]
No on-going soil monitoring will occur at the installation during the life of the permit.
[Justify the lack of soil monitoring at the installation, refer to specific sections above or
within the ASR]
[NOTE: or]
The design and proposed completion details of soil monitoring points are contained in
Appendix E1.
[NOTE: Soil monitoring can be the repeated sampling and analysis of soil at a location.
However due to cost constraints it is recognised that soil monitoring is unlikely to be an
attractive or well used monitoring strategy. The installation of lysimeters (or other
unsaturated zone soil moisture monitoring equipment) may be a useful monitoring tool
given the right circumstances and such monitoring should be considered within this
section.]
[Justify the location of all soil monitoring points with respect to specific monitoring
objectives, and specific sources or pathways for pollution migration]
87

[Summarise the inspection, testing and maintenance procedure for monitoring

infrastructure and reference schedules and protocols for such works that should be
reproduced in Appendix E1]
[NOTE: Most groundwater monitoring boreholes will require periodic maintenance. The
most common problem is associated with silt accumulation in the base of a borehole,
which can completely block screened intervals. It is expected that the inspection
frequency will be high in the initial stages of the monitoring programme until the
characteristics of the deterioration in the performance of the infrastructure can be
ascertained.]
The proposed environmental monitoring programme, including QA/QC checks is

contained in Appendix E1 and is summarised below.
[Insert table summarising environmental monitoring programme, referencing sampling

protocol contained in Appendix B and summarised in Section 4.3.2 below]
[NOTE: The environmental monitoring programme shall include an emergency

monitoring plan to be enacted following:
• an incident at the installation resulting in an emission to land,
• pollution identified from environmental monitoring during the operation of the
installation or increasing from reference data levels,
• or if reference data shows pollution that is not attributed to non-permitted
sources.
This shall include an increased frequency of monitoring to facilitate identifying the

source and extent of any pollution and to determine whether remediation is required
under the PPC Regulations. See Section 5.3 of the Guidance on the Protection of Land
under the PPC Regime: Application Site Report and Site Protection and Monitoring
Programme]
4.3.2 Sampling and Analysis Protocols
The protocols for analysis will remain the same as those to be used for the
investigations to collect reference data detailed in Section 3.3 above and reproduced in
Appendix C.
[NOTE: or]
Different analytical protocols will be used for the regular environmental monitoring as
listed below and reproduced in full in Appendix C.
[Detail different protocols and justify their use on an environmental setting and
substance specific basis as per Sections 3.1 and 3.3 above]
Sampling protocols are contained within Appendix B.
4.3.3 Personnel Issues
Personnel responsible for sampling, maintenance and inspection will be trained in

environmental monitoring to an appropriate level to ensure compliance with the quality
88
assurance and quality control plan. Roles and responsibilities for monitoring and
ensuring adequate competence of staff are shown in Appendix E1.
The existing inspection, testing and maintenance of pollution prevention infrastructure

programme meets the objectives identified within Section 4.1.2 above and thus there
are no changes to the EMS programme for the installation summarised within the
Permit Application.
[NOTE: or]
This section summarises alterations to the infrastructure monitoring programme that

are detailed in Appendix E2.
[Summarise alterations to the existing inspection and testing programme.]
[NOTE: The SPMP is not intended to replace or reproduce an existing EMS.

HOWEVER the operator shall ensure, and demonstrate, that the changes identified
within this and preceding Sections are incorporated and implemented within the
existing inspection, testing and maintenance programme of an EMS.]
Personnel responsible for the inspection, testing and maintenance of pollution

prevention infrastructure are to be trained to an appropriate level to ensure compliance
with the Infrastructure Monitoring Programme. Roles and responsibilities for
undertaking the Programme (including reporting) and ensuring adequate competence
of staff are shown in Appendix E2.
[Detail the methods, and procedures for assessing monitoring data as a result of
operating this Site Protection and Monitoring Programme (within an overall EMS for the
installation.)]
[NOTE: It is certain that the concentration at each environmental monitoring location

will change for each monitoring round even if there are no anthropological influences
(e.g. due to seasonal variations, sample and analytical uncertainty etc). Monitoring data
should be assessed in a time series to determine the range of natural variation in
pollutant concentrations. Values should be set that trigger more intensive monitoring
and investigation if they are exceeded. The monitoring programme for the site should
be assessed in the light of the data it produces. It is hoped that the frequency of
monitoring would reduce as trends in pollutant concentrations are characterised and
improvements to pollution prevention infrastructure (if necessary) are shown to have
worked.]
Summaries of the monitoring data will be sent to the EHS on the 31st of January each
year along with the results of the data assessment, and any recommendations for
amendments to the Monitoring Programme.
[Detail the standard internal reporting procedure and responsibilities]
89
[Detail the emergency reporting procedures and responsibilities should monitoring,

testing and inspection demonstrate a loss of containment and / or pollution of ground or
groundwater.]
The formats for standard and emergency reporting procedures are shown in
Appendix E3.
[Detail the recording and data management procedures for environmental monitoring
data and the results of infrastructure monitoring and of emergencies.]
[NOTE: One of the purposes of the SPMP is to provide the operator with data to aid in
the process of surrendering of a Permit. In order to surrender a Permit the operator
must demonstrate to the EHS that the site is in a satisfactory state. A suitably designed
monitoring programme should provide sufficient data to demonstrate satisfactory state
without recourse to additional intrusive investigations. However this is encumbant upon
suitable procedures to record such data, or summaries thereof.]
5.0 Other Issues
[Detail other issues relevant to the protection of ground or groundwater within the
installation, such as general staff awareness and specific training. If necessary append
additional information within Appendix F]
6.0 References
[List references]
7.0 Glossary
[Include a glossary of terms]
[NOTE: The glossary should contain an explanation of all acronyms and industry
specific jargon used within the report]
90
APPENDIX A
FIGURES AND PLANS
Contents
A1 Plans
A2 Photographs
A3 Diagramatic Representations of Conceptual Site Model
91
APPENDIX B
INVESTIGATION AND SAMPLING PROTOCOLS
Contents
B1 Soil
B2 Groundwater
B3 Soil-gas and Vapours
B4 Surface Water
B5 Infrastructure
92
APPENDIX C
ANALYTICAL PROTOCOLS AND LABORATORY ACCREDITATION
Contents
C1 Tables
C2 Analytical Techniques
93
APPENDIX D
QUALITY ASSURANCE AND QUALITY CONTROL
Contents
D1 Sampling and Analytical Quality Assurance and Quality Control Plan
94
APPENDIX E
INSPECTION AND MONITORING PROTOCOLS
Contents
E1 Environmental Monitoring Protocols
E2 Infrastructure Monitoring Protocols
E3 Data Recording and Reporting Procedures
95
APPENDIX F
OTHER ISSUES
Contents
F1 [add title]
96
and Control (IPPC)
Template for
Design of a Site Protection and
Monitoring Programme for
Installations, that DO NOT
Require Reference Data to be
Collected
INTRODUCTION
This document presents a reporting template for Operators to use when preparing a
Site Protection and Monitoring Programme (SPMP) for Installations that do not
require reference data to be collected. It is designed to assist Operators with the
completed in full.

submission.
97
DESIGN OF
THAT DOES NOT REQUIRE REFERENCE DATA TO BE
COLLECTED
[Date]
98
Contents
Summary
1.0 Introduction
2.0 Objectives
3.0 Intrusive Investigation to Collect Reference Data
3.1.1 General
Protocols
3.2.1 Zone 1
3.2.2 Zone 2 etc
3.3.2 Justification of Analytical Field Techniques and Detection Limits
4.1 Objectives of Monitoring Programme
4.2.1 Location
4.3.2 Analytical Suites
99

5.0 Other Issues
6.0 References
7.0 Glossary
Appendices
Appendix D - Quality Assurance and Quality Control
Appendix E - Inspection and Monitoring Protocols
Appendix F - Other Issues
100
Summary
This document represents the Site Protection and Monitoring Programme (SPMP) for [name
installation] submitted to the Environment and Heritage Service in pursuance of Permit No.
[Reference Number] (the "Permit") authorising the operation of [the installation name] (the
"installation").
This design document is required to be submitted to the EHS within 2 months of the date of
issue of the Permit.
[An Environmental Monitoring Programme for the site is presented in Section 3 and
Appendices B to E. The results of routine monitoring will be collated into a Monitoring Report
and sent to the EHS on the 31st of January each year. The Monitoring Report will also
contain recommendations for changes to the Site Protection and Monitoring Programme (if
any) to be formally agreed, in writing, by the EHS. The format of the Monitoring Report is
given in Appendix E3.]
[NOTE: Whilst, by condition, the Permit does not require environmental monitoring there may
be good reasons for including such monitoring in the SPMP (see Section 5.3 of the "Guidance
on the Protection of Land under the PPC Regime: Application Site Report and Site Protection
and Monitoring Programme")]
[If no environmental monitoring is to occur then delete the relevant sub-sections of Section 3,
i.e. 3.1.1, 3.2 and 3.3]
The testing, inspection and maintenance programme for pollution prevention infrastructure at
the site (the Infrastructure Monitoring Programme) has been designed as detailed in Section
4.4 and Appendix E2.
101
1.0 Introduction
applicant and any other relevant additional details.]
1.1 Site Location
The centre of the site is at National Grid Reference [8-figure grid ref ]. The site covers
and area of [enter area] Ha and can be seen in Figure 1 of Appendix A1.
1.2 Details of Installation
[Briefly describe the operations conducted under the permit referencing specific
sections of the ASR and permit application.]
[Identify any planned changes to operational layout or processes].
2.0 Objectives
¾ To design a monitoring programme for the installation to:
♦ [Monitor the effectiveness of pollution prevention infrastructure and

provide early warning of any release of polluting substances to ground or
groundwater.]
♦ [To collect data on the condition of the ground at the installation to assist
in the permit surrender process.]
♦ [To provide defensive monitoring at site boundaries for pollutant migration

onto the site of the installation.]
♦ [To monitor the movement of pollutants in the ground and / or groundwater

beneath the site of the installation.]
¾ To review and if necessary amend the inspection, testing and maintenance

programme for pollution prevention infrastructure at the installation to ensure
their continued integrity.
¾ [To also satisfy the requirements of (insert other objectives if appropriate)]
[Detail the objectives of the Environmental Monitoring Programme for the Installation
102
[Detail the objectives of the Infrastructure Monitoring Programme for the Installation
3.2.1 Location
Figure[(s) X to X] of Appendix A1 shows the proposed location of monitoring points at

the installation.
large installations.
If monitoring of the media in the sub-sections below will not occur then delete that sub-
section and re-number the remaining sub-sections accordingly]
The proposed completion details of each groundwater monitoring installation are

contained in Appendix E1. Each monitoring point will be finished with a lockable cover
and is designed to prevent the ingress of surface water.

[Justify the proposed location of all groundwater monitoring points with respect to
specific monitoring objectives, and specific sources or pathways for pollution migration]
Proposed completion details of each soil vapour monitoring installation are contained in
Appendix E1. Each installation will be finished with a lockable cover and designed to
prevent the ingress of surface water.
The design and proposed completion details of soil monitoring points are contained in
Appendix E1.
unsaturated zone soil moisture monitoring equipment) may be a useful monitoring tool
103
section.]


reproduced in Appendix E1]
ascertained.]
The proposed environmental monitoring programme, including QA/QC checks is

contained in Appendix E1 and is summarised below.
[Insert table summarising environmental monitoring programme, referencing sampling

protocol contained in Appendix B and summarised in Section 3.3.2 below]
[NOTE: The environmental monitoring programme shall include an emergency

monitoring plan to be enacted following:
• an incident at the installation resulting in an emission to land,
• pollution identified from environmental monitoring during the operation of the
installation or increasing from reference data levels,
• or if reference data shows pollution that is not attributed to non-permitted
sources.
This shall include an increased frequency of monitoring to facilitate identifying the

source and extent of any pollution and to determine whether remediation is required
under the PPC Regulations. (see Section 5.3 (c) of the "Guidance on the Protection of
Land under the PPC Regime: Application Site Report and Site Protection and
Monitoring Programme")]
The protocols for analysis are summarised below and reproduced in Appendix C.
substance specific basis]
Sampling protocols are contained within Appendix B.

ensuring adequate competence of staff are shown in Appendix E1.
104
The existing inspection, testing and maintenance of pollution prevention infrastructure

programme meets the objectives identified within Section 3.1.2 above and thus there
are no changes to the EMS programme for the installation summarised within the
Permit Application.
[NOTE: or]
This section summarises alterations to the existing EMS that are detailed in
Appendix E2.
[NOTE: The SPMP is not intended to replace or reproduce an existing EMS.

HOWEVER the operator shall ensure, and demonstrate, that the changes identified
within this and preceding Sections are incorporated and implemented within the
existing inspection, testing and maintenance programme of an EMS.]

with the Infrastructure Monitoring Programme. Roles and responsibilities for
undertaking the Programme (including reporting) and ensuring adequate competence
of staff are shown in Appendix E2.
operating this Site Protection and Monitoring Programme (within an overall EMS for the
installation.)]
[NOTE: It is certain that the concentration at each environmental monitoring location

will change for each monitoring round even if there are no anthropological influences
(e.g. due to seasonal variations, sample and analytical uncertainty etc). Monitoring data
should be assessed in a time series to determine the range of natural variation in
pollutant concentrations. Values should be set that trigger more intensive monitoring
and investigation if they are exceeded. The monitoring programme for the site should
be assessed in the light of the data it produces. It is hoped that the frequency of
improvements to pollution prevention infrastructure (if necessary) are shown to have
worked.]
amendments to the Monitoring Programme.

groundwater.]
105
The formats for standard and emergency reporting procedures are shown in
Appendix E3.
[Detail the recording and data management procedures for environmental monitoring
data and the results of infrastructure monitoring and of emergencies.]
monitoring programme should provide sufficient data to demonstrate satisfactory state
without recourse to additional intrusive investigations. However this is encumbant upon
suitable procedures to record such data, or summaries thereof.]
4.0 Other Issues
additional information within Appendix F]
5.0 References
[List references]
6.0 Glossary
106
APPENDIX A
FIGURES AND PLANS
Contents
A1 Plans
A2 Photographs
107
APPENDIX B
SAMPLING PROTOCOLS
Contents
B1 Soil
B2 Groundwater
B4 Surface Water
B5 Infrastructure
108
APPENDIX C
Contents
C1 Tables
109
APPENDIX D
Contents
D1 Sampling and Analytical Quality Assurance and Quality Control Plan
110
APPENDIX E
Contents
E1 Environmental Monitoring Protocols
E2 Infrastructure Monitoring Protocols
E3 Data Recording and Reporting Procedures
111
APPENDIX F
OTHER ISSUES
Contents
F1 [add title]
112
and Control (IPPC)
Template for
First Phase Reporting of the Site
Protection and Monitoring
where Reference Data is
Required
INTRODUCTION
This document presents a reporting template for Operators to use when reporting the
first phase of a Site Protection and Monitoring Programme (SPMP) for Installations
that require reference data to be collected. It is designed to assist Operators with the
completed in full.

submission.
113
FIRST PHASE REPORTING OF THE
WHERE REFERENCE DATA IS REQUIRED
[Date]
114
Contents
Summary
1.0 Introduction
2.0 Intrusive Investigation
2.4 Findings of the Ground Investigation
2.4.1 Summary of Site Physical Conditions and refinement of Conceptual Site
Model
2.4.2 Zone 1
2.4.3 Zone 2 etc
2.5 Data Interpretation
2.5.1 Statistical Analysis of Data (including further delineation of Zones)
2.5.2 Confirmed Sources of Identified Elevated Levels of Pollutants
2.5.3 Unknown Sources of Identified Elevated Levels of Pollutants
3.0 Statement of Reference Data
5.0 Other Issues
6.0 References
7.0 Glossary
Appendices
Appendix D - Records of Investigation Findings
Appendix E - Analytical Data and Statistical Analysis
Appendix F - Quality Assurance and Quality Control
Appendix G - Baseline Conditions
115
Appendix H - Inspection and Monitoring Protocols
Appendix I - Other Issues
116
Summary
This document represents the first report of the Site Protection and Monitoring Programme
(SPMP) for [name site] submitted to the Environment and Heritage Service in pursuance of
Permit No. [Reference Number] (the "Permit") authorising the operation of [the installation
name] (the "installation").
An intrusive investigation was undertaken to characterise substances identified as being

present or potentially present in, on or under the ground in the Application Site Report (ASR)
submitted with the Permit Application. The scope of the investigation is detailed within the
Design SPMP submitted in pursuance of Condition 4.1.7 of the above mentioned Permit. This
document should be read in conjunction with both documents.
This report sets the reference data for the installation which are summarised in Section 4 and
Appendix G.
The monitoring programme for the site is presented in Section 4 of the Design SPMP.
[NOTE: or]
[As a result of the investigations the monitoring programme has been amended and is
provided as Appendix H to this document. This supercedes the Monitoring Programme in the
Design SPMP]
[NOTE: Delete as applicable]
117
1.0 Introduction
applicant and any other additional details.]
1.1 Site Location
The centre of the site is at National Grid Reference [8-figure grid reference ]. The site
covers and area of [enter area] Ha and can be seen in Figure 1 of Appendix A1.
2.0 Intrusive Investigations
The investigations and sampling undertaken at the site was in accordance with the
Section 3 and Appendices B, C and D of the Design SPMP.
[NOTE: or]
The following Sections detail variations to and deviations from the Design SPMP
[NOTE: Delete as applicable. If no amendments occurred to any of the elements below

then delete all the following sub-sections. However where amendments did occur to
some aspects, but no amendments occurred to a particular sub-section below then
make a statement to that effect.]
2.1.1 General
[Include amendments to:
¾ The start and finish dates of investigation or investigation.

¾ A brief description of the personnel on site and their roles.
¾ Weather conditions.
¾ A brief description of the work that was actually undertaken.]
[Detail any constraints upon the nature, aerial extent, scope, timings etc encountered
during the iinvestigation(s) that were not identified within the Scope. Refer to specific
Figures in Appendix A1].
[Include amendments to the investigation and sampling techniques used in the

investigation to sample and characterise soils. For each technique detail the reason for
its inclusion with respect to the ability to collect representative data and samples for the
strata and possible pollutants found at and beneath the site and to the constraints
identified in 3.1.2 above.
Refer to the relevant sections of the QA/QC plan in Appendix F to detail the controls
and checks on the sampling, sample handling and transport.]
[NOTE: In this context soil is taken to include all solid materials, not including
infrastructure at and below surface including made ground and geological materials.]
[New or modified standard operating procedures for the use of the different techniques
as employed at the site should be referenced and reproduced in Appendix B1.]
118
[As 2.1.3 but for any groundwaters (and associated dissolved, emulsified or free-
product pollutants) beneath the site identified as a pathway and / or receptor within the
New or modified standard operating procedures for the use of the different techniques

Protocols
[As 2.1.3 but for soil-gas and vapours beneath the site if volatile or semi-volatile organic
chemicals or biodegradable pollutants are identified beneath the site.
[As 2.1.3 but for any surface waters (and associated dissolved, emulsified or free-
product pollutants) on the site identified as a pathway and / or receptor within the
[As 2.1.3 but for the investigation and testing of any process and pollution control
infrastructure. Include details on the accuracy of any integrity testing procedure, e.g.
minimum leakage rate detectable using that technique.
The number and location of samples remain the same as agreed in the Design SPMP.
[or]
The following Sections detail those sample locations that deviate from those agreed in
the Design SPMP. The following table lists all sample locations agreed in the Design
SPMP and identifies all the amendments [and augmentations].
Sample locations were [surveyed in / located using OS Digital Data / Topographic

Survey / GPS] and have a horizontal accuracy of [X units] and a vertical accuracy of
[Y units]. Sample locations for the site are shown on Figure [insert figure number(s)] of
Appendix A1.
Discussion of the selection, justification and design for each additional or modified
sample location with respect to individual zones for the site are given in the following
sections.
Samples have been referenced using the classification system detailed in the Design
SPMP (Section 3.2)
119
Zone Sample Installed as Amended to Shown on Described in

Number Agreed (Y/N) (Sample Number) Figure Appendix
1 BH101 N BH101A A1 D1
BH102 Y A1 D1
WS101 N WS101A A1 D2
2 BH201 Y A2 D1
etc
[NOTE: Delete as applicable. Table above is filled in as an example]
The findings of investigations are discussed in Section 2.4 below and all physical
ground results (borehole logs, trial pit logs, etc) are reproduced in Appendix D.
[2.2.1 Zone 1
The modified sample locations for Zone 1 are shown on Figure [insert figure number] of
Appendix A1.]
[Sample location BH101A
Identify investigation technique by referencing protocol in Appendix B. Detail the

justification of choice of sample location and the reason for the deviation from the
agreed Design SPMP e.g.:
¾ Inability to penetrate difficult ground causing a new location to be chosen to

replace Borehole BH101.
¾ The PID and FID results from BH101 along with drill returns indicated the
presence of potentially large volumes of volatile organic pollution in the
subsurface. Boreholes BH101A, B and C were installed to investigate the extent
of the pollution and to identify the source. NOTE: See comments in Section 5 of
the Guidance on Producing a SPMP.
Discuss the choice of location, the number of samples, the depths of samples and the
environmental media sampled with respect to the conceptual model and particular
source-pathway-receptor relationships.
Sample location WS101
As above.]
[NOTE: Justifications can be given for groups of samples relating to particular sources
or SPR relationships or other reasons identified from the conceptual model rather than
on a sample by sample basis. Each sample relating to a group must be referenced in
the particular section of the text.]
[2.2.2 Zone 2
The modified sample locations for Zone 2 are shown on Figure [insert figure number] of
Appendix A1.
Sample Location BH201]
[etc]
120
The analytical suites agreed in the Design SPMP were used in the analysis of samples
from the investigation to collect reference data.
[or]
The analytical suite for each Zone was modified for the following reasons. They are
shown in Tables C1 to C[insert table number] of Appendix C1.
[NOTE: Delete as applicable. Justify any modifications to the analytical suites in section
2.3.2 below]
2.3.2 Justification of Analytical / Field Technique and Detection Limits
The laboratory / field analytical techniques and detection limits for each analysis were
as agreed in the Design SPMP.
[or]
The following sections identify modifications to the laboratory / field analytical

techniques and detection limits agreed in the Design SPMP.
[NOTE: If the technique is UKAS accredited then it is sufficient to include the UKAS
reference number in the relevant column of Tables C1 to CX in Appendix C. If the
laboratory does not have UKAS accreditation then the analytical method summary,
method validation test data and the on-going quality control method statements should
be reproduced in Appendix C2.]
Detection Limits for each modified analytical and field technique are shown in Tables
C1 to C[X].
The following sections provide a justification for modifying a particular technique for a
particular substance in a particular phase. Any resultant modification to the detection
limits of a substance using that technique is justified with respect to expected
background concentrations and likely pollutant distribution and concentration.
[NOTE: Choice of analytical technique and thus detection limits should be made on a
site-specific basis. Careful consideration should be given to detection limits and the
operator or its consultants may wish to liaise with and seek the Agency's agreement
prior to undertaking site investigations or analysis. It should be noted that the use of too
high a limit could mask environmentally significant pollutant distributions at the site,
making it more difficult to assess the impact of any pollution which occurs from the
permitted installation In such circumstances the Agency might not accept the SPMP
and additional investigations / analysis might be required.]
2.3.2.1 Substance A
[Justify the modification to the analytical technique for all phases of the substance (i.e.
free-product, dissolved in porewater / groundwater / surface water, sorbed to soil / rock
matrix, soil-gas or vapour). Justify detection limits with respect to collecting reference
data for the site. Discuss any potential issues with interference of the analytical
technique from other substances identified in Table G1 of Appendix G.]
121
2.3.2.2 Substance B
[etc]
2.3.3.1 Laboratory Accreditation
[All laboratory analytical techniques undertaken are within UKAS Accreditation.]
or
[Tables C1 to C(X) detail which analytical techniques are UKAS accredited.
The Laboratory's quality assurance procedures for the individual techniques

undertaken outside UKAS accreditation is reproduced in Appendix C2]
[NOTE: It is not yet EHS policy to insist upon the use of laboratories with UKAS
Accreditation for each specific laboratory analysis for soil sampling. However the UKAS
Accreditation is the UK's recognised laboratory quality assurance scheme and use of
such laboratories is strongly advised as best practice.]
2.3.3.2 Quality Control
There were no modifications to the agreed sampling and analytical quality assurance
and quality control plan and Appendix F2 the results obtained from the QC plan.
[Discuss the findings of the QC plan with respect to the implications on the reliability
and accuracy of the analytical results presented as the statement of baseline condition.
If analysis data is presented in Appendix E which fell outside of the UKAS
Accreditation, the reason for the failure should be indicated in the relevant part of
Appendix F. The implications of this failure of analytical quality control on reliability of
the analytical result must be discussed within this and Section 2.5.1 below.]
[NOTE: Quality Control is typically measured by a combination of analytical checks,

which should be instigated either internally by the laboratory, or externally by the
Applicant. Such checks include duplicates, sample blanks, spiked samples, certified
and laboratory reference materials and spiked sample recovery. However the Applicant
must decide between which level of QC is achievable in theory, and which is
practicable and desirable in practice (e.g. cost constraints).]
2.4 Findings of the Ground Investigation
2.4.1 Summary of Site Physical Conditions and Refinement of Conceptual Site

Model.
[Briefly outline the results of the physical investigation for the site as a whole. e.g.
¾ Presence / absence, thickness and physical properties of made ground,

¾ Thickness and physical properties of different geological strata,
¾ Presence / absence and depth to water table,
¾ Groundwater flow directions,
¾ Confirmation of, or changes, to the physical site conceptual model.]
122
2.4.2 Zone 1
[Detail the findings and observations from the investigation within zone 1. Refer to
photographs reproduced within Appendix A2 to illustrate points, pollutant sources,
ground and contaminant conditions at sample locations referring to the full data set
reproduced within Appendix E. Refer to specific borehole logs, trial pit logs or the
results and interpretations of other investigation techniques (if appropriate) reproduced
within Appendix D.]
[Detail the pollutant concentrations and distributions for the different geological strata
and groundwater(s) within the zone. Refer to Figures and Plans showing contaminant
concentration variations across the zone to be included in Appendix A3.]
[NOTE: Only include Figures to illustrate particular points or for those pollutants with
elevated and variable concentrations.]
2.4.3 Zone 2
[As Above
etc]
2.5 Data Interpretation
[NOTE: The purpose of this Section is to examine the analytical data collected for each
zone to determine whether it is sufficient to adequately characterise baseline conditions
at the site]
2.5.1 Statistical Analysis of Data
2.5.1.1 Zone 1
[Discuss the need for any subdivision of the zone on the basis of the occurrence and
distribution of pollution.]
[NOTE: It is necessary to examine the analytical data to determine whether any sample
location represents a hot-spot of pollution associated with a particular source or
sources. If a sample or (group of samples) is a hot-spot (i.e. from a different data
population) then the zone should be sub-divided into two zones, one enclosing the hot
spot. The spatial distribution of the data should be assessed to determine whether
sufficient data exists to delineate this new zone(s). If not, further investigation and
sampling may be required. The new zone(s) should be numbered in a way so as to
avoid confusion with the existing zoning of the site (e.g. Zone 1A, 1B etc). The new
zones should be shown in Figures in Appendix A3.]
2.5.1.2 Zone 2
[As Above]
2.5.2 Confirmed Sources of Identified Elevated Levels of Pollutants
[All known sources of elevated levels of pollutants within the zones should be identified
at this stage (from the assessments in Section 3.5.1 above along with a reasoned
assessment of the implications for operations to be conducted under the permit. For
instance:
Pollution is identified from activities that will continue under the terms of a
permit: The cause of the pollution should be identified. Any necessary improvements
to an EMS or pollution control or other infrastructure to prevent any further pollution
123
should be identified within Section 6 below (or cross reference to relevant parts of
permit application/application site report). It is considered that operational monitoring
(of ground or groundwater to determine the effectiveness of these improvements)
should always be designed and undertaken as part of the EMS for the installation
under these circumstances.
Pollution is identified from activities that will not continue (historic activities)
under the terms of a permit: The cause of the pollution should be identified and it
should be confirmed that there is no potential for additional pollution from that source.
Other potential source(s) of the same pollutant within the zone will continue or come
into operation under the terms of a permit. The implications for the requirements for
operational records and to the EMS to aid in an eventual permit surrender process
should be discussed in Section 5 below.
Pollution is identified that has migrated onto or beneath the site of the
installation from adjacent activities: The cause of the pollution should be identified
or hypothesised. There is / are potential source(s) of the same pollutant within the zone
that will continue or come into operation under the terms of a permit. The implications
for the requirements for operational records, operational monitoring and to the EMS to
aid in the permit surrender process should be discussed in Section 5 below.]
2.5.3 Unknown Sources of Identified Elevated Levels of Pollutants
The sources of all elevated levels of pollutants within the ground or groundwater have
been identified and attributed within Section 3.5.2 above.
[NOTE: or]
[This section should identify areas of pollution where the source is unknown / uncertain
and could be a result of activities which are now covered by the Permit. If known,
potential sources of the pollutants should be detailed along with an assessment of the
data required to prove or disprove those sources]
[NOTE: In completing this and the preceding section it must be emphasised that
only those substances used (etc) under the terms of the permit will have been
investigated for. The EHS will therefore conclude that the permitted activities are
the source of the pollution unless an alternative source is confirmed. It will not be
considered sufficient to hypothosise an alternative source without direct physical or
documentary evidence. Statements of the integrity of pollution prevention infrastructure
will not suffice to exclude permitted activities if an alternative source is not proved.]
3.0 Statement of Reference Data
Reference Data for the site have been collected by this report and are presented in
summary as Appendix G2.
[NOTE: As detailed in Section 6 of the " Guidance on the Protection of Land under the
PPC Regime: Application Site Report and Site Protection and Monitoring Programme",
Reference Data are collected for the installation at the time sampling, investigation,
monitoring and / or testing occurs. They are not set at the date six months after the
issue of the permit or the date at which the SPP is received by the EHS (if different).]
4.0 Inspection and Monitoring Programme
The investigations to collect reference data have not led to any amendments to the
monitoring and inspection programme.
[or]
124
As a result of the investigations to collect reference data and install environmental

monitoring infrastructure the Monitoring Programme has been modified as follows
[NOTE: Delete as applicable. If no amendments occurred to any of the elements below

then delete all the following sub-sections. However where amendments did occur to
some aspects, but no amendments occurred to a particular sub-section below then
make a statement to that effect.]
4.1.1 Objectives of the Environmental Monitoring Programme
[Detail any modifications to the objectives of the Environmental Monitoring Programme

for the Installation (see Section 6.3 of the " Guidance on the Protection of Land under
the PPC Regime: Application Site Report and Site Protection and Monitoring
Programme")]
4.1.2 Objectives of the Infrastructure Monitoring Programme
[Detail any modifications to the objectives of the Infrastructure Monitoring Programme

Programme")]
4.2.1 Location
Modifications to the agreed environmental monitoring infrastructure are shown on

Figure[(s) X to X] of Appendix A1. These figures show the location of all environmental
monitoring points at the installation.
large installations]
The log and completion details of each groundwater monitoring installation are
contained in Appendix H1. Each monitoring point is finished with a lockable cover and
is designed to prevent the ingress of surface water.

[Justify any modifications to the location of all groundwater monitoring points with
respect to specific monitoring objectives, and specific sources or pathways for pollution
migration]
No on-going soil vapour monitoring will occur at the installation during the life of the
permit.
125
[Justify the lack of soil vapour monitoring at the installation, refer to specific sections
[NOTE: or]
[Logs (if applicable) and] completion details of each soil vapour monitoring installation
are contained in Appendix H1. Each installation is finished with a lockable cover and
designed to prevent the ingress of surface water drainage.
No on-going soil monitoring will occur at the installation during the life of the permit.
[Justify the lack of soil monitoring at the installation, refer to specific sections above or
within the ISR]
[NOTE: or]
The design and completion details of soil monitoring points are contained in
Appendix H1.
unsaturated zone moisture monitoring equipment) may be a useful monitoring tool
section.]
4.2.5 Procedure for the Inspection and Maintenance of Monitoring

Infrastructure

reproduced in Appendix H1]
ascertained.]
The monitoring programme, including QA/QC checks is contained in Appendix H1 and

is summarised below.
126
[insert table summarising monitoring programme, referencing sampling protocol

contained in Appendix B and summarised in Section 5.3.2 below]
The protocols for analysis remain the same as those used for the investigations to
determine baseline conditions detailed in Section 3.3 above and reproduced in
Appendix C.
[NOTE: or]
Different analytical protocols were used for this additional round of investigation as
listed below and reproduced in full in Appendix C.
substance specific basis as per Sections 3.1 and 3.3 above]
Sampling protocols are contained within Appendix H1.

ensuring adequate competence of staff are shown in Appendix H1.
The infrastructure monitoring programme meets the objectives identified within Section
5.1.2 above and thus there are no changes to the EMS programme for the installation
summarised within the Permit Application.
[NOTE: or]
This section summarises alterations to the inspection, testing and maintenance

programme that are detailed in Appendix H2.
[NOTE: The SPP is not intended to replace or reproduce an existing EMS. HOWEVER
the operator shall ensure, and demonstrate, that the changes identified within this and
preceding Sections are incorporated and implemented within the existing inspection,
testing and maintenance programme.]

with the Programme. Roles and responsibilities for undertaking the Programme
(including reporting) and ensuring adequate competence of staff are shown in
Appendix H2.
operating this Site Protection Plan within an overall EMS for the installation.]
127
[NOTE: It is certain that the concentration at each monitoring location will change for
each monitoring round even if there are no anthropological influences (e.g. due to
seasonal variations, sample and analytical uncertainty etc). Monitoring data should be
assessed in a time series to determine the range of natural variation in pollutant
concentrations. Values should be set that trigger more intensive monitoring and
investigation if they are exceeded. The monitoring programme for the site should be
assessed in the light of the data it produces. It is hoped that the frequency of
improvements to pollution prevention infrastructure (if any were necessary) are shown
to have worked.]
amendments to the monitoring programme.

groundwater.]
The formats for standard and emergency reporting procedures are shown in Appendix
H3.
[Detail the recording and data management procedures for monitoring data and the
results of inspection and testing of pollution prevention infrastructure and of
emergencies.]
monitoring, testing and inspection programme should provide sufficient data to
demonstrate satisfactory state without recourse to additional intrusive investigations.
However this is incumbent upon suitable procedures to record such data, or summaries
of such data.]
5.0 Other Issues
additional information within Appendix I]
6.0 References
[List references]
7.0 Glossary
[NOTE: The glossary should contain an explanation of all acronyms and industry specific
jargon used within the report]
128
APPENDIX A
FIGURES AND PLANS
Contents
A1 Plans
A2 Photographs
129
APPENDIX B
INVESTIGATION AND SAMPLING PROTOCOLS
Contents
B1 Soil
B2 Groundwater
B4 Surface Water
B5 Infrastructure
130
APPENDIX C
Contents
C1 Tables
131
APPENDIX D
RECORDS OF INVESTIGATION FINDINGS
Contents
D1 [e.g. Borehole Logs]
D2 [e.g. Trial Pit Logs]
D3 [e.g. Results of Historical Desk Study]
D4 [e.g.
D5
132
APPENDIX E
ANALYTICAL DATA AND STATISTICAL ANALYSIS
Contents
E1 [e.g. Zone 1]
E2 [e.g. Zone 2]
E3 [e.g. etc
133
APPENDIX F
Contents
F1 Sampling and Analytical Quality Assurance and Quality Control Plan
F2 Results of the Sampling and Analytical Quality Assurance and Quality Control Plan
134
APPENDIX G
REFERENCE DATA
Contents
G1 Chemical Inventory for Installation
G2 Reference Data
135
APPENDIX H
Contents
H1 Monitoring Protocols
H2 Inspection, Testing and Maintenance Protocols
H3 Reporting Procedures
136
APPENDIX I
OTHER ISSUES
Contents
I1 [add title]
137
and Control (IPPC)
Template for
First Phase Reporting of the Site
Protection and Monitoring
where Reference Data is NOT
Required
INTRODUCTION
This document presents a reporting template for Operators to use when reporting the
first phase of a Site Protection and Monitoring Programme for installations that do not
require reference data to be collected. It is designed to assist Operators with the
completed in full.

submission.
138
FIRST PHASE REPORTING OF THE
REFERENCE DATA IS NOT REQUIRED
[Date]
139
Contents
Summary
1.0 Introduction
3.0 Other Issues
4.0 References
5.0 Glossary
Appendices
Appendix B - Inspection and Monitoring Protocols
Appendix C - Other Issues
140
Summary
This document represents the first report of the Site Protection and Monitoring Programme
(SPMP) for [name installation] submitted to the Environment and Heritage Service in
pursuance of Permit No. [Reference Number] (the "Permit") authorising the operation of
[installation name] (the "installation").
The scope of this monitoring is detailed within the Design SPMP submitted in pursuance of
Condition 4.1.7 of the above mentioned Permit. This document should be read in conjunction
with both documents.
The monitoring programme for the site is presented in Section 3 of the Design SPMP.
141
1.0 Introduction
applicant and any other additional details.]
1.1 Site Location
The centre of the site is at National Grid Reference [8-figure grid reference ]. The site
covers and area of [enter area] Ha and can be seen in Figure 1 of Appendix A1.
[Detail any modifications to the objectives of the Infrastructure Monitoring Programme

Programme ")]
The monitoring programme, including QA/QC checks is contained in Appendix B1 and

is summarised below.
[insert table summarising monitoring programme, referencing sampling protocol

contained in Appendix B and summarised in Section 5.3.2 below]
The infrastructure monitoring programme meets the objectives identified within Section
2.1 above and thus there are no changes to the Design SPMP for the installation.
[NOTE: or]
This section summarises alterations to the inspection, testing and maintenance

programme that are detailed in Appendix B2.
[Summarise alterations to the Design SPMP.]

with the Programme. Roles and responsibilities for undertaking the Programme
(including reporting) and ensuring adequate competence of staff are shown in
Appendix B2.
operating this Site Protection Plan within an overall EMS for the installation.]
142
amendments to the monitoring programme.

groundwater.]
The formats for standard and emergency reporting procedures are shown in Appendix
B3.
[Detail the recording and data management procedures for monitoring data and the
results of inspection and testing of pollution prevention infrastructure and of
emergencies.]
monitoring, testing and inspection programme should provide sufficient data to
demonstrate satisfactory state without recourse to additional intrusive investigations.
However this is incumbent upon suitable procedures to record such data, or summaries
of such data.]
3.0 Other Issues
additional information within Appendix C]
4.0 References
[List references]
5.0 Glossary
143
APPENDIX A
FIGURES AND PLANS
144
APPENDIX B
Contents
B1 Monitoring Protocols
B2 Inspection, Testing and Maintenance Protocols
B3 Reporting Procedures
145
APPENDIX C
OTHER ISSUES
Contents
C1 [add title]
146

Guidance On The Protection of Land Under The PPC Regime

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Technical Guidance Note

Integrated Pollution Prevention

and Control (IPPC)

Protection of Land Under the

Application Site Report and

Site Protection and Monitoring

1.1 What is an Application Site Report ? 1

1.2 Which Sites Does This Apply To? 1

2.0 How to Use This Guidance 2

3.0 Framework for the Protection of Land under PPC 3

3.1 Application Site Report 3

3.2 Two Months After Permit Issue 6

3.3 Six Months After Permit Issue 7

3.4 Life of the Permit 7

GUIDANCE ON THE PREPARATION OF AN APPLICATION SITE REPORT

4.0 Stage 1 – Preparation of an Application Site Report 8

4.2 Step 1 – Site Environmental Setting and Pollution History 9

4.3 Step 2 – Identify Potentially Polluting Substances 11

4.4 Step 3 – Identify Pollution Prevention Measures 12

4.5 Step 4 – Assess the effectiveness of the

Pollution Prevention Measures 16

4.6 Step 5 – Conceptual Site Model 23

4.7 Step 6 – Reporting 26

GUIDANCE ON THE PREPARATION AND IMPLEMENTATION OF A SITE PROTECTION

5.0 Stage 2 – Designing a Site Protection and Monitoring Programme 29

5.2 Step 1 – Designing an Investigation to Collect Reference Data 30

5.3 Step 2 – Designing the Monitoring Programme 33

5.4 Step 3 – Designing an Information and Data Management and

5.5 Step 4 – Reporting 38

6.0 Stage 3 – Implement the Site Protection and Monitoring Programme 39

Monitoring Programme SPMP 39

6.4 Step 3 – Reporting 40

Appendix A What are Reference Data ?

Table 1 Information Requirements for Step 1 including Site Reconnaissance

Box 1 Example where environmental monitoring would normally be required –

1.1 What is an Application Site Report?

1.2 Which Sites Does This Apply To?

The Groundwater Directive (80/68/EEC), as implemented by the Groundwater Regulations

2.0 How to use this guidance

The guidance is broken down as follows:

Background Provides background information on the

Guidance on the Preparation of an ASR Detailed guidance on how to prepare an

Guidance on the Preparation and Detailed guidance on how to design and

Template for an Application Site Report in PPC Applications

Design of a Site Protection and Monitoring Programme for Installations Requiring

Reference Data to be Collected

Require Reference Data to be Collected

where Reference Data is Required

where Reference Data is NOT Required

3.0 Framework for the Protection of Land

3.1 Application Site Report (ASR)

A completed ASR must:

a) Identify the environmental setting and pollution history of the installation.

c) Identify preventative measures that are in place to protect the land.

made in relation to the installation including:

− the inventories (quantities and types) of substances held on the site;

Two Months after Permit Issue - SPMP submitted to the EHS

If the EHS agrees with the assessment that there is: