When is a site condition report required?
In principle, a site condition report (SCR) is required for any facility regulated under the Environmental Permitting Regulations where there may be a significant risk to land or groundwater.
What is a site condition report?
An SCR describes and records the condition of the land and groundwater at a site at particular points in time. It will enable you to demonstrate that you have protected land and groundwater during the lifetime of the site and that the land is in a satisfactory state when you come to surrender your permit.
You can demonstrate this by:
- Producing the application part of the SCR when you first apply for an environmental permit. For installations subject to the IED this will satisfy the requirements to provide a “baseline report”.
- Updating the SCR during the lifetime of your permit as appropriate.
- Completing the surrender parts and submitting the fully completed SCR when you
apply to surrender your environmental permit. In the last part of the SCR, you will
describe what condition the land and groundwater are in at the time of surrender. If the land and groundwater are not in a satisfactory state, we will not accept your application to surrender your environmental permit.
Why do you need to produce a Site Condition Report?
It is in your own interest as an operator to produce a site condition report. An alternative approach would be for you to assume that the site is completely uncontaminated, irrespective of its previous history, but that would mean that any contamination by substances used at, produced or released from the installation that is discovered when you applied to surrender your permit would be considered to have resulted from your operation of your installation. You would then potentially be liable for remediation work, and would be unable to surrender your permit until you had completed it satisfactorily.
You therefore need a point of reference at the start of operations or at the time the permit is issued so that when you want to surrender the permit you can demonstrate whether there has been any contamination of the site due to your operations, and ensure that the condition of the land and groundwater are in a “satisfactory state” when you apply to surrender the permit.