Environmental Permitting – EPR H1 Groundwater Risk Assessment

Environmental Permitting Regulations (EPR) 2010 govern discharges to groundwater. The Environment Agency (EA) has jurisdiction over environmental permitting, and has published a series of technical guidance documents, ‘Horizontal Guidance’, for all sectors regulated under EPR.

Within this guidance, the H1 Environmental Risk Assessment framework and supporting technical annexes help to assess risks to the environment and human health from specific activities such as the discharge of treated effluent to groundwater. Applications for discharge activities may require a permit, or be exempt? BOLD is able to provide advice at different stages of the Environmental Permitting process; so whatever the specifics of your activity we can offer:

  • Advice on whether your activity is Exempt, or requires a Standard or Bespoke Permit?
  • Advice on what the permit application or communications from the EA are actually asking you to provide?
  • Liaison with the local EA Technical Specialists (in groundwater or surface water);
  • EPR H1 Groundwater Risk Assessment (for when bespoke permit applications are required);
  • Completion of Annex J5: Infiltration Worksheet (the preferred risk assessment model to complete the EPR H1 Groundwater Risk Assessment process);

Although several hydrogeological groundwater risk assessment models are available, the EA prefers completion of their own Infiltration Worksheet when considering permit applications for discharges to groundwater. Bold suggests this is the best course of action to assist the application process.

This can involve changing environmental parameters such as the permeability of the receiving soils or aquifer; for example if you do not have bespoke field measurements then testing a range of values (sensitivity analysis) could provide the EA with the assurance they need that potential risk has been examined.... without undertaking site specific investigation. Sensitivity analysis can also be used to examine the risk of fluctuation in the concentration of final treated effluent; for example, what happens if your package treatment plant should temporarily fail?

  • Reporting of the Risk Assessment Outcome posed by the discharge activity (in a format to append to your permit application).

Our approach will involve concise communication with the EA to ensure upfront agreement on key aspects such as the Conceptual Site Model (Source-Pathway-Receptor) and on the key input parameters such as chemical species to be assessed and the Compliance Point at which the risk will be benchmarked. It is our experience that early discussions with the EA Technical Specialists are always helpful for all concerned and eradicate potentially costly delays during the permitting process.

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