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Guidance: Develop a management system: environmental permits

Environment Agency

August 31
08:00 2022

Your environmental permit requires you to have a written management system. This is a set of procedures describing what you will do to minimise the risk of pollution from the activities covered by your permit.

If you have a waste permit that was granted before 6 April 2008 that does not require you to have a working plan or management system, you will still need to manage and operate your waste activity in line with a written management system.

If you are applying for:

  • a standard rules permit, the risks are identified in the generic risk assessment
  • a bespoke permit, you will have identified the risks by carrying out your risk assessment

Your risk assessment will be part of your management system.

You must submit a summary of your management system as part of your application if you are applying for a bespoke permit. You do not need to do this if you submit a B6.5 or B6.6 application form for a standalone water discharge or a groundwater activity, but you must have your management system in place before you start operating.

You do not have to submit a summary of your management system if you are applying for a standard rules permit, but you must have your management system in place before you start operating.

If you are applying for a standard rules permit for waste activities and plan to store combustible waste you will need to submit a fire prevention plan as part of your application.

Once you are operating you must implement your management system or you will be in breach of your permit.

What to put in your management system and how to organise it

The amount of information you will need in your management system will depend on how complicated and risky your activities are.

If your permit is for low-risk activities, for example a small sewage treatment works, your management system can be simple.

If you have a number of permits they may be covered by an overall management system. You may carry out certain things in the same way at different permitted sites and you may also have site specific procedures.

You need to be able to explain what happens at each site and which parts of the overall management system apply. For example at some sites you may need to show you are carrying out additional measures to prevent pollution because they are nearer to sensitive locations than others.

How to develop your management system

You can develop and maintain your own management system or use an environmental management system scheme or standard.

If you have a larger site or carry out a more complex activity (like installations and waste operations dealing with hazardous waste), the Environment Agency prefers management systems:

  • based on a recognised standard
  • independently checked by an accredited body

An environmental management system may be certified against a standard such as ISO 14001. The organisation or individual carrying out certification may be accredited by a National Accreditation Body such as the UK Accreditation Service (UKAS).

Using an accredited certified management system is not a guarantee that you will meet all of your permit conditions. You are still responsible for implementing your system effectively and making sure you comply with each permit condition.

However, the independent checks carried out for an accredited certified scheme or standard should result in greater confidence in your management system, and in your management of compliance. This may lead to fewer checks from the Environment Agency.

Confirm on your application form if you are using any of the following as the basis for your management system:

Prepare your site infrastructure plan

If you are applying for a permit for a standalone water discharge activity or a point source standalone groundwater activity, you only need to read the section on Water discharge and groundwater activity.

Your management system must include a plan of your site, drawn to scale.

The plan must highlight where you do the activities covered by your permits (and any exemptions you have registered).

Waste, installations and mining waste permits

Your plan must also show any:

  • buildings, and other main constructions, like treatment plants, incinerators, storage silos and security fences
  • storage facilities for hazardous materials like oil and fuel tanks, chemical stores, waste materials
  • location of items for use in accidents and emergencies, like absorbants for chemical spills
  • entrances and exits that can be used by emergency services
  • points designed to control pollution, for example inspection or monitoring points
  • trade effluent or sewage effluent treatment plants
  • effluent discharge points
  • land that you believe is contaminated, for example areas of your site that have previously been used for industrial purposes

Vulnerable locations

Your plan must also show areas particularly vulnerable to pollution that are on or near to your site, for example:

  • rivers or streams
  • groundwater used for drinking water
  • residential, commercial or industrial premises
  • areas where wildlife is vulnerable or protected

Use therisk assessment guideto help you think about areas that are vulnerable to pollution.

Drainage

Your plan must show your foul and combined drainage facilities marked in red and your surface water drainage, facilities marked in blue.

It must also show:

  • the direction of flow of the water in the drain
  • the location of discharge points to the sewer, watercourse or soakaway
  • the location of manhole covers and drains
  • the location of stop and diverter valves and interceptors

Water, gas, electricity

Your plan must show the location of mains water, gas and electricity supplies on your site, including:

  • the mains water stop tap
  • gas and electric isolating valves and switches
  • the routes for gas, electricity and water supplies around your site - electric wiring and gas and water pipes must be labelled on the plan

Water discharge and groundwater activity

If you are applying for a permit for a standalone water discharge activity or a point source standalone groundwater activity your site plan must show:

  • your wastewater treatment plant
  • monitoring points - the locations from which you will take samples to check for contaminants or pollutant substances as required by your permit
  • the location of emergency equipment
  • the location of any mitigation measures referred to in your management system
  • the outlet to surface water (standalone water discharges only)
  • the infiltration system (standalone groundwater activity only)

If you are applying for a permit for a standalone groundwater activity where you are land spreading, your site plan must show:

  • the field locations for spreading
  • monitoring points - the locations from which you will check your discharge for contaminants or pollutant substances as required by your permit
  • the location of emergency equipment
  • the locations of any pollutant storage areas linked to your permit

Site operations

Break down the operations that will be carried out on your site during start up, normal operation and shut down, into a list of activities and processes, for example unloading waste, storing waste, incinerating waste.

For waste, mining waste, and installations, list the wastes that will be produced by each activity or process.

List the steps you will take to prevent or minimise risks to the environment from each activity or process and type of waste. Be specific about the actions you will carry out to do this.

For water discharge and point source

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