Baseline Reports for the Industrial Emissions Directive (IED)

IED Baseline Report sit map
What are my responsibilities under the IED?

The Industrial Emissions Directive (IED) aims to reduce pollution/contamination from industrial activities. Part of the IED covers contamination to soil and/or groundwater, and looks to ensure that no further contamination is being caused by industrial processes on site. In order for sites to monitor if proposed or current activities are causing pollution they must first establish 2 things:

1) what hazardous substances could be used, produced or released by the installation (activity) on site?

2) what levels of contamination already exist on site for the hazardous substances identified?

Under the requirements of the IED when activities/an installation on site are no longer in use the groundwater and soil need to be remediated to (at minimum) the same level of contamination present as of the starting operation of the installation or the first monitoring event after 7 January 2013. Monitoring events are typically at least once every 5 years for groundwater and 10 years for soil.

To establish the level of contamination for the relevant hazardous substances a baseline assessment/baseline report must be completed. It is important that the baseline report is sufficiently detailed so that any historic contamination is identified. If historic contamination is not identified in the baseline assessment when the installation on site is no longer in use the site operator may have to remediate historical contamination not associated with the permitted activities.

What are the requirements of the IED baseline assessment?

At Geo Pollution Technologies we are experienced at completing baseline reports in order to satisfy the requirements of the Industrial Emissions Directive (IED). Baseline assessments must as a minimum contain information on the present and past site use and information on the contaminative status of the soil and groundwater on site. Effectively the baseline report requires a detailed Phase I and Phase II site investigation to be undertaken. In addition to this a detailed risk assessment must be undertaken in relation to the potential for pollution by the proposed or current activities on site.

There are typically 8 stages in producing a baseline assessment:

Stage 1: Identify which hazardous substances are used, produced or released at the installation.

Stage 2: Identify which of the hazardous substances from Stage 1 are capable of contaminating soil or groundwater.

Stage 3: Identify the actual possibility for soil or groundwater contamination posed by the activities on site.

Stage 4: Provide a site history.

Stage 5: Identify the sites environmental setting.

(Stages 4 and 5 are essentially a Phase I site investigation)

Stage 6: Use the results of stages 3, 4 and 5 to undertake a pollution risk assessment to assess risks posed by, current and future site activities.

Stage 7: Investigate the contaminative status of the soil and groundwater on site (essentially a Phase II intrusive site investigation).

Stage 8: Produce a baseline report for the installation that quantifies the state of soil and groundwater pollution by relevant hazardous substances.

IED Baseline Assessments Case Studies

industrials emissions directive baseline report

Extracts from legislation and guidance

“Where an activity involves the use, production or release of relevant hazardous substances and having regard to the possibility of soil and groundwater contamination, a baseline report is to be drawn up before starting the operation of the installation or before a permit for the installation is updated for the first time after 7 January 2013.”

“It is in the operator's interest to ensure that the state of contamination of soil and groundwater identified in the baseline report is sufficiently detailed as this information will be used to determine which pollution has been added in the course of the operation of the installation concerned since the baseline has been established.”

European Commission Guidance concerning baseline reports under Article 22(2) of Directive 2010/75/EU on industrial emissions

(monitoring must be conducted) “at least once every 5 years for groundwater and 10 years for soil”.

The Environmental Permitting (England and Wales) (Amendment) Regulations 2013

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