Guidance

Tracer tests and remediation schemes: environmental permit exemption

When and how to register if you're discharging small quantities of substances for scientific purposes as part of a groundwater tracer test or remediation scheme.

You may need to register as exempt from requiring an environmental permit if you discharge small quantities of substances for scientific purposes as part of a:

  • groundwater tracer test, ie introducing a traceable substance into the ground or directly into groundwater to study the movement of water or a contaminant underground
  • specified groundwater remediation scheme, ie a scheme that involves adding substances to groundwater to enhance the rate of remediation of groundwater contaminants

The level of pollution risk will determine whether your activity can be:

If your activity doesn’t meet any of these requirements you must apply for a bespoke permit.

You must apply for a bespoke permit if you plan to use hazardous substances.

For radionuclide tracer tests, you need to apply for a permit that allows you to use radioactive substances. Contact the Environment Agency to apply.

Activities that don’t need an exemption or permit

You don’t need an exemption or permit to discharge low-risk quantities of substances for:

  • groundwater tracer tests with a direct input into groundwater of the equivalent of 10 litres of any non-hazardous pollutant
  • remediation schemes involving a concentration of any non-hazardous pollutant not greater than 10 times the concentration at which it is suitable for human consumption

These are called exclusions and do not need to be registered. However, the Environment Agency recommends that you carry out a water features survey, monitoring and keep a written record. You may need to provide evidence that your discharge was eligible for exclusion if groundwater pollution occurs.

Cultured micro-organisms and bacteria

Under the Environmental Permitting Regulations, there’s no requirement for registration or permitting if the tracer test or remediation scheme uses cultured micro-organisms or bacteria.

However, you should carry out monitoring, including:

Check if you can register as exempt

To register as exempt, you must be able to meet the following conditions. You must:

  • make sure the discharge doesn’t cause groundwater pollution
  • make sure the discharge falls within the description of a groundwater tracer test or a specified groundwater remediation scheme
  • make sure the discharge doesn’t contain any hazardous substances
  • make sure the concentration and volume of substances in the discharge are limited to the amount strictly necessary to achieve the objectives of the activity
  • carry out a water features survey to within 1 kilometre of the discharge – this must demonstrate that the discharge won’t cause pollution
  • get prior consent of any individual or organisation (eg the relevant water company) that has the right to abstract water in the vicinity of the discharge
  • not make any discharge as part of the tracer test or remediation scheme until you have registered the exemption

You should keep a written description of the tracer test, or details of the substances used as part of the specified remediation scheme, available for inspection for 6 months after any monitoring has demonstrated that pollution of groundwater hasn’t occurred.

For remediation schemes, you must carry out monitoring of the discharge to determine whether pollution has been caused.

A water features survey and any monitoring should be a part of a risk assessment. This must demonstrate that the discharge will not cause pollution.

If the discharge doesn’t meet the requirements for exemption you’ll need to apply for a bespoke permit.

You can be served with a remediation notice by the Environment Agency if the tracer test or remediation scheme causes groundwater pollution.

Carry out a water features survey for your exemption

A water features survey means a survey of all water features within 1 kilometre of the proposed activity that may be affected by it.

Water features include boreholes, wells, adits, springs, seepage and wetland areas, ponds, lakes and watercourses.

The water features survey should take into account:

  • the local hydrogeological setting (eg local drinking water supplies)
  • aquifer conditions (eg the aquifer types being used)
  • the details of the proposed groundwater activity

Your survey findings must demonstrate that the discharge won’t cause pollution of any of the receptors identified.

The Environment Agency doesn’t need to see the findings of your water features survey. However, you should keep a record of it in case pollution occurs.

Monitoring you must carry out for your tracer test exemption

A tracer test requires monitoring of parameters such as the concentration of the tracer with time and with distance from the discharge location in order to determine aquifer properties.

It is not a condition that you monitor receptors. However, subject to the risk assessment and water features survey, monitoring of receptors may be required.

Monitoring you must carry out for your remediation scheme exemption

A groundwater remediation scheme must include appropriate monitoring. Potential effects that may need to be considered include:

  • changes in the local chemical environment
  • residual substances in groundwater if these are not consumed in the degradation process
  • the release of more harmful breakdown products that may potentially cause a secondary risk

Keep records for your exemption

You should keep a written record of the discharges from your groundwater tracer test or remediation scheme. This should include details of the water features survey and any monitoring you’re carrying out. You may be asked to provide these if your discharge pollutes groundwater.

You should keep the records until 6 months after your monitoring has demonstrated that groundwater hasn’t been polluted.

Register your exemption

You need to contact the Environment Agency and ask them to send you the application form. You must complete and return this form to register.

It’s free to register.

You’ll need the:

  • registered address and number of your limited company, if you have one
  • address and postcode, with a map, where the exempt activity is being carried out, or a 12-digit grid reference

Groundwater exemptions for discharges for scientific purposes are valid for 12 months from the date of registration. You must renew the exemption every year that you want to continue with the activity.

After you’re registered as exempt

If the details of your groundwater tracer test or remediation scheme change significantly you must update your records.

You need to re-register if the:

  • name of the person carrying out the discharge (the operator) changes
  • planned location changes
  • registration expiry date passes

Carry out your remediation scheme under a standard rules permit

You don’t need to register the exemption if the Environment Agency has granted you a standard rules permit SR2008 No27: mobile plant for the treatment of soils and contaminated material, substances or products. However, you will need to complete a deployment form with specific information about your site.

You must:

  • meet the conditions on your deployment form
  • comply with the conditions of the permit

You can’t start your activities until the Environment Agency approves your deployment form.

The standard rules permit only covers the introduction of the remedial agent to groundwater. You need licences and separate permits for the recirculation of abstracted groundwater and the re-injection of substances.

If you don’t already have this standard rules permit, find out how to apply for a standard rules permit.

If you don’t meet the conditions for the standard rules permit or the exemption you must apply for a bespoke permit.

When you must apply for a bespoke permit

If you don’t meet the requirements for an exclusion, exemption or standard rules permit then you must apply for a bespoke permit.

Change, transfer or cancel your permit

After you have your permit, you can:

  • change (vary) the details on it
  • transfer it to someone else
  • cancel (surrender) it

Find out how to change, transfer or cancel your permit.

Contact the Environment Agency

Contact the Environment Agency if:

  • you need help with your application
  • you’re not sure if you need a permit

General enquiries

National Customer Contact Centre
PO Box 544
Rotherham
S60 1BY

Monday to Friday, 8am to 6pm

Published 1 February 2016