EPA Works Approvals and Emission Licenses - Compliance with Local Authorities
Q: What is a Works Approval?
"A Works approval permits works to be undertaken which will result in a discharge of waste to the environment or an increase / alteration to an existing discharge"....... EPA (Review) Act 1984.
Q: Do we need one?
There are "exemption" tables available which list the emission requirements for each type of industry, setting the limiting rates. If you compare your proposed operation with this document - Exemptions "Environment Protection (Scheduled Premises and Exemptions) Regulations 1996" available from the EPA, it will spell out the requirements. It should be noted that "emissions" can mean discharges to air, sewer, stormwater, land and even noise. These regulations were updated 1st July 2007. For an appraisal of your case please email us.
Q: If we need one, how long does it take and what does it cost??
Previously, from the time that the EPA accepted your full application they had a statutory period of 4 months to deliver or reject your Works Approval.
Recently, changes were made to this procedure, resulting in a "pre-application" meeting with relevant personnel at EPA. This now enables EPA to make an early appraisal of the project and to concentrate efforts in areas of importance. This has also reduced the processing timeline to two months in many cases. However, the 21 day advertising period remains in place and provided that there are no public objections or further queries by the Authorities involved (such as local Council, Water Authorities etc.), the assessment of the application can commence.
The equipment should not be installed until the approval has been obtained. The system should then be built to comply with the specifications in the approval documentation, and it is important to ensure that what has been requested is precisely what will be built. ...and for EPA to inspect the installation. the EPA will then grant a license to operate.
Works Approval fees depend on the cost of the works (eg. for an installation costing between $50K and $250K the EPA fee would be $2,768). For the latest figures go to EPA Victoria Works Approval Fees. The on-going cost of the license to operate is dependent on your industry but this can cost anything from $10,000 annually depending on the quantity and nature of the emissions.
Q: Can we engineer the process to make it exempt?
If you need to get a license, apart from the cost of the works approval application, on-going annual fees and the 4-6 month delay in project completion, the EPA license document will also include requirements for environmental, waste, greenhouse gas and sustainability management. It makes sense to consider addressing these aspects before beginning the proposal. If your process emits more than the prescribed limit it may still be possible to examine methods of reduction, either by managerial, design, formulation or engineering means. You may be able to avoid the need for licensing as well as reduce waste emissions, a win/win situation with considerable cost and time savings to your company.
Q: How do we find out if our emissions exceed the limit?
In some cases (such as solvent emissions to air from printing, spray painting, de-greasing, dip and curtain coating) these can be calculated from production usage and purchases of raw materials. We offer a spreadsheet service to assist with this. If you are a flexographic or gravure printer, we have two ready-made spreadsheets available (for Victoria and Australia/International) on our downloads page (ZIP format).
If the emissions cannot be calculated (eg. if there are reaction/combustion products or odours involved), we can provide exhaust Stack Testing facilities (NATA approved) to determine the emission inventory for your site. Part of the Approval process requires an estimation of the effect at ground level caused by the factory stack emissions. For this, a mathematical model is used. This is based on your factory layout, emission rates and the local meteorology file. We have full facilities for this modelling program.
Q: Where can we build and how far must we be from residential areas?
Another EPA publication - Buffer Distances "Recommended Buffer Distances for Industrial Residual Air Emissions" lists the minimum recommended distances of each industry from "sensitive" locations such as residential zones, hospitals, schools, caravan parks and similar public amenities. This should be carefully considered prior to purchasing or renting a new property.