issued under Section 20 of the Environment Protection Act 1970 This licence allows the licence holder to discharge waste to the environment from the premises and accept prescribed industrial waste for reprocessing, treatment, storage or disposal at the premises subject to the attached conditions. LICENCE HOLDER: TERIS (AUST) PTY LTD REGISTERED ADDRESS: 1/47 MELVERTON DRIVE, HALLAM PREMISES ADDRESS: 92-94 ORDISH RD, DANDENONG LICENCE NUMBER: EI21010 DATE OF ISSUE: 22 OCTOBER 1993 DATE OF AMENDMENT: 9 AUGUST 2001 ........................................................................ JACEK JOZEF MAMBORT DELEGATE OF THE ENVIRONMENT PROTECTION AUTHORITY Page 1 of 13 EPA Waste Discharge Licence No. EI21010 Plant Activities Licence Objectives This licence applies to a premises where the prescribed industrial wastes are accepted for storage and processing. Operations on the premises include: storage, batching and blending of liquid prescribed industrial waste for the use as the solvent based fuel at a cement kiln licensed by the Authority or approved by relevant state or territory environment protection body; and, storage of liquid prescribed industrial waste for off-site treatment and/or disposal at a premises licensed by the Authority or approved by relevant state or territory environment protection body The licence holder shall adopt the following objectives for the protection of the environment: meet environmental quality requirements for all segments of the environment. This includes meeting the general provisions of the Environment Protection Act (1970), State environment protection policies, and Industrial waste management policies. In particular, Industrial waste management policy (Waste Minimisation); State environment protection policy (Waters of Victoria); State environment protection policy (Groundwaters of Victoria); State environment protection policy (Air Quality Management); and State environment protection policy (Noise from Commerce, Industry and Trade) operations are in accordance with good environmental practice at all times; and opportunities are taken to minimise waste and continuously improve environmental performance. Licence Structure The licence consists of the following parts. 1. Waste Discharge and Management specifies the conditions for the discharge of waste to the environment specifies the conditions for the waste acceptance and waste storage specifies the wastes which may be accepted at the premises and the treatment or disposal methods that may be used specifies the conditions for maintaining Financial Assurance 2. Environment Improvement Plan and Operational Controls requires an environment improvement plan to be produced and regularly reviewed; and, includes the operating requirements for key plant items to ensure protection of the environment under both normal and plant upset conditions. 3. Performance Monitoring, Recording and Reporting specifies the scope of the performance monitoring programme required to demonstrate environmental performance; and specifies the arrangements for submission of performance monitoring reports and other reports to EPA. 4. Plan of Premises plan of the premises covered by this licence. Page 2 of 13 EPA Waste Discharge Licence No. EI21010 1 WASTE DISCHARGE AND MANAGEMENT General 1.1 A copy of this licence must be kept and displayed prominently on the premises1 at all times. 1.2 All operation staff on the premises must be familiar with the conditions of this licence. 1.3 Written procedures for operating plant and equipment, preventive maintenance inspection, regular training and contingency must be made available to an authorised officer of the Authority2. 1.4 The handling, storage and processing of waste containing highly odorous compounds including mercaptans and acrylates must be conducted strictly in accordance with licence holder’s “Onsite Environmental Management Plan”, dated 10 February 2000. 1.5 The handling, storage and processing of waste, which can release highly toxic vapours (including waste containing cancerigenic substance), is not allowed, unless approved by the Authority. 1.6 Discharge of the gaseous wastes generated from batching and blending of waste for liquid fuel production must be controlled by an activated carbon scrubbing system before discharge to air. 1.7 Odours offensive to the senses of human beings must not be discharged beyond the boundaries of the premises. 1.8 The Condition 1.7 does not apply to accidental or unintended emissions arising from action taken by the licence holder in an emergency to prevent danger to life or limb or a mishap or malfunction affecting land in the Dandenong Industrial Two Precinct (formerly known as Dandenong Offensive Industrial Zone) which do not result from: 1.9 (i) Neglect, omission or failure on the part of the licence holder to maintain equipment, or (ii) Failure of the licence holder to comply with a direction given by an authorised officer of the Authority Odorous discharges from waste spillage, waste storage or leaks must be controlled immediately. Discharge to Water 1.10 There shall be no discharge or seepage of waste from the premises to the land or waters 3 1.11 There shall be no discharge of water from the premises during dry weather conditions. 1.12 Only clean stormwater collected outside the bunded areas may be discharged from the premises to waters. 1.13 Clean stormwater referred to in Condition 1.12 must only be discharged via the stormwater discharge point designated on the Plan of the premises in Part 4 of this licence as SW pit "A". 1 "Premises" means all land, pavement, buildings, vehicles and plant within the Teris (Aust) Pty Ltd property boundaries as described in the plan in Part 4 of this licence. 2 "The Authority or EPA" means the Environment Protection Authority, Victoria. 3 “Waters” includes any reservoir, tank, billabong, anabranch, canal, spring, swamp, natural or artificial channel, lake, lagoon, waterway, dam, tidal water, coastal water or groundwater. Page 3 of 13 EPA Waste Discharge Licence No. EI21010 Schedule 4 activities Prescribed Waste Receival 1.14 Only waste listed in Table 1 may be accepted on the premises. 1.15 Wastes must only be processed by the relevant processing method specified in Table 1. 1.16 Wastes listed in Table 2 must not be accepted on the premises for treatment or disposal. 1.17 Any wastes not listed in Tables 1 or listed in Table 2 may be accepted on the premises providing that prior written approval is received from the Authority. 1.18 Notwithstanding condition 1.14, a waste must not be accepted on the premises unless the waste can be processed and/or disposed off at a premises approved by the Authority or approved by a relevant state or territory environment protection body. 1.19 Notwithstanding condition 1.14 and 1.18, a waste generated outside Victoria should not be accepted at the premises if the waste or residue resulting from its treatment or processing requires disposal at a landfill in Victoria. 1.20 The licence holder must provide the Authority with copy of an approval issued by the relevant environment protection body for the use of the solvent-based fuel at the interstate cement kiln. 1.21 The approval referred to in Condition 1.20 should indicate type of waste acceptable at the fuel receiving facility. 1.22 The licence holder must provide the Authority with copy of the solvent based fuel specification required by the cement kiln facility approved as referred to in Condition 1.20. 1.23 Waste must not be held on the premises for a period greater than six months from the date of receipt of the waste. 1.24 Prescribed1 waste accepted at the premises must be accompanied by a fully completed EPA transport certificate, in accordance with the Environment Protection (Prescribed Waste) Regulations, 1998. 1.25 Prescribed industrial waste must not be accepted at the premises until it has been sampled and analysed in accordance with the licence holder’s sampling and analysing procedure titled “General Sampling- Procedure No. MH015”. 1.26 (a) The licence holder must take at least 250 ml sample of each load of the prescribed wastes entering the premises: (i) (ii) (b) 1 from each bulk transport load; and from each drum of waste except where all drums in the batch contain the same type of waste material. In this circumstances at least 250ml composite sample must be obtained from a representative sample of drum. Samples taken must be clearly labelled with the date, an identification number and must be cross-referenced to the relevant Authority transport certificate number "Prescribed Waste" means Prescribed Industrial Waste as defined in the Environment Protection (Prescribed Waste) Regulations 1987, as amended. Page 4 of 13 EPA Waste Discharge Licence No. EI21010 (c) 1.27 Samples must be kept at the premises for at least one week from the date of sampling. Where analysis of a sample shows that it does not conform with the description specified on the accompanying Authority transport certificate, the licence holder must record the occurrence, note the discrepancy on the transport certificate, immediately report the discrepancy to the Authority and either: (i) refuse to accept the waste load; or (ii) accept the waste load provided it can be treated, processed or disposed of at the premises in accordance with the conditions of this licence. 1.28 Bulk flammable wastes1 must only be transferred to or from road tankers while on the bulk flammable tanker unloading bay, bulk sludge pad or bunded area adjacent to BT3 and BT4 storage tanks. 1.29 Bulk "non flammable" prescribed wastes, with the exception of liquid waste containing PCB2 and oil wastes, must be directly delivered to the relevant storage tanks. 1.30 Drums3, containing prescribed wastes, on receival at the premises must be: (a) labelled with the Authority transport certificate number; (b) checked to determine the integrity of the container; and (c) (i) unloaded only at the drum unloading area; and (ii) the contents of any damaged or leaking drums must immediately be transferred to leak-free drums. Operations of the drum heater 1.31 Each drum of waste, which requires heating in drum heater, must not be accepted for heating unless in accordance with Teris Aust Pty Ltd’s Drum Heating Procedure submitted to the Authority on 18 July 2000. 1.32 The licence holder must utilise and maintain an activated carbon filter controlling discharges from the drum heater to air. 1.33 At least once a month the licence holder must check against a temperature indicator that the maximum achievable temperature inside the drum heater does not exceed 70 degrees Celsius Financial Assurance 1.34 The licence holder must maintain a financial assurance in a form and sum approved by the Authority. 1.35 The Authority may call upon the financial assurance at any time to conduct a clean up of the premises or for the disposal of wastes held at the premises. 1 "Flammable waste" means a waste having a closed cup flashpoint of less than 61°C. 2 “PCB” means any of the chemical compounds known as the polychlorinated biphenyls. 3 "Drum" means any container of up to 210 litre capacity. Page 5 of 13 EPA Waste Discharge Licence No. EI21010 1.36 Access to the funds covered by the financial assurance shall continue to apply until the Authority has approved a final premises audit and it is satisfied that a further premises clean up is not necessary. 1.37 Notwithstanding Condition 1.35 the Authority will give the licence holder the first option to correct any problem or conduct any clean up of the premises before drawing on the financial assurance. Management of wastes containing PCB 1.38 Notwithstanding Table 1, the acceptance and management of waste containing PCB is prohibited unless in compliance with approved by the Authority “Environment Improvement Plan for PCB Management” dated 29 June 2000 and revised on 9 March 2001 1.39 PCB waste must only be stored on the premises in an area dedicated for storage of such waste. 1.40 Notwithstanding condition 1.39, PCB waste can be transferred and kept in the bunded waste processing area for a period not exceeding 24 hours. 1.41 Dilution of PCB waste on the premises is acceptable only by blending the waste into solvent base fuel for destruction at the cement kiln. 1.42 The storage area referred to in Condition 1.39 must be: - located under the roof; - bunded with concrete floor and walls; and - clearly marked as a PCB storage area. 1.43 The concrete floor and walls of bunded area referred to in Condition 1.42 must be sealed with epoxy resin coating. 1.44 No more than 30KL of PCB waste must be stored at the premises at any time. Page 6 of 13 EPA Waste Discharge Licence No. EI21010 TABLE 1: Acceptable Wastes and Processing Methods Waste type as per EPA Publication 422a “Industrial Waste Strategy Waste Management Guide – List of Permit Holder” November 1999 Processing method Water based waste (no calorific value) Alkalis: C100, C140 Effluent: L100-L150 inclusive Miscellaneous: T110, T120 Solvent based waste (high calorific value) Organic acids: B180 Paints, Lacquers, Varnish, Resins, Inks, Dyes, Pigments, Adhesives: F100-F200 inclusive Organic solvents, solvents residues: G110-G180 inclusive Pesticides: H110, H120, H130 (excluding Scheduled Waste), H140, H160, H180, H190 Oils, Hydrocarbons, Emulsions: J 100-J160 inclusive Putrescible/Organic Wastes: K120, K170, K190 Organic chemicals: M120 (liquid waste containing less than 50ppm1 of PCB only), M130-M150 inclusive, M160 (excluding waste listed in Table 2), M190-M280 inclusive Pharmaceutical Wastes: R120, R140 Blending into solvent base fuel or off-site disposal Batching and blending for re-use as a solvent based fuel for cement kilns TABLE 2: Prohibited Wastes Waste consisting of or contaminated with: diethyl ether, carbon disulphide, nitrocellulose lacquer with a concentration of nitrogen greater than 12.6 % (w/w) 2 and an alcohol content lower than 25% (w/w) polychlorinated dibenzodioxins and dibenzofurans and related substances solid waste containing PCB and liquid waste containing 50ppm or more of PCB Scheduled Waste3 including polychlorinated dibenzodioxins and dibenzofurans and scheduled organochlorine pesticides ozone depleting substances (as defined in Industrial Waste Management Policy (Control of Ozone Depleting No. IW-1B DangerousSubstances) Goods Class 4 and 5 as defined by the Dangerous Goods (Storage and Handling) schedule Regulations waste 1989. Radioactive Highly odorous materials such as mercaptans and methacrylates in concentration higher than 5% (w/w) Explosives PCB contaminated liquid waste having concentration of PCB of 50 ppm or greater 1 2 3 “ppm” means parts per million w/w means weight by weight “Scheduled Waste” means any waste which contains chemicals included by the Australian and New Zealand Environment and Conservation Council (ANZECC) in “Schedule X” (developed under the National Strategy for the Management of Scheduled Waste) in quantities and concentrations in excess of specified for these chemicals thresholds. Page 7 of 13 EPA Waste Discharge Licence No. EI21010 2 Environment Improvement Plan and Operational Controls GENERAL 2.1 The licence holder must display at the premises the approved contingency plan for dealing with accidental spills and discharges of wastes or chemicals which addresses: (a) restricting the spill; (b) containment of spill; (c) absorbing or neutralising the spill; (d) disposing of the spill, and (e) clean-up procedures. 2.2 In the event of any spill or discharge of waste or chemicals the licence holder must immediately bring into operation the procedures in the emergency contingency plan. 2.3 The prescribed wastes generated by the storage, treatment and processing operations on the premises must be transported off the premises, in accordance with the Environment Protection (Prescribed Waste) Regulations 1998, to a facility licensed by the Authority to accept such waste. ENVIRONMENT IMPROVEMENT PLAN 2.4 By 31 December 2001 the licence holder shall submit to EPA reviewed its Onsite Environmental Management Plan dated 10 February 2000. 2.5 The reviewed document should be titled “Environment Improvement Plan” and must: 2.6 (a) include a description of the environmental effects resulting from operation of the plant; (b) covers all aspects of minimisation of wastes generated at the premises including minimisation of odorous and other waste emission to air, reduction of amount of waste needing disposal at landfill and reduction of volume of contaminated stormwater generated at the premises; (d) include an implementation timetable and review program for the opportunities identified for minimisation of waste; (e) include the arrangement for identification and separate storage of waste solvents suitable for off-site treatment and recycling; (e) include a protocol for compliance inspection with requirements of the Environment Management Plan and EPA licence; and, (i) include a protocol for preventive maintenance inspection with specific consideration of effectiveness of fail safe1 devices. The licence holder must review, and if necessary update, the premises Environment Improvement Plan at least once a year. 1 "Fail safe" device means equipment designed to indicate, prevent, or take steps to cease or minimise an situation which has the potential to cause environmental impact. Examples of such devices are indicators, recording devices, alarms, trips and interlocks. Page 8 of 13 EPA Waste Discharge Licence No. EI21010 2.7 A copy of any revisions to the Environment Improvement Plan, together with a report on progress in implementation of the plan over the past 12 months must be submitted to the Authority before the 1 January each year. Air Controls of Waste Emission 2.8 The gaseous waste generated from storage and processing of liquid wastes must be ducted to an activated carbon scrubbing system. 2.9 The activated carbon scrubbing system must be tested on a monthly basis for scrubbing efficiency and must be maintained in good working order. Stormwater controls 2.10 Stormwater pit "A" must incorporate a storage tank, an effective water-oil separator, an isolation valve, a vapour trap and sampling pit. 2.11 The stormwater pit referred to in Condition 2.10 must be maintained and operated so that: a) liquids discharged may be seen without removing a cover; b) samples can be easily taken there from; c) samples obtained are representative of the discharge; d) the pit is accessible at all times to any Authorised Officer of the Authority; and, e) maintenance is undertaken by a person or company experienced or familiar with the operation of the treatment plant. 2.12 Contaminated stormwater and stormwater collected within bunded areas on the premises must be transported off-site as prescribed waste for treatment and/or disposal at an EPA licensed site. 2.13 All liquid in the internal sumps serving the drum storage areas and underground storage areas must be transferred off-site as prescribed waste for treatment and/or disposal at an EPA licensed site. Schedule 4 activities 2.14 All storage and handling of waste must be carried out in accordance with the Dangerous Goods (Storage & Handling) Regulations 1989. 2.15 All waste, process chemicals or product must be unloaded, loaded, treated and stored in the secure bunded areas constructed, sized operated and maintained in accordance with the EPA Publication No 347 "Bunding Guidelines". 2.16 The licence holder must ensure that: 2.17 (a) Integrity of concrete base and concrete wall of any bunded areas is maintained so that the concrete remains impermeable to the wastes stored within the areas, and; (b) All prescribed wastes or chemical spillage collected within bunded areas are immediately cleaned up and stored in the containers to limit odorous emissions before processing or final disposal. Bulk prescribed wastes must only be transferred to or stored in storage tanks within bunded areas. Page 9 of 13 EPA Waste Discharge Licence No. EI21010 2.18 (a) All storage tanks must be fitted with operative level indicators (b) All transfer hoses must be stored in bunded areas (c) All pumps, used for the transfer of prescribed wastes must be located in the bunded areas. 2.19 The tank farms must be equipped with effective alarm systems, which activate audible alarms whenever liquid accumulated in the tank farm bund exceeds 25 percent of the total bunded capacity. 2.20 The licence holder must drain the tank farm bund on the day when the audible alarm referred to in Condition 2.19 is activated. 2.21 The tank farm bunds referred to in Condition 2.20 must not be used for storage or temporary storage of waste material including industrial wastewaters. 2.22 All empty uncrushed, contaminated drums must be stored in the 'contaminated empty drums area'. 2.23 Drums intended for crushing must contain less than l percent by volume of solid residual waste. 2.24 All crushed drums must be stored within a roofed and bunded area. 2.25 The procedures must be followed to ensure that solid waste transported off site to landfill meets the elutriation test criteria of the disposal site. INSPECTION AND MAINTENANCE 2.26 The licence holder must conduct a daily inspection and maintenance program at the premises. The program must include the following features (a) all above ground tanks; (b) all bunds and bunded areas; (c) all drum stores; (d) all instrumentation including recorders and alarms; (e) safety and emergency equipment; (g) process pipe work, gaskets, joints and valves, and (h) the stormwater systems. Page 10 of 13 EPA Waste Discharge Licence No. EI21010 3 PERFORMANCE MONITORING, REPORTING AND RECORDING General 3.1. By 1 March each year the licence holder must submit a report to EPA which includes: (a) advice on the total quantity (in tonnes) of prescribed wastes (including the proportion of priority wastes) entering and leaving the premises; (b) advice on the type and total quantity (in tonnes) of processed wastes that are recovered and sent off the premises as recycled products for reuse, and (c) the results of the monitoring programme required by the Conditions 3.7 to 3.9, prepared by a person or body registered by NATA or a person or body approved by the Authority in respect of the testing for the previous calendar year. 3.2 The licence holder must notify the Authority in writing as soon as practicable of any performance monitoring result, which indicates a breach of any condition of this licence. The notification must include an evaluation of why the breach occurred and what action is being taken to prevent a recurrence of the breach. 3.3 In the event of an unauthorised discharge of waste including emissions to atmosphere beyond the boundaries of the premises the licence holder must: 3.4 (a) immediately inform the Authority by telephoning 9794 0677, and (b) submit a report to the Authority within 7 days detailing: (i) the discharge of waste or chemicals leaving the boundaries of the premises; (ii) the cause of the discharge; (iii) the action taken to clean up the discharge and prevent it from happening again, and (iv) the effect on the environment. The licence holder must ensure that all samples referred to in Part 3 of the licence: (a) are obtained by or under the instruction of a qualified analyst and will be analysed only by an analytical laboratory accredited by the National Association of Testing Authorities (NATA); and, (b) record of analysis results referred to in this Part of the licence bears a NATA stamp endorsement. Stormwater 3.5 The licence holder must install and maintain a sampling point at the point indicated on the Premises Plan: a) b) c) 3.6 which is as near as practicable to the discharge point; so that samples may be easily obtained and are representative of the waste discharged; and which is easily accessible at all times to authorised officers of EPA. The licence holder shall undertake a monitoring program for the stormwater discharged from the premises via Stormwater pit A on a quarterly basis to allow comparison with the Page 11 of 13 EPA Waste Discharge Licence No. EI21010 State Environment Protection Policy (Waters of Victoria) limits. Parameters may include: iron, lead, cadmium, zinc, chromium and copper, suspended solids, total organic carbon, aromatic hydrocarbons, pH and phenol. Groundwater 3.7 The licence holder must provide and maintain a minimum of 5 bores: (a) as designated on the attached plan of the premises; (b) at a minimum depth of 2 metres below the standing water level, and (c) that the bores are accessible at all times to any Authorised Officer of EPA or any Authorised Officer under the Water Act 1989. 3.8 Standing water levels in each bore must be measured and recorded on each occasion that samples are obtained in accordance with condition 3.7. This measurement must be carried out prior to any disturbance by sampling and must be reported as the depth in metres to the water surface within the bore from the top edge of the casing collar. 3.9 Samples of water must be taken from each of the 5 bores on at least one occasion during the months of January and June each year, and analysed or tested for: electrical conductivity pH redox potential temperature total dissolved solids total organic carbon lead zinc copper chromium cadmium Record Keeping 3.10 The licence holder must keep and up-to-date an inventory of all prescribed wastes on the premises including the following information: (a) date of delivery/acceptance at the premises; (b) description including the physical form; (c) cross reference to EPA transport certificate number; (d) origin (including interstate and overseas); (e) method proposed for processing or disposal; and (d) quantity of accepted waste. 3.11 The prescribed wastes referred to in Tables 1 must be marked to show the true calender date and time of day of acceptance. 3.12 The prescribed waste inventory referred to in Condition 3.10 must be retained for not less than 3 months from the date of the original record and must be available upon request to any Authorised Officer of the Authority who must be permitted to make copies thereof. 3.13 The licence holder must keep and maintain records of the inspection and maintenance program referred to in Condition 2.26 and makes these records available to any Authorised Officer of the Authority and is kept for at least 60 days. Page 12 of 13 EPA Waste Discharge Licence No. EI21010 4 PLAN OF PREMISES Page 13 of 13