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: BRAMBLES AUST LTD
REGISTERED ADDRESS: LEVEL 40 GATEWAY, 1 MACQUARIE PL,
SYDNEY NSW 2000
PREMISES ADDRESS:
LICENCE NUMBER:
DATE OF ISSUE:
DATE OF AMENDMENT:
64-68 ORDISH RD, DANDENONG VIC 3175
EM36133
21 AUGUST 1998
20 NOVEMBER 2000
Page 1 of 17
MARTIN O'SHAUGHNESSY.
DELEGATE OF THE
ENVIRONMENT PROTECTION AUTHORITY

EPA Waste Discharge Licence No. EM36133
Plant
Activities
Licence
Objectives
Licence
Structure
This licence applies to a premises where prescribed industrial waste in the form of clinical and related wastes is incinerated and organic and inorganic wastes are stored in drums prior to transport from the premises for disposal.
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);

State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade), No. N-1.
 operations are in accordance with good environmental practice at all times; and
 opportunities are taken to minimise waste and continuously improve environmental performance.
The licence consists of the following parts.
1. Waste Management
 specifies the general requirements under which wastes may be discharged to the environment; and
 specifies which wastes may be stored, treated or otherwise disposed of and the general requirements under which this may occur; and
 requires the provision of a financial assurance
2. Environment Improvement Plan and Operational Controls
 requires an environment improvement plan to be produced and regularly reviewed; and
 includes operating requirements for good waste management and protection of the environement under both normal and plant upset conditions.
3. Monitoring and Reporting
 specifies the monitoring requirements and the arrangements for submission of reports to the Environment Protection Authority ("EPA").
4. Plan of Premises
 plan of the premises covered by this licence, including discharge points.
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EPA Waste Discharge Licence No. EM36133
1. WASTE MANAGEMENT
Discharges to air
1.1 All wastes specified in Table 1 discharged to air from the premises must be discharged: a) only at the discharge point specified in Table 1 the location of which is indicated on the attached Plan of Premises; b) vertically upwards by means of a stack which must not terminate at a height above ground level less than that specified in Table 1; c) from the discharge point specified in Table 1 at a rate not exceeding that specified in the Table; d) from the discharge point specified in Table 1 at a concentration not exceeding that specified in the Table; e) from the discharge point specified in Table 1 at a velocity not less that specified in the Table; and f) so that there are no visible emissions excluding water vapour.
1.2 Wastes other than those specified in Table 1 must not be discharged from the discharge point specified in the Table.
1.3 The exhaust stack associated with discharge point number 1 must be conspicuously marked with the following details: a) the number of this licence, and b) the discharge point number.
1.4 Odours offensive to the senses of human beings must not be discharged beyond the boundaries of the premises.
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EPA Waste Discharge Licence No. EM36133
TABLE 1: Emission Limits and Discharge Requirements
Discharge Point 1: Incinerator stack
Waste/Parameter
Chlorine compounds (as HCl)
Fluorine compounds (as HF)
Sulphur dioxide
Total particulate matter
Insoluble particulate matter
Carbon monoxide
Oxides of nitrogen (as N0
2
)
Heavy metals (total)
TOC
Mercury
Lead
Polychlorinated dibenzop -dioxins
("PCDD") and polychlorinated dibenzofurans ("PCDF")
Discharge height above ground level
(m)
Discharge velocity (m/sec) rate g/min concentration g/m3
30.0
100.0
2.0
6.0
10.0
1.0
8.0
50.0
14.0
0.05
0.005
0.04
0.25
0.07
0.15
0.5
0.01
0.03
0.04 0.0002
1.0 0.005
0.1 ng/m 3 toxic equivalent
21.0
10.0
Notes
1.
"Cubic metre" (m 3 ) means the volume of dry gaseous effluent which occupies 1 cubic metre at a temperature of zero degrees Celsius ( o C) and at an absolute pressure of 101.3 kilopascals and calculated at 7% oxygen.
2.
"Chlorine compounds" means chlorine, hydrogen chloride and compounds of chlorine as hydrogen chloride.
3.
"Fluorine compounds" means fluorine, hydrogen fluoride and compounds of fluorine as hydrogen fluoride.
4.
"Total Organic Compounds" (TOC) means the sum of all compounds of carbon which contain at least one carbon to carbon bond plus methane and its derivatives. For the purposes of measurement 1 gram TOC shall be deemed to have the same flame ionisation response as 1 gram of hexane.
5.
"Heavy metals" means the total of antimony, arsenic, cadmium, chromium, copper, cobalt, lead, mercury, zinc and their compounds.
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EPA Waste Discharge Licence No. EM36133
Acceptable wastes, waste acceptance, and disposal
1.5 Only those wastes listed in Table 2 may be accepted on the premises.
1.6
Wastes must only be processed by the relevant processing method(s) specified in
Table 2.
1.7
Any wastes not listed in Table 2 may be accepted on the premises providing that prior writted approval is received from EPA.
TABLE 2: Acceptable Wastes and Processing Methods
Waste Type Processing method

Security non infectious, pharmaceutical and Australian
Customs quarantine wastes

Clinical and related wastes

Or any other wastes as approved by
EPA in writing

Cyanide wastes

Inorganic chemical waste

Paints, resins, inks, dyes and adhesives and solvents.

Non-recoverable oil sludges

Isocyanates

Arsenical waste compounds

Or any other wastes as approved by
EPA in writing
Incineration and/or transport off site for treatment and/or disposal at
Environment Protection Authority licenced premises.
Transport off site for treatment and/or disposal at EPA licenced premises.
"Clinical and related wastes" means any waste that is an infectious or pharmaceutical substance or is waste material that is contaminated with infectious or pharmaceutical residues as prescribed by the
Environment Protection (Prescribed Waste) Regulations 1987 as amended.
1.8
Prescribed industrial waste accepted at the premises or transported off the premises must be accompanied by a fully completed EPA transport certificate in accordance with the Environment Protection (Transport) Regulations 1987 as amended.
1.9
The licence holder must maintain a regularly updated waste manifest accessible at all times to an officer of Environment Protection Authority.
1.10
Wastes listed in Table 2, other than clinical and related wastes, must not be stored for longer than 180 days at the premises.
1.11
The licence holder before accepting any waste at the premises from any waste producer must advise the producer in writing of the waste types as listed in Table 2 which can be accepted at the premises.
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EPA Waste Discharge Licence No. EM36133
1.12 Any waste received at the premises which is not listed in Table 2 or does not conform with the description in the accompanying Environment Protection Authority ("EPA") waste transport certificate, must: a) immediately be reported to the EPA; b) be refused to be accepted at the premises; or c) be stored in a designated bunded quarantine area; and d) not be stored for longer than 180 days; and e) be registered on a separate manifest which lists the type and volume of waste stored in a designated quarantine area; or
1.13 Any waste received at the premises in drums, packages or containers must; a) be checked to determine the integrity of the drums, packages or containers; and b) in the event that a drum, package or container is found to be damaged or leaking, must immediately be transferred to a leak-free drum; and c) must not be decanted or handled in a manner whereby the contents of any two or more drums, packages or containers are consolidated, combined or mixed.
1.14 Incinerator ash including any other materials collected within the sump and bund referred to in condition 2.4 must be disposed of by an appropriate EPA approved method.
Waste records
1.15 The licence holder must keep on the premises records of all waste transported on or off the premises and must include the following information: a) date of acceptance to the premises or transport off premises; b) description of the waste, or type of clinical and related wastes; c) cross reference to EPA transport certificate number (where applicable); d) quantity of waste; e) origin or destination of waste; f) result of analysis (where applicable); and g) method of waste treatment or disposal used (where applicable).
1.16 Records made in accordance with condition 1.15 must be retained for 12 months and made available to any authorised officer of EPA upon request.
Discharges to water
1.17
Any discharge to sewer must have the prior written approval of the relevant Water
Authority.
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EPA Waste Discharge Licence No. EM36133
1.18
There shall be no discharge or seepage of waste from the premises to land or to the waters 1
1.19
Only clean stormwater may be discharged from the premises to the waters.
1.20
Stormwater discharged from the premises must not contain any oil, foam, grease, scum, litter or other objectionable floating matter.
1.21
There shall be no discharge of water from the premises during dry weather conditions.
1.22
Water collecting within bunded areas must not be discharged to the waters.
1.23
Water collecting outside bunded areas excluding roof water must be discharged from the premises via one or more intercepting pits in compliance with conditions 1.19,
1.20, 1.24 and 3.2.
1.24
The interceptor pit or pits referred to in condition 1.23 must: a) have a minimum volume of 2000 litres; b) be maintained free of floating oil and sludge accumulation; c) be desludged whenever there is a build up of sludge; d) have its contents tested for pH weekly; and e) have access for sampling from a manhole in its cover.
Acceptable waste treatment procedures
1.25 All prescribed waste generated by storage or treatment operations at the premises must be treated or disposed of in a manner approved by the EPA.
1.26 All clinical and related wastes disposed of on the premises must be disposed of by incineration in the incineration equipment served by discharge point No 1.
Financial assurance
1.27 The financial assurance provided to the EPA by the licence holder must be maintained by the licence holder until such time EPA is satisfied that no clean up of the premises will be required as a result of the licence holder’s use of the premises.
1
“Waters” includes any reservoir, tank, billabong, anabranch, canal, spring, swamp, natural or artificial channel, lake, lagoon, waterway, dam, tidal water, coastal water or groundwater.
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EPA Waste Discharge Licence No. EM36133
2. ENVIRONMENT IMPROVEMENT PLAN AND OPERATIONAL CONTROLS
Environment improvement plan
2.1 The plant must be operated and improved in accordance with the Environment
Improvement Plan first approved by EPA in July 1997 as amended from time to time.
Bunding, handling and storage
2.2 All storage and handling of waste must be carried out in accordance with the
Dangerous Goods (Storage & Handling) Regulations 1989.
2.3
All waste, process chemicals or product, including clinical and related wastes and incinerator ash, must be unloaded, loaded, treated and stored in secure bunded areas which must: a) be constructed, sized operated and maintained in accordance with the EPA publication 347 "Bunding guidelines" ; b) be kept free from fissures, gaps or cracks; and c) have no pipework pass through any bund wall.
2.4 All ash removed from the incinerator must be stored in a container in an impermeable concrete bunded area which is drained to an impermeable concrete sump.
Inspection and maintenance
2.5
The licence holder must conduct a regular inspection and maintenance program at the premises. The program must include but not be limited to the following features: a) all storage containers and vessels; b) all bund walls and bunded areas; c) all pipework, gaskets, joints and valves; d) all fixed and portable pumping equipment; e) all monitoring devices and alarms; f) safety and emergency equipment; g) calibration of all instrumentation; and h) the interceptor pits.
2.6 The licence holder must keep and maintain permanent records on the premises of the inspection and maintenance program and make these records available to any authorised officer of EPA on request.
2.7 The automatic chemical dosing equipment associated with the recirculating liquor of both the quench tower and the venturi scrubber referred to in condition 2.12(c) must
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EPA Waste Discharge Licence No. EM36133 be maintained to a standard where operations are continuous and without leaks from pumps, tanks and other associated equipment.
Premises security
2.8 The premises must be manned at all times during the movements of prescribed waste into and out of the premises.
2.9 The premises must be enclosed by a fence and lock up gates of at least 1.8 metres in height to prevent unauthorised access to the premises.
Spill precautions and unauthorised discharges
2.10
In the event of any spill, adverse discharge of waste or chemicals or failure of air pollution control equipment the licence holder must immediately bring into operation contingency plans and procedures approved by EPA to prevent further discharge to the environment.
2.11
The contingency plans and procedures referred to in condition 2.10 must address: a) clean up procedures for accidental spills or discharges of waste; b) disposal of the spilled materials; c) actions to be taken in the event of the failure of the incinerator process control system or pollution control equipment; and d) regular operator training exercises in such events.
Incinerator
Operation
2.12
Wastes must only be incinerated in the incinerator referred to in condition 1.26 when: a) the gas temperature at a point one metre from the entrance of the secondary combustion chamber is at least 1100 o
C; b) the percentage excess oxygen content of the exhaust gases leaving the secondary combustion chamber of the incinerator is at all times greater than 5 percent; and c) all gaseous and particulate matter leaving the incinerator is directed to the waste heat boiler, and treated in a quench tower and a venturi scrubber each using an alkaline liquor at a pH of 8.5 or greater.
2.13
The temperatures of the gases must be continuously and accurately measured and recorded in degrees Celsius at the following locations: a) within the operating primary combustion chamber; b) at a distance of one metre from the entrance to the secondary combustion chamber; c) at the entrance to the quench tower; and d) at the sampling position in the exhaust stack.
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EPA Waste Discharge Licence No. EM36133
2.14
An audible alarm must sound and an electrical interlock must activate auxiliary gas burners in the secondary combustion chamber whenever the secondary combustion chamber falls below 1100 o
C whilst incinerating prescribed waste.
2.15 The percent excess oxygen content of the exhaust gases leaving the secondary combustion chamber of the incinerator must: a) be continuously and accurately measured and recorded; and b) actuate an audible and visual alarm that alerts the person in charge of the incinerator whenever the percentage excess oxygen content of the exhaust gases leaving the secondary combustion chamber of the incinerator is less than 5 percent.
2.16 The pH of the liquor recirculating in the wet scrubber system referred to in condition
2.12(c) must be continuously measured and recorded, and a permanent log at 8 hourly intervals produced and retained.
2.17
The recordings of temperature required by condition 2.13 and pH as required by condition 2.16 must be: a) marked to show the true calendar date and time of day; and b) retained for not less than 12 months from the date of the original record and must be available upon request to any Authorised Officer of EPA.
2.18
A record of the biennial calibration of all instruments involved in the measuring and recording of temperature as required by condition 2.13 and pH as required by condition 2.16 must be kept in the form of a log and must be available upon request to any Authorised Officer of EPA.
2.19
At the completion of incineration of wastes the following must occur: a) the temperature of the gases in the primary combustion chamber must be maintained at greater than 650 o C for a period of at least 240 minutes from the final waste charge prior to the shut-down of the primary combustion chamber air fan; b) the temperature of the gases in the secondary combustion chamber must be maintained at greater than 1100 o
C for the period the primary chamber fans are in operation which must be at least 240 minutes from the final waste charge; and c) the air pollution control equipment by-pass valve is not opened until the induced draft fan is shut down.
2.20 During electrical power failure the standby power generator must provide power to the incinerator control system and the secondary chamber air supply fan.
2.21 The scrubber liquor and boiler water standby pumps must be operated whenever the duty pumps are inoperable.
Storage
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EPA Waste Discharge Licence No. EM36133
2.22 Clinical and related wastes, other than non infectious security, waste pharmaceutical and quarantine material, accepted at the premises: a) must be transferred immediately to either refrigerated storage facilities or the medical waste incinerator, located within the process building; b) must remain sealed in their storage containers at all times except during loading or unloading operations; c) which is not incinerated within four hours of acceptance must be stored in the refrigerated storage facilities at a temperature of 5°C or less; and d) must not be stored on the premises for a period longer than 14 days without written approval from EPA.
2.23
All transportable containers and vehicles which contain clinical and related wastes must be stored within impermeable concrete bunded areas: a) with bund walls at least 100 mm high; and b) which drain to an impermeable concrete sump within the bunded area.
2.24 Refrigerated storage containers must be equipped with an temperature indicator which displays the internal air temperature to an operator located outside the sealed vessel.
Loading
2.25 Prescribed industrial waste must not be loaded to the primary chamber of the incinerator unless the temperature of the gases exiting the secondary combustion chamber is at least 1100 o C.
2.26 When the emissions control equipment by-pass valve on the incinerator is open to allow gases to by-pass the pollution control equipment referred to in condition 2.12(c) no wastes must be loaded to the incinerator.
2.27
An audible alarm must be activated and an electrical interlock must prevent the loading of wastes to the primary combustion chamber whenever: a) the temperature of the gases exiting the secondary combustion chamber of the incinerator is below 1100 o
C; b) the air pollution control equipment is by-passed; and c) the pH of the scrubbing liquor entering the scrubber is less than 8.5.
2.28 At no time during loading, operation or ash removal must there be a visible discharge of gaseous or particulate emissions from the incinerator building to the environment.
2.29 A ventilation system must be fitted to the automatic loading equipment which extracts the air from the waste loaders and directs all captured emissions to either the primary or secondary combustion chamber.
2.30 A daily record of the loading of waste to the incinerator must be kept for the previous
12 months and made available on request to any Authorised Officer of EPA, which must include:
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EPA Waste Discharge Licence No. EM36133 a) the quantity and type of each charge; b) the time at which the waste is added to the incinerator; c) the temperature of the primary combustion chamber at the time of addition; and d) the temperature of the secondary combustion chamber at the time of waste addition.
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EPA Waste Discharge Licence No. EM36133
3. MONITORING AND REPORTING
Performance monitoring
Incinerator stack
3.1 The licence holder must conduct a monitoring program of the waste discharged from discharge point number 1 in accordance with the following requirements: a) provisions for sampling must conform with EPA publication 440
“A guide to the sampling and analysis of air emissions”; b) the following tests must be conducted and samples of waste must be taken on at least one occasion in every 3 month period: i.
gas velocity and volume flow rate, ii.
temperature, iii.
water vapour concentration, and iv.
mass rate and concentration of:
1) total particulates
2) hydrogen chloride
3) hydrogen fluoride
4) carbon monoxide
5) carbon dioxide
6) TOC
7) heavy metals
8) oxygen; c) the following tests must be conducted and samples of waste must be taken on at least one occasion every 12 months: i.
chlorinated aromatic hydrocarbons, and ii.
benzo alpha-pyrene; and iii.
Polychlorinated dibenzop -dioxins ("PCDD") and polychlorinated dibenzofurans ("PCDF") d) during the sampling periods referred to in sub-conditions (b) and (c) the following information must be gathered: i.
complete process and operating details, ii.
combustion efficiency, iii.
type of waste, iv.
waste feed rate, and v.
ash analysis for heavy metals; and e) ensure all records of analysis bear a National Association of Testing Authorities
(NATA) stamp of endorsement.
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EPA Waste Discharge Licence No. EM36133
Note: "Combustion Efficiency" means the concentrations, in ppm by volume, of carbon dioxide (C0
2
) and carbon monoxide (CO) expressed as the ratio: 100 x [CO
2
]/([C0
2
] + [CO]).
Discharge to Stormwater
3.2 Sampling of each stormwater interception pit referred to in condition 1.23 must be undertaken on at least one occasion in the months of February, May, August and
November each year in accordance with the following requirements: a) Samples must be taken by or under the instructions of a qualified chemist; b) Samples must be taken, presented and analysed as specified in the most recent edition of EPA publication 441 “A
guide to the sampling and analysis of water and wastewater” or other methods approved by EPA; c) Samples must be analysed and reported by a NATA accredited laboratory for that purpose; d) Samples must be analysed to confirm compliance with the State Environment
Protection Policy (Waters of Victoria) limits. Parameters may include concentration of Total Suspended Solids, COD, BOD, metals including zinc,
Anionic Surfactants and pH. e) The presence of visible floating oil, grease, foam or litter must be noted; and f) The licence holder must ensure that the following results are accurately recorded and maintained: i.
Sample analyses; ii.
Observations including comment on any visual presence of oil or sludge; iii.
Date and time of sampling and name of sampler; iv.
NATA accredited stamped and signed; v.
Analysis results tabulated in the form of a table; and vi.
Make the results available to an authorised officer of EPA upon any request to do so.
Groundwater
3.3 The licence holder must maintain groundwater monitoring bores in operation at the locations shown on the attached Plan of Premises.
3.4 The bores must be reasonably accessible at all times to any Authorised Officer of EPA or any Authorised Officer under the Water Act 1989.
3.5 Samples of water must be taken from the bores on at least one occasion in February and August of each year, and analysed or tested for the parameters listed in Table 3.
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EPA Waste Discharge Licence No. EM36133
Table 3: Groundwater monitoring parameters electrical conductivity pH temperature total dissolved solids silver copper lead mercury ammoniacal nitrogen chemical oxygen demand zinc chromium alkalinity as calcium carbonate
3.6 All samples must be: a) obtained by or under the instruction of a qualified analyst; b) preserved and analysed as specified in the most recent edition of EPA publication
441 "A guide to the sampling and analysis of water and wastewater" , or by other methods approved by EPA; and c) analysed and reported by a NATA accredited laboratory for that purpose.
3.7 Standing water level in the bores must be measured and recorded on each occasion that samples are obtained in accordance with condition 3.5. 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.
3.8 The licence holder must ensure that the following results are recorded and accurately maintained: a) Sample analysis; b) Observations ; c) Date and time of sampling; and d) Make the results available to an officer of EPA upon request.
3.9 The licence holder must forward to the Department of Natural Resources and
Environment, Project Manager, Groundwater Database, 240 Victoria Parade, East
Melbourne a copy of the record of all analyses, measurements and observations within
28 days of the completion of analyses for each sampling occasion in the groundwater monitoring program referred to in conditions 3.5 to 3.8.
Spill, leak and exception reporting:
3.10 The licence holder must, in the event of any:
- spillage of waste, chemicals or effluent leaving the boundaries of the premises,
- fire,
- air emission inconsistent with normal incineration operations,
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EPA Waste Discharge Licence No. EM36133
- monitoring result in breach of this licence, or
- other incident or equipment failure that causes a breach of this licence: a) immediately inform EPA by telephone; and b) report to EPA in writing within 7 days of such an event , detailing: i.
its nature and cause; ii.
the action taken at the time to clean up the spillage or to restrict any adverse discharge; and iii.
the measures proposed to prevent its recurrence.
Annual report
3.11 By the 31 January each year the licence holder must submit a report in writing for the previous calendar year to EPA containing:
Financial assurance: a) confirmation of the continuance of the EPA endorsed financial assurance;
Air emissions: b) the previous year's air monitoring results obtained in accordance with condition 3.1; c) an assessment of the air monitoring data against the licence requirements;
Stormwater: d) the previous year's stormwater monitoring results obtained in accordance with condition 3.2; e) an assessment of the stormwater monitoring data against the licence requirements;
Groundwater: f) the results of the groundwater monitoring program required by condition 3.5 to 3.8; g) comments on the results of the groundwater monitoring including trends in quality of groundwater;
Waste processed and recycled; fee review: h) the total mass and type of waste incinerated during the year; i) the total mass of prescribed industrial waste accepted at the premises for treatment or storage;
Environment improvement plan: j) advice on any works proposed to improve performance at the premises; and k) progress in implementing and any changes proposed to the Environment
Improvement Plan.
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EPA Waste Discharge Licence No. EM36133
4. PLAN OF PREMISES
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