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: CHEMSAL PTY LTD REGISTERED ADDRESS: C/O STANNARD COGHLAN & ANGELINI, 60 TOORAK RD, SOUTH YARRA VIC 3141 PREMISES ADDRESS: 83 DOHERTYS RD, LAVERTON NORTH VIC 3026 LICENCE NUMBER: EI2 DATE OF ISSUE: 12 JANUARY 1988 DATE OF AMENDMENT: 26 FEBRUARY 2002 ................................................................ WAYNE SAUNDERSON SECRETARY Page 1 of 17 EPA Waste Discharge Licence No. EI2 Plant Activities This licence applies to a premises where prescribed wastes are reprocessed, treated and stored. Licence Objectives 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); Industrial waste management policy (Prescribed Industrial Waste); Industrial waste management policy (Movement of Controlled Waste between States and Territories ); 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 (Noise from Commerce, Industry and Trade) Licence Structure operate in accordance with good environmental practice at all times; and take opportunities 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. specifies which wastes may be stored, treated or otherwise disposed of and the general requirements under which this may occur. 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 environment under both normal and plant upset conditions. 3. Monitoring and Reporting specifies the monitoring requirements and the arrangements for submission of reports to EPA. 4. Plan of Premises plan of the premises covered by this licence, including discharge points and reprocessing, treatment, storage or disposal areas. Page 2 of 17 EPA Waste Discharge Licence No. EI2 DEFINITIONS For the purposes of this licence the following interpretations apply: “Controlled waste” means any waste as defined under Clause 3 of the National Environment Protection Measure (Movement of Controlled Waste between states and territories) dated 26 June 1998. “Discharge” when used as a noun includes emission and any other grammatical terms of that word shall have a corresponding meaning. “EPA Victoria” means Environment Protection Authority. “NHMRC” means National Health and Medical Research Council. “ARMCANZ” means Agriculture and Resource Management Council of Australia and New Zealand. “Polychlorinated biphenyls” are any material or waste containing polychlorinated biphenyls at a concentration of more than 2 mg/kg. “Polychlorinated Biphenyls Management Plan” is the national plan for the management of polychlorinated biphenyls published by the Australian and New Zealand Environment and Conservation Council in November 1996, as amended from time to time or republished by ANZECC. “Reprocessing” means changing the nature of a specific waste, so that it is suitable for reuse. “Stabilisation” means immobilisation of contaminants into concrete blocks to prevent leaching of contaminants into the environment and to achieve compliance with the limits specified in the destined landfill licence. “Storage Only” means storing of waste, repackaging and consolidation of similar waste, but excludes physical and chemical manipulation of waste by such activities as blending, stabilisation, neutralisation, thinning etc. “Waste” means prescribed waste as defined in Environment Protection (Prescribed Waste) Regulations 1998. "Waste Type Code" is the four –digit code corresponding to the prescribed waste as listed in EPA Victoria Information Bulletin Industrial Waste Strategy; Instructions for Completion of Waste Transport Certificates, Publication No. 395. Page 3 of 17 EPA Waste Discharge Licence No. EI2 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 locations of which are 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 the Table 1; c) from the corresponding discharge point specified in Table 1 at a rate not exceeding that specified in the Table; d) from the corresponding discharge point specified in Table 1 at a concentration not exceeding that specified in the Table; e) from the corresponding 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 corresponding discharge point specified in the Table. 1.3. Odours offensive to the senses of human beings must not be discharged beyond the boundaries of the premises. Discharges to Water 1.4. There shall be no discharge or seepage of waste from the premises to the land, groundwater or water environments. 1.5. Any discharge to sewer shall be with the approval of the relevant Water Authority. 1.6. Stormwater discharged from the premises must not contain visible floating oil, grease, scum, litter or other objectionable floating matter. 1.7. Waste collected within bunded areas must not be discharged to the stormwater drainage system or to the land environment. Page 4 of 17 EPA Waste Discharge Licence No. EI2 Table 1: Emission Limits and Discharge Requirements DISCHARGE POINT IDENTIFICATION DISCHARGE REQUIREMENTS EMISSION LIMITS MONITORING FREQUENCY* DP No. Discharge Point Description Min. Stack Height (m) Min. Velocity (m/sec) Compound Maximum Rate (g/min) *(ouv/min) Maximum Conc. (mg/m3) *(ouv) 1 Caustic Scrubber 13.5 15 Particles 118 250 Notes "DP" means discharge point(s). aMonitoring of emissions should be conducted during waste stabilisation processes and the emission rates are at maximum level . bIn addition to particles, emissions must also be monitored for Mercury, Lead, Arsenic and speciation of organic compounds. Page 5 of 17 a,bOnce every four months EPA Waste Discharge Licence No. EI2 Waste Acceptance 1.8. No wastes other than those specified in Table 2 and corresponding to the waste type code specified in that table may be accepted on the premises. 1.9. Waste accepted at the premises must be accompanied by an EPA Victoria waste transport certificate which has been completed in accordance with the Environment Protection (Prescribed Waste) Regulations 1998. Interstate Wastes Acceptance and Disposal 1.10. Waste or controlled wastes from interstate must not be accepted at the premises unless those wastes are accompanied by a consignment authorisation number issued by EPA Victoria. 1.11. Waste or controlled wastes from interstate must not be disposed of to any landfill or sewer within Victoria following storage or treatment unless approved by EPA Victoria in writing. Waste Quantity 1.12. No more than 150 tonnes of waste may be held on the premises at any time. Waste Storage Period 1.13. Waste must not be held on the premises for a period greater than 12 months from the date of receipt of the waste, except with written approval from EPA Victoria. Storage and Treatment Area 1.14. Wastes must be stored and treated only within those areas of the premises marked on the attached Plan of Premises as Warehouse 1, Warehouse 2, Warehouse 3, Warehouse 4, Oxidising Chemical Storage, and Process Area 4. 1.15. All storage areas on the premises must always be provided with clear signage which corresponds to the markings provided on the attached plan premises. 1.16. All waste, process chemicals or products must be unloaded, loaded, treated and stored only within areas which are provided with a bunding constructed, sized, operated and maintained in accordance with the EPA Publication No. 374 “Bunding Guidelines” or an equivalent containment. 1.17. All bunding referred to in condition 1.16 must be maintained free of gaps and cracks. 1.18. There must be no gaps or cracks between the walls and the floors of the: a) warehouses; b) shipping containers used for storing oxidising chemicals; and c) shipping container used for washing drums. Waste Treatment 1.19. Wastes accepted at the premises must only be treated by the treatment method(s) specified for that waste type in Table 2. 1.20. Treatment of waste must be limited only to the following areas as marked on the attached plan of premises: Page 6 of 17 EPA Waste Discharge Licence No. EI2 a) stabilisation; b) blending; c) acid-base neutralisation; d) storage; e) drum washing; and f) drum decanting. Polychlorinated Biphenyls 1.21. No more than 10 tonnes of waste substances and articles containing or contaminated with polychlorinated biphenyls may be held on the premises at any time. 1.22. Waste substances and articles containing or contaminated with polychlorinated biphenyls must not be held on the premises for a period greater than six (6) months from the date of receipt of the waste. Labelling 1.23. All the containers holding waste must be appropriately and correctly labelled to enable tracking of waste origin. 1.24. The labelling referred to in condition 1.23 must include but not be limited to the following details: a) name of Waste Producer b) UN number c) tracking number; d) date of acceptance; e) description of waste; f) transport certificate number; and g) differentiation of interstate waste from wastes produced in Victoria. Page 7 of 17 EPA Waste Discharge Licence No. EI2 Table 2: Acceptable Wastes and Treatment methods Waste Waste Type Code* Acids in a solid form and acidic solutions with a pH value of 4 or less B100, B130, B160, C100, C140, M230 K150, M140 Alkaline solids and alkaline solutions with a pH value of 9 or more Animal and vegetable oils and derivatives Heterocyclic organic compounds containing oxygen, nitrogen or sulphur Highly odorous organic chemicals (including mercaptans and acrylates) Organic solvents (excluding halogenated solvents) Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish (n.o.s.) Waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives (n.o.s.) excluding solid inert polymeric materials Antimony and antimony compounds Arsenic and arsenic compounds Barium and barium compounds Beryllium and beryllium compounds Boron and boron compounds Cadmium and cadmium compounds Chromium compounds Cobalt and cobalt compounds Copper compounds Inert sludges or slurries Lead and lead compounds Mercury and mercury compounds Phenols and phenol compounds (including halogenated phenols) Selenium and selenium compounds Tannery wastes (n.o.s.) including leather dust, ash, sludges and flours Textile effluent and residues (n.o.s.) Waste from the production, formulation and use of biocides and phytopharmaceuticals (n.o.s.) Waste from the production, formulation and use of wood preserving chemicals Waste resulting from surface treatment of metals and plastics Inorganic chemicals (n.o.s.) Asbestos (all forms) Cyanides (inorganic) (organic) Detergents and surface active agents (surfactants) Halogenated organic chemicals (n.o.s.) Halogenated organic solvents B110, B140, B170, C110, C150, B120, B150, B180 C120, L110, Treatment Method Acid-base Neutralisation Acid-base Neutralisation K170 Blending Blending M200, M260, M270 Blending G100, G110, G120 Blending F100, F120, F140, F160, F180 Blending F110, F130, F150, F170, F190, F200 Blending D170 D130, H170 D290 D160 D310 D150 D140 D200 D190 T130 D220 D120, D121 M150 Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation Stabilisation D240 D141, K140 Stabilisation Stabilisation L140 H100, H110, H120, H140, H150, H160, L120 H180, H190 Stabilisation Stabilisation A100, A110 Stabilisation D370, D390 Stabilisation** (see note) Storage Only Storage Only N220 A120, A130 M210 M250 M160 G130, G140, G150 Stabilisation Storage Only Storage Only Storage Only Page 8 of 17 EPA Waste Discharge Licence No. EI2 Highly reactive chemicals (n.o.s.) Inorganic chemicals (n.o.s.) Inorganic fluorine compounds Inorganic sulphur containing compounds Isocyanate compounds Nickel compounds Oxidising agents including chlorates, perchlorates, peroxides Phosphorous and phosphorus compounds Prescribed wastes that are encapsulated, chemically fixed, solidified or polymerised Residues from industrial waste treatment or disposal operations (n.o.s.) including filter backwash waters Silver and silver compounds Tellurium and tellurium compounds Thallium and thallium compounds Vanadium compounds Vegetable, fruit, food processing effluent Vehicle, machinery and industrial plant wash waters with or without detergents Waste chemical substances from research and development or teaching activities (n.o.s.) that are new or unidentified substances with unknown human health or environmental effects Waste from production, formulation and use of photographic chemicals and processing materials Waste from the production, formulation and use of biocides and phytopharmaceuticals (n.o.s.) Waste from the production, preparation and use of pharmaceutical products (n.o.s.) Waste of an explosive nature not subject to other legislation including azides Waste substances and articles containing or contaminated with polychlorinated biphenyls or polybrominated biphenyls Zinc compounds *see definitions D280, E110, E130 D370, D390 D110 D330 M220 D210 E100 Storage Storage Storage Storage Storage Storage Storage D320, M190 N160, N170, N180 Storage Only Storage Only N200, N205, N210, T110 Storage Only D260 D250 D180 D270 K200 L100, L101, L150 Storage Storage Storage Storage Storage Storage T100 Storage Only T120, D261 Storage Only H130, H110, H150, R120, Storage Only H160, H100, H120, H140, L120. R130, R140 Only Only Only Only Only Only Only Only Only Only Only Only Only Storage Only E120 Storage Only M100, M110, M120 Storage Only D230 Storage Only **Only the inorganic compounds (n.o.s) specified below, are permitted to be stabilised (all others can be accepted for storage only): Aluminium and aluminium compounds Magnesium and magnesium compounds Manganese and manganese compounds Tin and tin compounds Note: n.o.s. means not otherwise specified. Page 9 of 17 EPA Waste Discharge Licence No. EI2 Financial Assurance 1.25. By 1 May 2002 the licence holder must provide a revised financial assurance acceptable to the Authority calculated by the method set out in the EPA Victoria Publication “Guidelines for Determining Financial Assurances for Schedule 4 Premises” in accordance with section 67B of the Environment Protection Act. Page 10 of 17 EPA Waste Discharge Licence No. EI2 2. ENVIRONMENT IMPROVEMENT PLAN AND OPERATIONAL CONTROLS 2.1. The plant must be operated in accordance with the Environment Improvement Plan (EIP) as amended and approved by EPA Victoria. 2.2. The licence holder must ensure that all waste containers are suitable for containing the designated waste. 2.3. By 31 May 2002 the licence holder must submit a revised Environment Improvement Plan to EPA for approval which must include but not limited to the following: a) procedures for the identification of the types of incoming waste including random sampling and monitoring mechanisms; b) proposed corrective measures in the event of the waste transport certificate description of the accepted waste not conforming with the waste analysis; c) procedures for clearly segregating specific waste types within the “Bond in Transit mixed area”; d) internal auditing procedures for assessing the age of the wastes stored at the premises; e) procedures for the internal transaction of any goods received as surplus chemicals as waste; f) procedures for providing batch composition for each of the bulk load resulting from blending operation; g) mechanisms to minimise the discrepancies between the data provided to EPA and the data captured by the licence holder on the waste transactions; h) procedures for reconciling of the total waste accepted, disposed and recycled at the premises i) measures for recording the details of all incoming waste that do not conform with the accompanying EPA Victoria waste transport certificate; j) mechanisms for reporting the waste discrepancies to EPA; k) procedures for storing highly odorous chemicals to minimise any off-site odours; l) maintenance of carbon beds attached to the drum washing enclosures; m) procedures on managing the ventilation air from the chlorinated hydrocarbon storage area; n) procedures for proper disposal of empty waste containers; o) procedures for minimising cross contamination of security destruction materials with wastes; and p) exploration of contingencies for storing any water resulting from potential fire. Air 2.4. The standard checklist as included in the approved EIP on the stabilisation process reaction vessel interlock must be completed on a daily basis. 2.5. The standard checklist as included in the approved EIP for the stabilisation process reaction vessel alarm must be completed on a daily basis. Fire Management Page 11 of 17 EPA Waste Discharge Licence No. EI2 2.6. Prior to the commencement of construction of any proposed modification to the premises, the Metropolitan Fire and Emergency Services Board must be notified of any such modifications and an application made for a revised fire protection report. 2.7. Any recommendations from the Metropolitan Fire and Emergency Services Board for additional fire protection facilities related to any proposed modification must be implemented prior to any materials posing an environmental hazard being placed in the modified area. Polychlorinated Biphenyls 2.8. The licence holder must manage polychlorinated biphenyls at the premises in accordance with the Polychlorinated Biphenyls Environment Improvement Plan as amended and approved by EPA Victoria. 2.9. The licence holder must only accept waste substances and articles containing or contaminated with polychlorinated biphenyls at the premises in accordance with the Polychlorinated Biphenyls Environment Improvement Plan as amended and approved by EPA Victoria. 2.10. Waste polychlorinated biphenyls must not be diluted without written consent from EPA Victoria. 2.11. The licence holder must only store, handle, treat and reprocess polychlorinated biphenyls within the area as delineated on the attached plan of premises. 2.12. The licence holder must maintain records of all polychlorinated biphenyls accepted at the premises that include but are not limited to: a) date of acceptance; b) description of the waste, including waste type code; c) origin of the waste; d) name of waste producer; e) quantity of waste received; f) concentration of polychlorinated biphenyls in the waste; g) location of the waste at the premises; h) transport certificate number (inwards); i) consent authorisation for polychlorinated biphenyls (inwards); j) date(s) of transport off-site; k) destination of the waste or product; l) quantity of the waste or product despatched; m) nature of the waste or product despatched; n) certificate of analysis for the waste or product despatched; o) transport certificate numbers (outwards); p) consent authorisation for polychlorinated biphenyls (outwards); q) consignment authorisation for movement of controlled waste between States and Territories (outwards); and r) reconciliation of the total waste accepted, disposed and recycled at the premises. Page 12 of 17 EPA Waste Discharge Licence No. EI2 2.13. The records required by condition 2.12 must be retained for a period of 2 years from the date of treatment or off-site transport of the waste. 2.14. The records required by condition 2.12 must be made available to any authorised officer of EPA Victoria when requested to do so. Non Conforming Wastes 2.15. The licence holder must isolate any batch of waste oil in the event that the certificate of analysis of that waste shows the concentration of polychlorinated biphenyls is greater than 2 mg/kg. 2.16. Waste isolated as per condition 2.15 must not be transported from the premises without written consent from EPA Victoria. Page 13 of 17 EPA Waste Discharge Licence No. EI2 3. MONITORING AND REPORTING General 3.1. All samples for analysis must be submitted to an analytical laboratory accredited by the National Association of Testing Authorities (NATA) to undertake the analyses specified in this licence unless prior agreement to do otherwise has been obtained from EPA Victoria. 3.2. The licence holder must ensure the results of the analysis are submitted to EPA Victoria in a NATA endorsed test report unless prior agreement to do otherwise has been obtained from EPA Victoria. 3.3. All samples must be obtained by or under the instruction of a qualified analyst. Air 3.4. The wastes discharged from the discharge point listed in Table 1 must be tested in accordance with EPA Victoria Publication No 440 "A Guide to the Sampling and Analysis of Air Emissions" at a frequency of not less than that specified in the Table. 3.5. Maintenance on the alarm system for pressure drop on the venturi scrubber must be performed on a monthly basis. Water 3.6. The licence holder must provide a detailed report by 30 June 2002 outlining a management plan for stormwater originating from the hatched area designated on the attached plan of premises. 3.7. The management plan referred to in condition 3.6 must incorporate but not be limited to the following elements: a) a suitably designed triple interceptor with a hydraulic capacity equivalent to 90%ile rainfall run-off; b) a first flush system capable of capturing the first 10mm of run-off from the hatched areas designated on the attached plan of premises; c) a lock off valve at the stormwater outlet; d) a monitoring program; and e) reuse options for any stormwater collected in the first flush system. Waste 3.8. The licence holder must sample and test each load of incoming waste in accordance with the Environmental Improvement Plan as submitted and approved by EPA Victoria. 3.9. All waste transported from the premises for disposal at a landfill must meet the acceptance standards in the relevant EPA licence for that landfill. 3.10. Notwithstanding the requirements specified in condition 3.9: (a) wastes listed in Table 3 must not be disposed to landfill unless the elutriable concentrations of contaminants in those wastes are less than 100 times the relevant guideline values specified in Australian Drinking Water Guidelines (NHMRC & ARMCANZ 1996) as amended from time to time or re-published; Page 14 of 17 EPA Waste Discharge Licence No. EI2 Table 3 Waste Waste Type Code Phenols and phenol compounds (including halogenated phenols) Waste from the production, formulation and use of biocides and phytopharmaceuticals (n.o.s.) Waste from the production, formulation and use of wood preserving chemicals M150 3.11. H100, H110, H120, H140, H150, H160, L120 H190 (b) by 1 May 2002, the licence holder must develop a protocol to the satisfaction of EPA Victoria which must contain testing and verification procedures for demonstrating that the wastes referred to in Table 3 meet the requirements specified in condition 3.10 (a); and (c) until the protocol referred to in condition 3.10 (b) is approved by EPA Victoria, wastes listed in Table 3 must not be disposed at any landfill. Waste sampling and analyses required by this licence must be conducted in accordance with EPA Victoria Publication No 441 A Guide to the Sampling and Analysis of Waters, Wastewaters, Soils and Wastes unless prior agreement to do otherwise has been obtained from EPA Victoria. Annual Report 3.12. By 30 September each year the licence holder must submit to EPA Victoria two copies of an annual environmental performance report for the previous financial year ending 30 June that includes but is not limited to: a) the quantity and type of prescribed industrial waste received; b) the treatment and fate of prescribed industrial wastes received; c) the total mass of prescribed wastes processed at the premises for reuse/recycling; d) the types and quantities of interstate wastes accepted; e) the treatment and fate of all interstate wastes received; f) the quantity, concentration and type of polychlorinated biphenyls consigned for destruction; g) summary of all Certificates of Destruction or Disposal of Polychlorinated Biphenyls issued and/or received; h) reconciliation of the amount of polychlorinated biphenyls consigned for destruction or disposal and the amount of polychlorinated biphenyls destroyed or disposed for which Certificates of Destruction or Disposal have been issued; i) a completed Notification of polychlorinated biphenyls form that specifies the quantity and concentration of polychlorinated biphenyls at or in excess of the threshold concentration and quantity of 50 mg/kg and 50 g stored at the premises as at 30 June; j) results of environmental monitoring required by condition 3.4; k) details of community liaison; l) a record of complaints; m) details of any enforcement action by EPA Victoria; Page 15 of 17 EPA Waste Discharge Licence No. EI2 3.13. n) a completed prescribed industrial waste Annual Return form; and o) a completed Fee Calculation form. The report required by condition 3.12 must be signed by the licence holder or their delegate. Record keeping 3.14. Records must be maintained in accordance with the EIP as submitted and approved by EPA Victoria to enable the identification of the source, location, stage of treatment, disposal route, transport certificate number and results of analysis, of any waste that has been accepted at the premises. 3.15. Records must be maintained in accordance with the EIP as submitted and approved by EPA Victoria detailing the quantity, physical form, method of treatment, date of dispatch, transport certificate number, results of analysis and destination of all waste which leave the premises. 3.16. The records specified in conditions 3.14 and 3.15 must be retained for a period of 2 years from the date of treatment, disposal or offsite transport of the waste. 3.17. Records required by conditions 3.14 and 3.15 must be made available to an authorised officer of EPA Victoria on request. Incident Reporting and Notification 3.18. The licence holder must notify EPA Victoria in writing as soon as practicable of any monitoring result which indicates a breach of any condition of this licence. 3.19. The licence holder must notify EPA Victoria of incidents in accordance with the approved EIP. 3.20. The licence holder must notify EPA Victoria immediately of any incident or spill of wastes containing or contaminated with polychlorinated biphenyls. 3.21. Within 3 days of the occurrence of an incident at the premises (conditions 3.18 to 3.20), as defined in the EIP, the licence holder must report to EPA Victoria in writing: a) the cause of the situation; b) the measures taken to rectify it at the time; and c) the measures proposed to prevent a recurrence of such a situation. Page 16 of 17 EPA Waste Discharge Licence No. EI2 4. PLAN OF PREMISES Page 17 of 17