Changes at IPPC and Waste Licensed Facilities

What needs to happen when there are changes at a licensed facility that may have an environmental impact? 3 common scenarios are outlined below;

Minor Changes - such as minor changes to process, raw materials, final product and abatement with no impact on emissions.

These are usually accommodated under Condition 1.4 of the IPPC licence, which requires the licensee to obtain approval from the EPA but does not involve a Technical Amendment of Licence Review.

Changes - such as moving existing emission points, changing flows (but not increasing mass emissions), increasing mass emissions for a particular emission point but keeping the 'bubble limit' for the site the same or less.

These would normally be accommodated under a Technical Amendment to the licence where the overall mass emission of substances from the site is the same or less, there are no new substances emitted and there is no increased impact on the environment. The Technical Amendment will allow for changes to be made to the licence and is a process that can be completed in approximately 4 months.

Significant Changes - additional emission points, additional substances emitted, increased overall mass emission, increased impact on the environment or new major abatement will normally trigger a Licence Review. The review process is similar to an application for a new licence and will normally take a minimum of 9 months to complete.

Please note that the EPA tends to deal with this issue on a case-by-case basis. If you have any concerns regarding planned changes at your facility please feel free to contact Environet Solutions.