application form for epa works...

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Application form for EPA works approval

How do I complete and submit this application form?

Contacting EPA

Please contact EPA:

if you have any questions regarding the works approval process

before preparing your application to confirm you require a works approval.

About this application form

This application form works in parallel with the new works approval guidance, which describes the level of information required to fill out the form appropriately. The sections of this form correspond directly to the sections of the guidance.

If, while preparing your application you require advice on:

the level of information needed

further consultation with other agencies and neighbouring communities

please schedule a meeting with EPA. This is usually best done once you have completed sections 1 to 8.

The form allows you to add text directly to the form and save it. The completed form can then be printed and sent to EPA. The full application will usually be 10-20 pages, plus any required attachments (i.e. certificate of registration, site map, technical data etc.). If any of the information you are providing is `commercial in confidence' it should be marked as such, and attached separately.

EPA welcomes feedback on the application form.

How do I submit the application form?

Once you have completed your works approval application, the following should be forwarded to Environment Protection Authority (GPO Box 4395, Melbourne 3001):

completed application (sections 1 to 8 and the relevant A to I sections)

application fee

relevant supplementary information.

Note: Please supply both a hard and electronic copy (cd is preferable).

Once EPA confirms that your application is complete, the formal environmental assessment of your project begins.

http://epanote2.epa.vic.gov.au/EPA/publications.nsf/2f1c2625731746aa4a256ce90001cbb5/a6469089d1f5b649ca25765b001f4a51/$FILE/1307.pdf


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1. APPLICANT

1.1 Company details

Company name ACN

Australian Tartaric Products Pty Ltd 92 008 275 554

Registered address

Cummings Flavel McCormack, Level 15, 390 St. Kilda Rd, Melbourne Vic.3000

1.2 Contact details

Name Position

Sam Testa General Manager

Phone Email

03 50291450 [email protected]

1.3 Premises details

Premises address Municipality

1074 Boonoonar Road Colignan, Vic. 3494 Mildura Rural City Council

2. PROPOSAL

2.1 Project description

Provide a simple, one-line explanation of the project. Attach a site and location plan.

A renewable fuel Biomass Boiler to be installed replacing the existing fossil fuel boilers for the purpose of producing the plant’s steam requirements.

2.2 Cost of works and application fee

Cost of works Application fee

4.73 million $8,810.60

2.3 Proposed dates

Start construction: Month, Year Start operation: Month, Year

March, 2012 January, 2013

3. APPROVALS

3.1 Need for works approval

Schedule type Act section that applies

L01 19A (1)(a), (1)(b), (1)(c), (1)(d), (1)(e)

List any exemptions that apply: section of the Regulations

N/A


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3.2 Planning and other approvals

Planning Zone Type of approval required

Farming Zone (FZ) Planning Permit

Approving authority Approval received or pending

Mildura Rural City Council Pending

3.3 Existing EPA approvals (if any)

List any EPA documents held

Nil

4. ENVIRONMENT AND COMMUNITY

4.1 Track record

Summarise the company’s recent environmental performance

The company has an excellent environmental performance record. On a yearly basis the company is obligated to report to the EREP program. This boiler project was a non-mandatory action item in our EREP program but we have chosen to proceed with its implementation nonetheless. The company serves an integral and vital role in the Australian wine industry as it collects and processes byproduct waste material from most wineries in the Murray Valley, Riverland and Riverina regions. Without the existence of our plant, tens of thousands of tones of waste matter would need to be disposed in currently overburdened landfill facilities.

Report any relevant offences; e.g. indictable and summary offences

List any enforcement actions related to this site

Minor Works Pollution Abatement Notice EPA Act 1970, Section 31(B)1, Your Ref: 25535 – 14th March 2001. Revoked 7th June 2001.

4.2 Key environmental considerations

List the main environmental aspects of your proposal

The proposed Biomass Boiler will provide a sustainable solution to our energy needs by; - reducing our reliance on fossil fuels thereby reducing our carbon emissions - closing the loop on approximately 45,000 tonnes of waste grape Marc from the wine industry by ensuring the waste grape marc doesn’t end up in landfill.

The proposed renewable energy boiler will boost confidence in ongoing investment in the region’s wine industry by ensuring a sustainable, reliable and commercial option for the disposal of waste grape marc.

4.3 Community engagement

Summarise any public consultation that has been undertaken or planned

None to date but plan to consult with the local community


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Indicate any issues that have been raised


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5. PROCESS AND BEST PRACTICE

5.1 Process and technology

Key process steps

Key inputs Key outputs Key controls

Marc drying Spent Marc Marc moisture content within acceptable limits

Laboratory monitoring of dried marc moisture content

Boiler make-up water preparation

Raw water Boiler feed water

As per current practice – daily laboratory analyses

Marc burnt in boiler

Dried Marc Boiler feed water

Process steam

Pressure control Boiler level control

Blowdown Regular manual measurement of conductivity of boiler water

Flue gas Ash Fly ash

CO, NOx, ash and dust emissions monitored to ensure compliance limits met Injection of calcium carbonate slurry to remove HCl and SOx. Bag filter to remove fly ash Wet collection system for ash from below and at end of grate Good combustion practices:

Water-cooled, hydraulically operated linear grate.

Under-grate injection of preheated primary air

Secondary air injected above grate with high turbulence.

High gas residence time and high temperature in combustion chamber to allow complete combustion of volatiles

Monitoring of flame shape colour and position via CCTV to enable correct air to fuel ratio to be achieved.

Periodic ash analysis to ensure


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Key process steps

Key inputs Key outputs Key controls

satisfactory burnout of combustible matter.

5.2 Environmental best practice

Indicate steps taken to determine industry best practice

Global investigation undertaken to determine possible uses for disposing of spent Marc. Visited a working biomass (spent Marc) boiler in Italy.

Explain why waste generation and resource use cannot be avoided or minimised

Waste generation will be reduced significantly by this project. Current practice is to dispose of this product into landfill. If the proposed project does not go head, this practice will continue.

Explain options considered and why this process is considered best practice

We believe that using our spent Marc as a renewable fuel will reduce the pressure on already overburdened landfill and as a secondary benefit replace our current reliance on fossils fuels for our energy needs.

5.3 Integrated environmental assessment

Indicate any areas where there are competing environmental demands

None

Indicate how you will determine net environmental benefit in these areas

Not Applicable


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5.4 Choice of process and technology

Process or technology Advantages Disadvantages

Bono Sistemi reciprocating grate combustion system and heat recovery system based on water tube heat recovery boiler

50 years experience in the field of heat & power generation system using wood, olive husks, agricultural wastes, etc

Existing (identical plant) burning exact same fuel experience at our parent company’s site in Italy

None that we’re aware of

RCR Energy Systems Moving air-cooled grate single combustion chamber

Large & experienced company

No experience burning spent Marc

Visdamax Two parallel combustion systems each comprising understood pile “Bio T-burner”

No experience burning spent Marc

Malaysian Company with little representation in Australia

5.5 Choice of location and layout

Location or layout Advantages Disadvantages

Existing LPG facility site Already achieves buffer distance compliance as a consequence of the site already being a dangerous goods facility.

Proximity to existing boiler steam manifold distribution point.

nil

6. RESOURCES

It is worth noting that Australian Tartaric Products already submits yearly reports as part of its

regular reporting obligations to EREP, NGER and NPi.


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6.1 Carbon

Type of energy use or greenhouse gas emission Amount in GJ/yr or tCO2e

Organic spent Marc 284,000 Gj/yr

Currently the plant’s steam requirements are met from LPG-fired boilers. Greenhouse emissions from this brown fuel are currently 9,000 – 10,000 tCO2e/yr. With the proposed biomass boiler, net greenhouse emissions are expected to be close to zero tCO2e/yr.

6.2 Water use

The water usage: ML per year

Water usage is expected to be essentially unchanged as the consumption of water is a factor of the amount of steam generated by the boiler. We are not expanding our plant production output but merely replacing our existing fossil fuelled boilers with a new renewable fuel boiler. Consequently water usage is expected to remain relatively unchanged.

6.3 Solid waste

Type of solid waste Amount t/yr Destination

Wet Ash 507 To be finalized, possibly Adelaide Brighton Cement

Dry Ash 158 To be finalized, possibly Adelaide Brighton Cement

6.4 Prescribed industrial waste

Type of prescribed waste Amount t/yr Destination

Not Applicable

7. EMISSIONS

7.1 Air emissions

Type of air emissions Rate or scale of emissions List any class 3 indicators

CO 90 kg/day (max)

NOX 300 kg/day (max)

7.2 Discharge to surface water

Provide reasons for any discharge to water (rather than to sewer or to land)

Not Applicable

Rate of discharge to water; litres per day Indicate water quality or treatment level

7.3 Discharge to land

Rate of discharge or deposit to land, Types of waste and level of treatment litres/or tonnes per day e.g. secondary or tertiary

Approximately 2.5 KL/day discharged to Boiler water is blended with existing water effluent


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effluent system as per current EPA sanctioned practices.

which is discharged to existing woodlots. Hundreds of acres of native trees are grown and managed with the organic effluent.

For reuse, demonstrate that the proposal will meet EPA guidelines

Provide the reasons for any discharge to groundwater and indicate segment

7.4 Noise emissions

Hours of operation Noise sources Are they audible at nearby residences?

Mainly 24/7 Mainly fans, some electric motors

No

8. ENVIRONMENTAL MANAGEMENT

8.1 Non-routine operations

List process upsets that could impact on the environment

Non-routine process upsets will be mitigated by installing a backup generator for critical components. This will ensure orderly shutdown if necessary thereby avoiding any potential environmental impact.

8.2 Separation distances

Proposed buffer distances, in metres Recommended buffer distance, in metres

Greater than 500m from nearest neighbour 300m

8.3 Management system

Explain the system that will be used to manage environmental risk

An emissions monitoring plan will be devised to ensure compliance with licence conditions. The plan will be developed using a risk based approach, ie. The probability and severity of deviations will determine what measures are put in place to monitor compliance. Both wet and dry ash discharges to be collected in bulk bins and disposed of according to legislative requirements (planning to dispose to Adelaide Brighton Cement or similar organisation). As the new boiler is simply replacing the existing one, boiler blow downs (quantity and quality) will be similar to current practice (no additional load) and will be managed using existing procedures.

8.4 Construction

Identify any environmental risks that will need to be managed during installation

Not Applicable

Identify any existing site contamination issues

Not Applicable

Explain how construction will be managed to prevent environmental impacts

A comprehensive construction environmental management plan will be developed and implemented.


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We do not envisage any significant environmental risks at this point however the plan will address the management of any issues that may arise during the construction phase.

Application Form for EPA Works Approval

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A. CARBON

A1. Energy use and greenhouse gas emissions

Note any existing energy use and greenhouse gas emissions

Currently both ATP’s boilers are fired by LPG (fossil fuel).

Type of energy use or Amount (TJ/year) or Process step greenhouse gas tCO2e/year

Boiler (Maxitherm) LPG (Butane) ≈ 4,500 tCO2e/yr

Boiler (Tomlinson) LPG (Butane) ≈ 4,500 tCO2e/yr

Basis for numbers

EREP reports

A2. Best practice carbon management

Outline the steps taken to identify best practice carbon management

Decision made to install biomass-fired renewable energy boiler to replace existing fossil fuel boilers

Summarise the options considered to avoid or minimise carbon emissions

This is the only option that eliminates the need for landfill of spent grape marc and significantly reduces carbon emissions.

Explain why the chosen option is best practice

This is the only option that eliminates the need for landfill of spent grape marc and significantly reduces carbon emissions.

B. WATER

B1. Water use

Note any existing water use

Water is required by the boiler to produce plant steam demand. Condensate is returned to the boiler, the balance is consumed in the process via direct steam injection. The new boiler will operate in the exact same way as our existing boilers.

Process step Type of water use Amount (ML/year)

Boiler feedwater preparation Boiler feedwater 25

Basis for numbers Internal consumption figures

B2. Best practice water management

Outline the steps taken to identify best practice for saving water

Water consumption is very dependent on the quality of the incoming water. There is little that can be done practicably to reduce water consumption. Reducing steam consumption would reduce water usage, but would have a severe impact on production output and quality.


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Steam usage per tonne of production is similar to parent company’s plant in Italy

Summarise the options considered to avoid or minimise water usage

Regular monitoring of the conductivity of the boiler water will continue, to avoid unnecessary blowdown.


Comparison with parent company’s operation shows similar results.

C. SOLID WASTE

C1. Solid waste generation

Note any existing solid waste generation

Wet Ash, Dry Ash, dust at baghouse filter

Process step Type of waste generated Amount (t/year)

Combustion Wet Ash 507

Dry Ash (boiler & economizer) 158

Dust 190

Basis for numbers

Manufacturer provided

C2. Best practice solid waste management

Outline the steps taken to identify best practice for solid waste management

Solid waste (ash) will be collected in contained vessels and disposed of according to licence requirements.

Summarise the options considered to avoid or minimise solid waste

Process control monitoring to ensure efficient burning of fuel thereby minimizing solid waste output. Where practicable, ash will be sent to a suitable contractor (ie: Adelaide Brighton Cement) or sold to local farmers for use as fertiliser or soil conditioner.


Using ash as a feedstock for cement manufacture or as a fertiliser reduces the need for this material to be sourced from other places.

Indicate where these wastes will go

Adelaide Brighton Cement or similar organization Local farmers

D. PRESCRIBED INDUSTRIAL WASTE

D1. Prescribed industrial waste generation

Note any existing prescribed industrial waste generation

Not Applicable

Process Type of waste Waste category Amount (t/year)


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Basis for numbers

D2. Best practice prescribed waste management

Outline the steps taken to identify best practice for prescribed waste

Not Applicable

Summarise the options considered to avoid or minimise prescribed waste


Indicate where these wastes will go

E. AIR

E1. Air emissions

Note any existing air emissions

CO, NOX, Particulates

Process step Type of air emission* Amount (g/min)

Combustion CO 63 (max)

NOX 146 (max)

Particulates 21 (max)

*Identify any class 3 indicator emissions

Basis for numbers Manufacturer provided

E2. Best practice air emissions management

Outline the steps taken to identify best practice for air emissions

European boiler manufacturer with experience in burning grape marc chosen so that best European practice is integrated into design.

Summarise the options considered to avoid or minimise air emissions

Baghouse filter installed to mitigate emissions of particulates. Other options include wet scrubber or electrostatic precipitator (ESP). Calcium carbonate slurry injected into flue gas to remove HCl and SOx. Alternative option is to do nothing, as these emissions would otherwise be small, as fuel is not high in sulphur or chlorine.


European boiler manufacturer with experience in burning grape marc chosen so that best European practice is integrated into design. Wet scrubbers would consume additional water. ESP probably less effective due to high moisture content of fuel. #For class 3 indicator emissions assess against maximum extent achievable


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E3. Impact on air quality

Predicted maximum concentration (project)1 Background concentration

* Ausplume modelling predictions – 99.9th percentile – refer to attached report

CO 0.08 mg/m3 Not available – assumed small

NOX 0.18 mg/m3 Not available – assumed small

Particulates 0.026 mg/Nm3 Not available – assumed small

Predicted maximum concentration (total)^ Design criteria (mg/m3)

CO 0.08 mg/m3 29

NOx 0.18 mg/m3 0.19

Particulates 0.026 mg/ Nm3 0.08 ^Where any predicted concentrations are above the design criteria, provide a risk assessment. Assess any emissions that could impact on regional air quality.

F. WATER

F1. Water discharges

Note any existing water discharges

Boiler blowdown and boiler feedwater preparation will be handled as per current practice, in similar quantities. Process step Type of water discharge Flowrate (L/day)

Boiler blowdown Intermittent discharge of water with pH approx 10 - 11 and TDS approx 2000 ppm

2500 L/day

Basis for numbers

Current practice

F2. Best practice water management

Outline the steps taken to identify best practice for discharge to water

The new biomass boiler is simply replacing our existing boilers and this will result in commensurate water discharge both in quality and quantity as currently occurs under our current practices. No additional water discharge over and above current volumes (detailed above) is expected.

Summarise the options considered to avoid or minimise water discharges

1 These are rough estimates of worst case and have NOT been modelled using Ausplume data or techniques.


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Benchmarking against parent company’s plant in Italy shows that steam consumption is already close to optimum. We have no control over in feed (river) water quality.

Explain why the chosen option is best practice The company already submits to EREP where water resource efficiencies have been addressed.

F3. Impact on waterway

Indicator Maximum concentration Median concentration (mg/L)

Not Applicable

Water quality objective^

^Where any predicted concentrations are above the objectives, provide a mixing zone assessment

G. LAND AND GROUNDWATER

G1. Discharge or deposit to land

Note any existing discharge or deposit to land

ATP currently discharges its boiler blowdown water to irrigated woodlots on the property. This practice has been approved by the EPA in the past and since 1995 (after been given authorization by the EPA) we have been on a self monitoring program with regard to the management of this discharge. The new boiler will be replacing the existing boiler and consequently discharge volumes are anticipated to remain the same.

Process step Type of discharge Flow rate (L/day)

Boiler blowdown Intermittent discharge of water with pH approx 10-11 and TDS approx 2000 ppm

2500 L/day

Or Type of waste Amount (t/year)

Basis for numbers

Current practice

G2. Best practice land and groundwater management

Outline the steps taken to identify best practice in discharge or deposit to land

Our plan is to continue the current practice (sanctioned by the EPA) of disposing the discharge water to our extensive native tree woodlots onsite. Discharge water pH is continuously monitored by our Laboratory staff and regular grab samples are sent to an independent laboratory for additional analyses. The woodlots are maintained by our Farm Manager. A rotational system of irrigation is employed. Additional woodlots are planted on a regular basis and water and soil monitoring by an independent laboratory is undertaken as part of our environmental self assessment program.


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Summarise the options considered to avoid or minimise discharge to land

Boiler blow downs kept to minimum in order to minimize energy and water losses.

For landfills, demonstrate best practice siting and design


G3. Impact on land and groundwater

Provide a land capability assessment

ATP has employed regular and independent testing of both water and soil quality for many years now as part of its environmental self assessment program. A yearly performance review program is also in place to ensure the sustainability of its operation. ATP is aware of its environmental responsibility and part of its environmental policy is to ensure that the disposal of its wastewater is conducted in a manner, which does not adversely impact on its land or the surrounding environment. We employ a simple intermittent rotational irrigation methodology using a set of travelling irrigators, which allows wastewater to be sparsely discharged over the available land. Our policy is to observe a dry buffer area of approximately 100 metres between our property and our neighbours. ATP believes that the combination of a low impact rotational irrigation philosophy coupled with a considerable irrigable land area and the use of trees will ensure a sustainable an effective wastewater disposal system. An added advantage of this type of wastewater disposal is the mitigation of offensive odours. A full time Farm Manager is employed to oversee the wastewater disposal system. That person monitors, records and regulates the volume and distribution of water discharged over the available land area. The land is also regularly tilled to improve organic decomposition and soil quality. He liaises with factory Supervisors and Production Manager as part of his daily responsibilities and reports directly to the General Manager. Our environmental policy encompasses the following objectives;

Use of wastewater disposal practices to ensure long term sustainability Continue yearly tree planting vegetation program thereby enhancing the aesthetics of

our environment Monitor and review water and soil analysis results and obtain independent expert

advice on soil condition Have sufficient trees to ensure volume of water uptake by the trees is always greater

than the volume of wastewater discharged Continual diminution of wastewater discharge volume per hectare

Independent soil analysis results have been very encouraging and vindicate our wastewater disposal system practices, as there appears to be no significant effect on the soil structure. In fact we believe that the wastewater discharge is enhancing the soil structure and condition. The natural sandy soil is of poor agricultural quality and prone to soil erosion by regular dust storms. The application of water in this situation is proving to have multiple benefits. It enhances the otherwise poor nutrient/organic soil quality and the added moisture content along with stability afforded by the tree root system mitigates soil erosion by wind. The


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growth and health of the trees is testament to their capacity to absorb and in fact flourish on the wastewater discharge. Additional benefits include enhanced environment via improved aesthetics and positive outcomes in relation to salinity. A yearly audit and review is conducted to assess our performance in meeting our stated environmental objectives. The review addresses critical aspects of our environmental objectives and operating conditions including;

Standards to be maintained Actions to be taken if required standards not met Summary of complaints and follow up actions Overall assessment of environmental performance Review of tree planting program Review of water and soil analysis Consideration of opportunities to improve on environmental performance

Senior management is briefed on the review and any recommendations that may arise from this assessment. ATP is using the wastewater from its Tartaric Acid operation to grow a plantation of Murray River Red Gums. This is solving a problem posed by large volumes of wastewater that cannot be treated easily when disposed of by traditional lagooning methods. The trees are a resource for the future, are aesthetically pleasing and are ensuring that ATP’s wastewater doesn’t add to the salinity problems facing the region as a consequence of past land clearing. The obvious benefits of our wastewater disposal system and irrigated woodlot plantation includes:

Economical disposal of wastewater Elimination of problem odours Aesthetic benefits to the area A renewable future timber resource A sustainable practice for the region’s salinity problem

Trees are also obviously good for the environment, good for the soil and good at not contributing to the region salinity problems. Our trees are healthy and we believe they are contributing to enhanced environmental outcomes on our property, none more evident than eliminating soil erosion by wind. Soil analysis results vindicate our current practices and concord with a sustainable operation. The volume of water discharged by our operation is well below the quantity of water taken up by our woodlot plantation and consequently we believe does not impact on the water table or our neighbours. Groundwater Indicator Predicted Concentration Water quality objective^

^Where any predicted concentrations are above the objectives, provide an attenuation zone assessment


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Assess any impacts on the level of the water table

Independent and regular soil tests data show no significant impact.

H. NOISE EMISSIONS

H1. Noise emissions

Process step Source/type of emission Sound power level (dBA)

Combustion Boiler FD and ID fans Other motors Occasionally, steam venting.

85 dBA at 1.5m

Basis for numbers

Manufacturer provided

H2. Best practice noise management

Outline the steps taken to identify best practice for noise emissions

The boiler will be located out in the open and hence the noise level (refer above) will be dispersed into the ambient rural environment. (see attached aerial view)

Summarise the options considered to avoid or minimise noise emissions

Proposed boiler plant has been located behind existing warehouses which will provide a buffer zone to existing roadway


Outdoor and set within an isolated rural area away from any residential dwellings represents best possible option for mitigating any impact on existing amenity.

H3. Noise impact

Location of Noise levels Existing noise Background receptor(s) from project^ levels (site)^ noise level^

Not Applicable

Total noise level^ Noise limit^

^dBA for each of day, evening and night where relevant. Where existing site noise is above the limit, provide a noise reduction plan.

I. ENVIRONMENTAL MANAGEMENT

I1. Non routine operations

Outline the steps taken to identify potential process upsets or failures

A diesel generator is being procured for critical boiler components so as to enable an orderly shutdown of the plant in the likelihood of a power outage

Outline approach to identifying best practice in managing these environmental risks

A backup power generator will be used to orderly shutdown the boiler in the advent of loss of power or water availability at the site.


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Type of process upset Potential environmental Measures to reduce

impact likelihood and impact

Loss of power Nil as backup generator is planned

300 – 400 Kva Power generator being purchased

Loss of water None – plant will shut down automatically on low water level in boiler system.

None – already low risk.

Explain why the buffer distance to residents is acceptable

The plant is situated in a rural area and the nearest neighbour is hundreds of meters away

I2. Monitoring

Indicator Monitoring Monitoring Use of Process Measured type frequency monitoring

Boiler Flue gas quality Oxygen content Continuous Combustion control

Boiler Flue gas Temperature Continuous Combustion control

Boiler Blowdown Water quality (TDS, boiler chemical concentration)

Daily as per current practices

Boiler operation control

APPLICANT STATEMENT

I declare that to the best of my knowledge the information in this application is true and correct, that I have made all the necessary enquiries and that no matters of significance have been withheld from EPA. Signed CEO or delegate


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