IPPC licence application

- how to avoid the costs

As a result of changes in the IPPC Directive, more and more companies are required to have an IPPC licence. Where a licence is required, there are significant time and cost factors involved - not only in making the application, but also with ongoing compliance costs.

This article discusses the cost implications of a licence application and suggests that, where possible, the need for a licence should be avoided by undertaking processes changes.

The typical cost of applying for a licence (including EPA application fee, newspaper advertisement and consultancy) would be a minimum of 16,000.

Should the EPA request further information - such as air dispersion models - the total cost can rise to over 20,000.

In addition, however, the running costs of the licence also need to be considered. These include -

the Annual Environmental Report
EPA Licence Fees
testing of bunds - and
emissions monitoring.

At present, the annual EPA fees are based on the activities and size of the company - together with additional charges driven by the number of EPA inspections. Licence fees range from 6,000 - for a small compliant site - to a possible 30,000 for larger non-compliant sites. Monitoring fees, typically, range from 2,000 per year - for a small printing plant - to over 20,000 per year for a large pharmaceutical plant.

The cost of installing and running pollution abatement equipment (e.g. thermal oxiders for printers) is often overlooked. It is always possible to meet the specified limits without abatement and, therefore, the cost needs to be included in the budget. Capital costs of abatement - for example, for a thermal oxidiser - would be over 100,000 with additional high running costs.

Having considered the costs involved, it is well worth examining if - by changing processes (e.g. moving from solvent to water-based inks or paints), subcontracting some activities (e.g. plating) or downsizing (reducing the volume of plating tanks) - the need for a licence can be avoided altogether.

In the current economic climate, overheads are factors which need to be constantly evaluated - e.g. the recent increase in energy costs - and any opportunity to reduce - or, indeed, eliminate - these costs, serves only to increase the profitability and stability of the company.

This article has been reproduced by kind permission of Bob Sutcliffe, MIMechE, MCIWM, MBA C.Eng, Director, Environmental Efficiency, Consulting Engineers[1].
Environmental Efficiency has advised a large number of clients on the IPPC application process - and, in many cases, successfully initiated changes to avoid the need for such a licence. Indeed, much of this work can be grant-aided, subject to eligibility.

[1] Tel: +353 (0)1 2761428; Email: [email protected]; Web: www.enviro-consult.com

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