When a change needs to be reviewed
The scope of permitting depends on the actual parameters of the project and on the conditions of the valid decisions. What matters are the designed capacity, the raw materials used, the volume of emissions, the method of extraction, the noisiness of the equipment, the operating hours, the waste generated and the associated traffic.
We recommend an environmental review in particular when:
- installing a new production line, paint shop, furnace, boiler, crusher, filtration unit or central extraction,
- increasing production capacity, consumption of fuels, chemical substances or organic solvents, or introducing night-time operation,
- building a new vent, relocating outdoor equipment, increasing traffic or changing the way waste is handled.
The new technology needs to be compared with the existing operation and the permitted state. The valid operating permit, operating rules, integrated permit or EIA documentation may contain specific capacities, materials, vents and binding conditions.
Which areas a change of technology will affect
Scroll the table horizontally to see all columns.
| Area | What needs to be assessed | Possible required document |
|---|---|---|
| Air | Capacity, emissions, raw materials, extraction, vents and filtration | Expert report, dispersion study, amendment of the operating permit |
| Noise | Machinery, fans, cooling, compressors, handling and traffic | Noise study, design of noise-control measures |
| Waste | Types, categories and quantities of waste, method of collection and transfer | Update of records and operating procedures |
| EIA | Change of capacity, technology, scope or manner of operation | Project notification, screening procedure |
| Building permit | Vents, foundations, penetrations, extensions and outdoor equipment | Project documentation, JES |
| Integrated prevention | Change to the installation or its operating parameters | Notification of change, amendment of the integrated permit |
Air: the classification of the source and the extent of the change are decisive
The first step is to classify the technology under Act No. 201/2012 Coll., on Air Protection. For listed stationary sources, it is necessary to verify whether the new technology corresponds to the valid operating permit.
An amendment of the permit may be needed where the designed output or capacity is increased, new emissions arise, the raw materials used change, the abatement is modified or the way waste gases are discharged changes.
A new vent must be described by technical parameters. The project should state its height, diameter, volume flow, temperature, exit velocity, operating time, connected equipment and the expected pollutants.
When the operating permit is amended, an expert report is generally not required unless the designed output, capacity or emissions increase. For sources marked in column A of Annex 2 to the Act, a dispersion study for substances with a set ambient air limit is submitted where the output, capacity or emissions increase.
For technologies using organic solvents, the designed consumption must be evaluated for the relevant activity or technological unit. Other equipment operated on the same site may also enter the balance.
Noise: both machines and auxiliary equipment are risks
Fans, compressors, vacuum pumps, cooling units, hydraulic power packs, vents, loading of material and heavy goods traffic are typically significant noise sources. Their location relative to the nearest residential buildings and the expected operation during the day and at night are important.
For noise from stationary sources, the hygiene limit in the protected outdoor space is determined from a basic level of 50 dB and the relevant corrections. For night time, a correction of −10 dB applies to the protected outdoor space of buildings. For an ordinary stationary source, the limit therefore generally comes to 50 dB by day and 40 dB at night. If a tonal component is demonstrated, a further correction of −5 dB is applied.
The daytime assessment is carried out for the eight consecutive noisiest hours, the night-time assessment for the noisiest single hour. The details are set out in Government Decree No. 272/2011 Coll..
For preparing a noise study, it is advisable to require from the technology supplier the sound power level LWA, the noisiness of the individual operating modes and information on tonal or impulsive components. A sound pressure level figure must be accompanied by the distance and the measurement conditions.
The noise study should also include the existing sources on the site. The resulting level at a protected building arises from the combination of the new technology, the existing equipment, handling and on-site traffic.
Waste: a change of technology is reflected in the records
New technology may generate waste oils, cutting fluids, filters, sludges, sorbents, contaminated packaging, production rejects or dust from abatement equipment. Each waste must be correctly classified by type and category and collected in a way appropriate to its properties.
Ongoing records are kept even for smaller waste production. The annual report of summary data is submitted by 28 February of the following year if, in the previous calendar year, the producer generated or itself handled more than 600 kg of hazardous waste or more than 100 tonnes of other waste.
Technology intended for processing waste received from other parties requires special assessment. Such an operation may be subject to a permit for a facility intended for waste management under Act No. 541/2020 Coll., on Waste.
EIA is also reviewed for a change to an existing operation
The classification of the project under Annex 1 to Act No. 100/2001 Coll., on Environmental Impact Assessment is decisive. The capacity, scope, technology used, manner of operation and possible significant impacts on the environment are assessed.
For an existing site, it is important to find the original EIA notification, the conclusion of the screening procedure or the binding opinion. The proposed change is compared with the parameters of the previously assessed project.
The EIA process may be relevant where capacity increases significantly, the production area is extended, the technology changes, solvent consumption increases, waste handling is extended or new traffic and emission impacts arise.
JES and the building permit
If the change of technology requires a permit under the Building Act, it may be necessary to obtain a Unified Environmental Opinion – JES. This applies, for example, to new vents, foundations, building penetrations, extensions or outdoor technological equipment.
The statutory time limit for issuing the JES is no more than 60 days from submission of a complete application. In a particularly complex case it may be extended by no more than a further 30 days. When a request is made to remedy defects in the application, the time limit is suspended.
The speed of the proceedings is significantly affected by the quality of the project and by the consistency of technical data in all the documents submitted. The details are governed by Act No. 148/2023 Coll., on the Unified Environmental Opinion.
Operations with an integrated permit
The operator of an installation under the integrated prevention regime must notify the regional authority of every planned change in the use, manner of operation or scope of the installation that could have consequences for the environment.
The authority then evaluates whether the change requires an amendment of the integrated permit and whether it is a substantial change. It is therefore advisable to deal with the installation of technology well ahead of the planned start of operation.
The rules are laid down by Act No. 76/2002 Coll., on Integrated Prevention.
What to prepare before ordering the technology
The supplier should guarantee parameters that can be used for design and permitting proceedings. These include production capacity, consumption of raw materials, emission parameters, the volume of extracted air, filtration requirements, noisiness and the types of waste generated.
The project documentation, technical data sheets, studies and applications must work with the same capacity, operating hours and technical solution. Differing data usually lead to requests for supplementation and longer proceedings.
What you can send us and what we will verify
For an initial review, you can send us:
- a description of the existing and proposed operation, a layout drawing, project documentation and technical data sheets,
- hourly and annual capacities, operating hours, consumption of raw materials, fuels and chemical substances, vent parameters, emissions, noisiness and traffic,
- the valid operating permit, operating rules, integrated permit, EIA documentation, JES and an overview of the waste generated.
We will review the planned change in terms of air protection, noise, waste, EIA, JES and integrated prevention. We will determine the documents needed for the authorities and point out data that should be supplemented before the contract with the technology supplier is concluded.
You can find an overview of related activities on the page NATURCHEM Services.
Related legislation
Act No. 201/2012 Coll., on Air Protection
Act No. 541/2020 Coll., on Waste
Act No. 100/2001 Coll., on Environmental Impact Assessment
Act No. 148/2023 Coll., on the Unified Environmental Opinion