Adelaide Brighton Cement
The Adelaide Brighton Cement (ABC) site is located on the LeFevre Peninsula, in an industrial area that is adjacent to the residential areas of Birkenhead, Peterhead and Largs Bay.
ABC produces a range of cement and cement products. Cement production started at the Birkenhead site in 1911 and currently, ABC produces approximately 1.4 million tonnes of cement per year at Birkenhead.
ABC is regulated by the EPA under the Environment Protection Act 1993. The EPA seeks to ensure that all reasonable and practicable measures are taken to protect, restore and enhance the quality of the environment according to the principles of ecologically sustainable development. To achieve this objective, the EPA uses a number of regulatory decision making principles and actions outlined in the Compliance and enforcement regulatory options and tools.
ABC is regulated by the EPA for several activities of environmental significance including:
- cement works
- activities producing listed wastes
- bulk shipping facilities
- crushing, grinding or milling works (rock, ores or minerals)
- fuel burning.
Conditions of the licence require ABC to implement a number of management plans to address environmental considerations at the site, and meet specific monitoring, reporting and notification requirements. These requirements aim for continuous environmental improvement at the site, and compliance with legislation, including:
- Environment Protection Act 1993
- Environment Protection (Water Quality) Policy 2015
- Environment Protection (Air Quality) Policy 2016 – ground level concentrations (GLC) criteria to ensure public health protection
- Environment Protection (Noise) Policy 2007.
Documents, plans and reports
Dust management, monitoring and reporting
Dust management plan
The EPA often requires licensees via a condition of licence to develop a dust management plan (DMP) to the satisfaction of the EPA to reduce the risk of offsite dust impacts.
ABC’s DMP was first submitted to the EPA in February 2018. To ensure the DMP addresses requirements, it was assessed by the EPA and revised versions were required to be submitted prior to approval. The DMP was approved in June 2018.
The DMP specifically focuses on fugitive dust emissions, as stack emissions are addressed in ABC’s stack particulate management plan. The DMP outlines trigger values, as well as action and response strategies, to prevent and minimise particulate emissions arising from ground level sources of dust.
Real-time dust monitoring
The DMP also requires ABC to provide public access to real-time monitoring data of PM10 and PM2.5 from air quality monitors located within the community.
Quarterly and annual reporting
ABC is required to provide quarterly and annual reports to the EPA on the implementation of the DMP, which includes, but is not limited to, reporting of:
- dates, triggers, action and response strategies implemented
- trend analysis of monitoring data with community complaints
- opportunities for continual improvement in dust management.
ABC must ensure public access is available to its quarterly and annual reports. The timeframe of reporting and due dates for submission of reports to the EPA is summarised in the table below.
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Timeframe of monitoring
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Due date for submission
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January to March
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30 April
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April to June
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31 July
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July to September
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31 October
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October to December
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31 January
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Annual
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14 February
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Ground level air quality notifications and continual improvement
ABC must also, as a condition of licence, provide notification to the EPA within 48 hours when particulate limits are exceeded at any of its community air quality monitoring locations. The notification must include the date, cause, the measured particulate concentration and any remedial actions taken to reduce particulate emissions. The EPA is subsequently able to assess each notification, to ensure all reasonable and practicable measures are being implemented at the site to minimise particulate emissions, with an aim for continual improvement.
Stack management, monitoring and reporting
Stack notifications
ABC must take all reasonable and practicable measures to prevent particulate emissions exceeding 100 mg (Kiln Stack 4A) or 60 mg (Precalciner Stack 4B) per m3 based on a 1-hour average. When stack emissions exceed the limit specified, ABC must take all reasonable and practicable immediate action to reduce emissions below the limit. It is important to note that these limits are not intended to be a maximum pollutant concentration, but are instead intended to drive good process control, implementation of corrective actions by ABC when these limits are triggered, and to ensure timely notification to the EPA.
ABC must provide notification to the EPA as soon as reasonably practicable of any exceedance of the limit. The information contained within each notification is expected to assist in identifying opportunities for continual improvement at the site and this is specifically to be addressed through quarterly reporting.
The EPA’s response and compliance decisions in relation to any notification depends on a range of factors including the nature and extent of the notification event, and the information received from the company regarding the cause and/or corrective actions undertaken. The EPA’s regulatory response is based on the foundation of firm and fair compliance and enforcement in a timely manner.
Stack particulate management plan
The EPA requires ABC via a condition of licence to implement an EPA-approved stack particulate management plan (SPMP) to minimise the offsite risk of stack particulate emissions. ABC’s SPMP was first submitted to the EPA in February 2018. To ensure the SPMP addresses EPA requirements, the SPMP was assessed by the EPA and revised versions were required to be submitted to the EPA prior to approval. Approval of the SPMP was provided in June 2018.
The SPMP focuses on continuous monitoring of particulate emissions, and trigger and response strategies to prevent high level emissions.
Stack testing
A condition of licence also requires ABC to undertake twice-yearly stack emission testing. The previous two reports are:
Please see Archive documents heading on this page for historical stack testing reports.
Quarterly and annual reporting
ABC provides quarterly and annual reports to the EPA, which includes, but is not limited to, reporting of:
- details of exceedence notifications including date, duration, cause, measured particulate concentration
- actions taken to reduce particulate emissions and corrective actions taken to prevent future events of the same kind
- trend analysis and trend comparisons, including of monitoring data with community complaints
- opportunities for continual improvement.
Public access to quarterly and annual reports is available via ABC community website. The timeframe of reporting and due dates for submission of reports to the EPA is summarised in the table below.
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Timeframe of monitoring
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Due date for submission
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January to March
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30 April
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April to June
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31 July
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July to September
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31 October
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October to December
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31 January
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Annual
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31 October
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Noise management
To prevent and minimise noise emissions, the EPA requires ABC via a condition of licence to implement an EPA-approved noise management plan (NMP). The NMP was first submitted to the EPA in January 2018. To ensure the plan addresses EPA requirements, it was assessed by the EPA and revised versions were required to be submitted to the EPA prior to approval. EPA approval of the Noise Management Plan was provided in August 2018.
The NMP includes:
- detailed action and response strategies to prevent and minimise noise emissions
- a framework for provision of quarterly and annual reports to the EPA, and a requirement for ABC to ensure public access to these reports.
In addition, the EPA requires ABC to strive for continual improvement in noise management by implementation of ongoing noise abatement works.
In 2018, ABC has implemented noise abatement works via an EPA approved environment improvement program (EIP). These works included noise improvements in regards to:
- gas supply train
- main dust collector fan on the top of the blending silo
- stack 4A discharge fan
- Stack 4B airslide transport system.
Acoustic consultants assessed the reductions achieved by each of these projects, and a report was provided to the EPA.
Quarterly and annual reporting
Public access to quarterly and annual noise management reports is available via ABC’s community website. The timeframe of reporting and due dates for submission of reports to the EPA is summarised in the table below.
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Timeframe of monitoring
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Due date for submission
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January to March
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14 May
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April to June
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15 August
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July to September
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15 November
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October to December
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14 February
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Annual
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14 February
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Environment improvement program (EIP)
To ensure continual environmental improvement at the site, the EPA requires ABC to develop and implement an environment improvement program (EIP).
The previous EIP, completed in 2018, included a range of noise abatement works, and an upgrade to the gas conditioning towers to improve air emissions. These works are now complete as reported in the EIP update.
Moving forward, the EPA requires ABC to consider its next environmental improvement projects for noise and dust improvement works. In November 2018 ABC’s licence was amended to include a condition which requires an EIP to be handed in by 28 February 2019, and ABC has submitted its EIP to the EPA’s satisfaction by this deadline.
To inform the EIP process, ABC engaged a suitably qualified expert to undertake an assessment of options for improved dust management at the site. A number of recommended options were identified, and consideration of these options, along with additional noise abatement works, will form part of the current EIP.
Community consultation occurred as part of the process in development of the EIP. Please view the ABC community website for further information on its community consultation.
Air quality monitoring
EPA
Add to my listReal-time monitoring
The EPA has two ambient monitoring stations – Le Fevre 1 and 2. Click the link below and scroll down to regions to view the air quality monitoring data.
EPA stations
Add to my listHow to interpret air quality data
Location of air quality monitoring stations
PM10 levels and averaging period
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1-hour average*
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24-hour rolling average
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What is it?
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The average PM10 levels over a one-hour period.
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An average of the hourly readings of PM10 levels over the previous 24-hour period.
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How often is the average calculated
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Every hour
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The previous 24 one-hour readings are averaged each hour.
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What does it say about air quality? |
It tells us about PM10 levels over the previous 1-hour period.
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It tells us about air quality over the previous 24 hours.
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Does this type of data trigger any health advice or regulatory response?
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No |
Yes, if the levels are above relevant criteria**.
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What is this data used for?
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1-hour average data can quickly show when an increase in PM10 is happening. It can also indicate how severe it is. |
Compliance reporting – 24-hour average data is compared to the SA EPA’s regulatory criteria and source identification |
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Why don't all increased PM10 levels trigger regulatory response?
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In Le Fevre, dust can originate from variety of sources such as motor vehicles, earthworks, domestic sources, wind blown natural dust or industrial activities such as ABC. Only when winds are blowing from the direction of ABC and PM10 levels are above criteria for that day, may the EPA trigger a regulatory response.
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* EPA real time monitoring display concentration for recent 1-hour average
** Ground level concentration criterion for PM10 is 50 µg/m3
Graphical presentation – wind direction would need to occur in the direction of the green arrows for a dust source to be from the ABC site.
Source identification
EPA scientists carefully examine monitored dust levels, weather data and any other available information is used to determine if a particular dust event may trigger any regulatory response. The following factors are considered.
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Information
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What does it mean
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Wind direction (forecast or observations)
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Wind direction would inform where the dust is coming from (eg natural/ regional dust)
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Wind speed (forecast or observations)
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Wind speed would determine how far dust would have travelled. Higher winds speed (eg more than 30 km/hr) can potentially raise the dust levels in general
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Dust levels are recorded high at all monitors (eg PM10 greater than 80µg/m3 for 1 hour)
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Potentially a regional scale dust event in the metro area. Wind direction will provide further information
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Dust levels high at one monitor and not others
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Potentially a local dust event. Source can be interpreted from observed wind speed and direction
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Other weather conditions(s)
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Other weather conditions such as rain or storms can have an effect on dust levels (eg heavy rain may reduce the dust concentration)
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Add to my listAir quality index (AQI)
An index for any given pollutant is its concentration expressed as a percentage of the relevant criteria, or
Index = Pollutant Concentration
---------------------------------------- X 100
Pollutant Criteria
Based on the percentage values, there are 5 AQI values:
For dust (PM10 or PM2.5) AQI uses an average of the preceding 24 hours of PM10 or PM2.5 readings, divided by the 24-hour air quality criteria of 50 µg/m3 for PM10 and 25 µg/m3 for PM2.5.
Notes about AQI displayed on the EPA website
- The table show average pollutant concentrations for the previous hour. Concentrations are displayed in μg/m3 for particles (TSP, PM10 and fine particles PM2.5).
- Recent air quality data is indicative only and may be affected by instruments not working correctly, power failures and the like. Data will be validated at a later date.
- Times shown on this page are Australian Central Standard Time (ACST). During daylight savings an hour will need to be added to the times shown.
- Recent air quality table displays 1-hour average pollutant concentrations for each of our monitoring sites.
- Data on the AQI page is updated hourly at half past the hour, so air quality for the period 8 am to 9 am will be shown at 9.30 am.
- In order to get an overall air quality, the index for each pollutant is calculated. The maximum of these figures is taken to be the index for that monitoring station.
ABC
ABC stations
Alternate fuel use
ABC Birkenhead has supplemented its use of natural gas through the use of alternative fuel, including demolition wood waste. This demolition waste can sometimes contain small amounts of plastic and it is not economical to remove this prior to burning. Burning small amounts of plastic within the wood waste, at high temperatures, does not cause any adverse impacts on emissions. To ensure that the amount of plastic remains at levels where no impact would be detected, the EPA had previously placed a licence limit of no more than 10% plastic in the demolition wood waste used. This limit was based on the original applications and information provided which suggested this was the makeup of the material to be used.
The EPA required the production of a detailed pre-trial report, the completion of the approved trial methodology and submission of a post-trial report as per the EPA licence for ABC.
The EPA assessed and accepted the Alternative fuel post-trial report, March 2015 and is satisfied that there are no adverse impacts from the increase in the plastic content based on the trial reports and modelling. The post-trial report also highlighted likely environmental benefits as a result of using alternative fuels to complement the primary fuel source of natural gas. The benefits include a reduction in both nitrogen oxide emissions and the overall carbon dioxide emission footprint of ABC’s operation. All other analytes, including dioxins, were well below the levels specified in the Environment Protection (Air Quality) Policy 2016.
In late 2016, the EPA received an application from ABC to increase the allowable percentage of plastic (from 10% to 20%) in the alternative fuel it burns as a supplement to natural gas to fire its Cement Kilns. This alteration was requested due to changes in the materials received by the supplier and the way in which the fuel was being produced.
This change of process request from ABC triggered a licence relaxation process resulting in a public notification and consultation process. As part of the assessment of the proposal and the consultation process the EPA:
- sought public feedback
- issued public notifications in local media
- provided ABC with a summary of submissions raised through the public consultation process and an opportunity to respond
- provided updates on the EPA website outlining the information regarding the proposal and the EPA’s proposed changes to licence conditions.
In July 2018 the EPA has now approved the process change and has amended Licence 1126 to permit an increase of the allowable maximum plastic content (by weight) to 20%.
The EPA’s decision was based on:
- a thorough review and analysis of the submitted application provided by ABC which included the increased plastic content trial methodology, testing and results. This review and verification of information included advice from the EPA’s Air Quality Scientists and a third-party review by the Victorian EPA
- confirmation of the use of independent National Association of Testing Authorities (NATA) accredited testing
- regard to the community submissions on the proposed changes received on this matter, including ABC’s response to the summary of submissions.
The EPA has placed additional controls to ensure compliance with current environment protection policies and the maximum allowable plastic content of 20%. The licence now aligns with the Refuse Derived Fuel standard, which is referenced in the Environment Protection (Waste to Resources) Policy 2010. The term ‘refused derived fuel’ or RDF has been applied to the licence to more accurately reflect what can be received and used as an alternative fuel. The EPA has required ABC to develop a recovered product plan, which has now been approved.
These controls ensure that quality assurance measures are in place and that appropriate material is received and used.
Application to amend the approved feed rate of RDF
In August 2020, ABC applied to the EPA to vary its licence to amend the feed rate of RDF. At this time the licence specified (under Schedule X-1) that RDF could be used at an approved feed rate of 15 tonnes per hour (to a maximum of 20% plastic contamination by weight). ABC submitted an application to the EPA to increase its approved feed rate of RDF to 25 tonnes per hour (to a maximum of 20% plastic contamination by weight).
ABC’s licence specifies the steps that must be taken for such a change to be approved. This includes submission of a pre-trial report to the EPA, conducting a trial (where approved and pursuant to the pre-trial specifications) and provision of a post-trial report for the EPA’s consideration.
ABC met the pre-trial and post-trial requirements, and the EPA assessed and accepted the post-trial report. The EPA is satisfied that the RDF feed rate increase will not result in adverse impacts and will be managed in an environmentally acceptable manner and that ABC has consulted with its Community Liaison Group on this variation.
As such, the EPA assessed and approved an application to amend the approved maximum feed rate specified in Schedule X-1 of the Licence 1126 to 25 tonnes per hour (maximum of 20% plastic contamination by weight). Further information related to this amendment, including copies of the pre-trial and post-trial reports, can be found on
ABC community website.
Community engagement
ABC undertakes community engagement in accordance with its community engagement plan.
In addition to convening a community liaison group every quarter, ABC is required to:
- provide public access to its real-time monitoring data of PM10 and PM2.5 from within the community
- in the event that ground level concentrations are exceeded at monitoring sites within the community, provide public access to an explanation of why the exceedence occurred
- consult with the community regarding the development of EIPs
- provide public access to management plans and quarterly and annual reports
- keep ongoing records of community complaints and concerns
- undertake trend analysis between community complaints and air quality monitoring data.
The EPA held an information session for the Le Fevre community in August 2018, and a report regarding the session has been produced by the EPA.
Archived documents
Environment improvement program reports
ABC
Stack monitoring
Stack testing
Ambient monitoring (quarterly updates)
Impact assessment reports
Emission reports – Air emissions monitoring of release points 4A & 4B
Noise
Reports
Surveys
EPA
Further information
For all enquiries, please contact the EPA on (08) 8204 2004 or via email. This line is answered 24 hours a day, 7 days a week in the case of an emergency. If the matter is not urgent you will have your called returned within business hours.
For health-related queries, please contact SA Health on (08) 8226 7100.
For further information from Adelaide Brighton Cement, please call (08) 8300 0520 or visit the ABC website or visit the ABC Community Liaison Group dedicated page.
