Kanmantoo & Callington (Neutrog)
Neutrog Holdings Pty Ltd (Neutrog) is located at Kanmantoo and is a manufacturer of biological fertilisers.
The company was first licensed by the EPA in 1995 to undertake composting works. In 2011 Neutrog ceased operations and surrendered its EPA licence.
In mid-2018 the company renewed composting operations at its Kanmantoo site to assist with the management of a disease which threatened the viability of the state’s poultry industry.
Accordingly, with oversight from PIRSA and Biosecurity SA, the EPA issued Emergency Authorisations to Neutrog to process contaminated poultry waste between late 2018 and late 2019.
EPA licence for composting
Composting is a ‘Prescribed Activity of Environmental Significance’ defined in Schedule 1 Part A, 3(2) of the Environment Protection Act 1993 (EP Act). The Act requires these types of activities to be licensed and provides the EPA with a means of regulating such operations through licence conditions. An EPA licence may only be granted after development approval has been provided by the relevant development authority, which in this case is the Mount Barker District Council.
Once development approval was granted by the council, Neutrog applied to the EPA for a licence to conduct composting works at its Kanmantoo site.
Granting of the licence
In 2020, the EPA undertook public consultation in relation to Neutrog’s application. In accordance with statutory requirements, the EPA notified neighbouring properties directly via mail and published details of the application on its website.
An EPA licence was subsequently granted with a number of conditions placed on the company.
The licence includes conditions requiring the company to develop the following plans:
- odour management
- dust management
- community engagement
These conditions are enforceable and the EPA can take a number of different actions, including prosecution, if the licence conditions are not met.
The licence restricts operations in line with the current development approval.
Odour and dust
The EPA has conducted many site inspections since February 2020 as a result of community concern about odour and dust. An increased inspection schedule has been maintained until operations are satisfactory and community impacts resolved.
In May 2020 the EPA commenced odour monitoring in Kanmantoo and the surrounding area. In early December 2020 the EPA implemented a regular odour profiling program for Kanmantoo and Callington.
Odour monitoring has also been conducted on many occasions in Kanmantoo, Callington and surrounding areas. Odour levels have so far not exceeded requirements of the EP Act and associated policies. However, very high odour levels have been detected at and around the facility. The EPA is planning on extending its monitoring activity to ensure longer periods of monitoring are undertaken to better capture community impacts.
The EPA has approved Neutrog’s odour management plan (OMP) and dust management plan (DMP). Implementation of these plans is ongoing.
Odour source identification, monitoring and testing are informing ongoing odour mitigation and management actions in accordance with the OMP.
Developing and implementing an odour environment improvement plan (EIP) is pending, in order to ensure odour emissions are prevented or minimised, and odour levels do not exceed requirements of the EP Act and associated policies.
Dust impacts have reduced following enclosure and process improvement of several identified dust sources. This includes installation of dust covers on feed hoppers of screening and mulching machines and additional cleaning of exhaust/ductwork associated with the pellet press.
All odour and dust complaints received are being investigated and onsite activities reviewed and improved in response.
- Odour management FAQs, 2 December 2021
- 3 February 2021
- Public notice to extend groundwater monitoring plan deadline, 21 December 2021
The EPA issued Neutrog with a licence on 28 January 2021, and included a condition to develop and submit a groundwater monitoring plan to the satisfaction of the EPA by the compliance date of the 30 April 2021 (Licence condition U-1231). This was required by the EPA to address legacy groundwater impacts, ensure the protection of groundwater in the future and inform the need for any additional management measures at the site to protect human health and the environment.
On 18 March 2021, Neutrog appealed its licence condition relating to the requirement to develop a groundwater monitoring plan. Following a period of direct negotiations, Neutrog filed a discontinuance of its appeal with the court on 14 September 2021, and agreed to the requirements of the licence condition. However it sought an extension of time to prepare its groundwater monitoring plan.
This was accepted by the EPA in order for Neutrog to prioritise the most important compliance issue at the site which is odour. This includes ongoing odour improvement actions required by its odour management plan (Licence condition U-1288) and the preparation and implementation of its odour environment improvement program (Licence condition U-1398) for a permanent solution to the significant odour issue.
In addition the EPA considers the ongoing environmental risk of groundwater contamination is relatively low, as Neutrog has rectified the main source of potential groundwater contamination through the installation of an approved compost pad and lined wastewater collection pond.
The original requirements of the licence condition have been maintained, however the revised condition imposed requires the groundwater monitoring plan to be submitted to the EPA by the compliance date of the 30 April 2022 (a 12-month extension to the original compliance date). As an extension of time has been agreed, this constitutes a variation of the original requirements and results in the requirement for public notification. Given the public interest in the site, the EPA has elected to publically notify broadly and beyond the stipulated requirements of the Environment Protection Act 1993.
You are invited to make written submissions in relation to the proposed variation outlined above by Friday 7 January 2022.
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 call returned within business hours.
For health-related queries, please contact SA Health on (08) 8226 7100.