Refuse Derived Fuel Trial Proposal

Refuse Derived Fuel (RDF) Trial Proposal

Adbri Birkenhead has submitted a proposal (trial) to utilise refuse derived fuel (RDF) in the cement kiln, with a maximum rate of 10t/hr with up to 50% plastics content. This trial application is currently under assessment by the EPA.

EPA licence 1126 (Adelaide Brighton Cement Limited) provides a protocol for trialling alternative fuels and raw materials (AFRM). Adbri is required to submit a pre-trial report outlining the duration and nature of the trial process, the nature of the RDF, the environmental emissions assessment and the production of a post-trial report at the completion of the trial.

The EPA regulatory focus is to assess and consider whether the trial can be undertaken safely and that the trial can be accurately assessed against required outcomes (process stability, emissions, uniformity of AFRM). Importantly, the trial assessment will focus on ensuring there is no detrimental increase in inorganic oxides of the key pollutants, heavy metals, organic emission compounds and volatile organic and polyaromatic hydrocarbons as per the trial protocol.

The EPA may refuse a trial based on its assessment.

The Refuse Derived Fuel (RDF) Standard

The EPA Standard for the production and use of Refuse Derived Fuel provides the information and processes that are required to support resource efficiency and the beneficial recovery of energy from waste by the combustion of refuse derived fuel in an industrial process. This standard includes reference to the Waste Hierarchy which outlines that the production and combustion of RDF, is viewed as a recovery of energy activity and is seen as an alternative to disposal (the least preferable option) but should not be at the expense of preferable options, including waste avoidance or closed loop recycling.

Current RDF Use in the Calciner

The Birkenhead plant is currently authorised to utilise up to 32 tonnes per hour (tph) of RDF into its Calciner with a maximum plastics content in the RDF of 20%. The RDF fuels the calciner, and together with natural gas operates between 850 – 890 degrees C. At this temperature limestone is decarbonised to lime (with carbon dioxide emitted) and the lime and other raw materials combine together and are transferred to the main rotary kiln where the cement clinker is formed.

Manufacture and Quality Control of the RDF

The EPA requires the RDF currently used in the calciner to meet the RDF Standard. All proposals for production and use of refuse derived fuel must be approved by the EPA.

The quality and consistency of the RDF must be maintained via a quality control and quality assurance (QC/QA) programme at the producer. This testing program is a key component of Adbri’s Recovered Product Plan (RPP) and the producer’s Environmental Management Plan (EMP) both of which have been approved by the EPA and the 20% maximum plastics content confirmed via sampling and analytical reports.

The approved calciner RDF product is a shredded mixture of timber, paper, cardboard, plastics, and other inert fibrous materials. The RDF is trucked to the Birkenhead plant on a “just-in-time" basis.

Community Input and Feedback on RDF Trials and Usage

EPA will have regard to community feedback and questions. Submissions can be made via YourEPA online portal.

Frequently Asked Questions:

Some of the questions we have frequently been asked about Adbri’s Birkenhead facility include:

What is refuse derived fuel (RDF) and why is it used?

The RDF currently used in the Birkenhead calciner is an engineered fuel manufactured by Veolia ResourceCo at its dedicated facility in Wingfield and is comprised of Commercial and Industrial Waste (C&I), Construction and Demolition Waste (C&D) and Municipal Solid Waste Hard-Waste (MSW HW). The final RDF product is a shredded mixture of timber, paper, cardboard, plastics, and other inert fibrous materials. 

The Birkenhead plant is currently authorised to utilise up to 32 tph of RDF into its Calciner with a maximum plastics content in the RDF of 20%. This equates to approximately 50% substitution of its main natural gas supply via the utilisation of refuse derived fuel (RDF). The RDF fuels the calciner, which operates between 850 – 890 degrees C.

How is the current RDF quality and consistency checked?

The EPA requires Veolia ResourceCo and Adbri to ensure the quality and consistency of the RDF is prepared and maintained to a specification and regulates this requirement in their licence via the preparation of an Environmental Management Plan (EMP) and Recovered Product Plan (RPP) respectively. The quality control and assurance (QC/QA) programme at Veolia ResourceCo and at Adbri’s Birkenhead National Association of Testing Authorities (NATA) accredited laboratory is achieved via a sampling, testing, and analysis program. This testing program is a key component of Adbri’s RPP and Veolia ResourceCo’s EMP, both of which have been approved by the EPA and the 20% maximum plastics content confirmed by the EPA via sampling and analytical reports provided.

How are emissions monitored when RDF is being burned?

The EPA requires Adbri to undertake specific stack emissions testing during any RDF trial period to measure the mass emission rate and concentration of the combustion emission pollutants. Additionally, if approval is given for ongoing RDF use (once the trial has been completed), Adbri is required to undertake twice yearly stack emissions testing to ensure the emission combustion products of utilising the RDF are safe and meet the Environment Protection (Air Quality) Policy, 2016. The suite of compounds specified in the licence (Schedule Y-1) are targeted to those pollutants associated with the use of RDF in the combustion process. These include inorganic and organic emissions compounds, chlorine and chlorinated hydrocarbons, heavy metals, polyaromatic hydrocarbons, dioxins and furans.

The stack testing over the period since commencement of RDF use in 2003 has demonstrated that the Environment Protection (Air Quality) Policy, 2016 emission criteria have been met. Additionally, the ambient emission levels in the local community must meet the National Environment Protection Measure (NEPM) for Nitrogen Dioxide, Sulphur Dioxide, Carbon Monoxide, Particulates PM10 and PM2.5 which are designed for ambient air quality that is protective of health. To date, Adbri has demonstrated that NEPM standards have been met for the use of RDF.

How much plastic is allowed in the RDF used by Adbri?

The EPA approved the original use of RDF in the Birkenhead Calciner in 2003 at a rate of 10 t/hr with a maximum plastics content of 10%. The approval followed a closely monitored trial by Adbri with stack testing conducted on both the calciner and kiln, which reported no detrimental increase in inorganic oxides of the key pollutants and no increase in organic emission compounds and volatile and polyaromatic hydrocarbons. There was also no detrimental change in the heavy metal emissions relative to natural gas usage (which was the primary fuel).

In July 2017, the EPA approved an increase of RDF to 15 t/hr with a maximum plastics content of 20% following a successful trial of the RDF in the calciner at the higher rate. The stack testing program during the trial analysed Nitrogen Oxides, Sulphur Dioxide and Carbon Monoxide emissions, heavy metals, and organic emissions as well as dioxins and furans. The trial demonstrated no detrimental emission levels compared to the previous emissions for these compounds.

The current licence permits up to 32t/hr of RDF to fuel the calciner, with a maximum plastics content of 20%. In practice, the calciner operates at around 25t/hr.

Does the EPA conduct air quality monitoring in Birkenhead?

The EPA conducts real-time monitoring in Birkenhead at its Le Fevre #1 air quality monitoring site and at North Haven at its Le Fevre #2 site. This monitoring is for the smaller health-impacting particles less than 10 micrometres in diameter (PM10) and particles less than 2.5 micrometres in diameter (PM2.5) in the ambient air as part of its continuous air quality monitoring program across metropolitan Adelaide. One micrometre (µm) is 1 millionth of a metre or 1 thousandth of a millimetre.

Real-time public access to EPA data is available by visiting its Air quality monitoring | EPA

The EPA requires Adbri to undertake air quality monitoring in the community for Total Suspended Particulates (TSP), PM10 and PM2.5, and also Nitrogen Dioxide.

What are the processes following the Adbri pre-trial outcomes?

If the Adbri Refuse Derived Fuel (RDF) pre-trial report is approved by the EPA regulatory assessment, a trial may take place under strict conditions.

Following the trial, a post-trial written report is required to be submitted to the EPA within 90 days. A post-trial report would include results of stack testing and modelling, process stability and uniformity of alternative fuels and raw materials.

Following a successful post-trial assessment Adbri may seek a process change application as in accordance with conditions A5 and or A6 of EPA licence 1126 for ongoing use. Development assessment may also be triggered.