Cockburn Cement Limited. Summary of stack emission and ground level concentration data. September 2010

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1 Cockburn Cement Limited Summary of stack emission and ground level concentration data September 2010 THIS REPORT CONTAINS INFORMATION EXTRACTED FROM THE KATESTONE ENVIRONMENTAL AIR QUALITY IMPACT ASSESSMENT OF THE MUNSTER PLANT KE JULY 2010

2 Executive Summary Katestone Environmental has been commissioned by Cockburn Cement Limited (CCL) to undertake a dispersion modelling assessment of baseline operations at the Munster plant in Western Australia. This report details the findings of an air quality impact assessment using dispersion modelling techniques, and is based on stack emissions tests conducted by ECS during the period October 2008 to July The dispersion modelling indicates that: Predicted maximum ground-level concentrations of all air pollutants, at and beyond the Munster plant boundary, are well below air quality standards and guidelines using conservative modelling assumptions The highest 1-hour, 8-hour and 24-hour average ground-level concentrations are predicted to occur in close proximity to the site boundary Background to this report The dispersion modelling undertaken by Katestone Environmental (2010) for CCL at the Munster plant is based on emissions monitoring information collected between October 2008 and July 2009 and is a follow-up to an earlier study undertaken at the site in 2001 and Katestone Environmental are independent experts in dispersion modelling. To help readers of this document, a comparison between the results of the two Katestone studies is provided in Table 4. The initial Katestone Environmental report was prepared specifically for the then Western Australian Department of Environmental Protection (now Department of Environment and Conservation) and used to brief local residents about the composition of air pollutants associated with emissions to air from the Munster plant and their predicted highest ground level concentrations. A full assessment of the report was then undertaken by the Western Australian Department of Health, which concluded that the emissions from the Munster plant should not pose a health risk to local residents. In the initial report Katestone Environmental conducted an air quality impact assessment of 66 compounds specifically selected from the National Pollutant Inventory (NPI) list of compounds and agreed by Cockburn Cement with the Department of Environmental Protection. All of these substances were found to be many times below (up to 100,000 times less) than Western Australian and national health regulations. Where no local guidelines were available for a particular compound, the predicted highest ground-level concentration of the compound was assessed against the toughest limits that could be found nationally or internationally. The 2001 and 2002 air quality assessments conducted by Katestone Environmental were based on emissions monitoring of the cement and lime kilns operating on gas, coal and oil fuels, and ensured that the full range of NPI compounds were analysed. By 2008 and 2009 the use of oil as a fuel source at the site had been suspended due to supply constraints.

3 Introduction Katestone Environmental has been commissioned by CCL to undertake an air quality impact assessment for the Munster plant. In accordance with the terms of CCL s environmental licence, stack exhaust monitoring is conducted on all of the kilns periodically. The frequency of the monitoring for all air pollutants is outlined in Table 1. Table 1 Frequency of kiln stack monitoring program Parameter Current licence stack test frequency Particulates Bi-annual Sulfur dioxide Bi-annual Nitrogen dioxide Bi-annual Carbon monoxide Hydrogen chloride / hydrogen fluoride Volatile organic compounds Polycyclic aromatic hydrocarbons Metals Dioxins and furans Volumetric flow rate Not applicable Stack source characteristics and emission rates used in this dispersion modelling study have been adapted from stack emission tests conducted by ECS Stack Pty Ltd, a subsidiary of ECS (Environmental Consultancy Services) Corporate Pty Ltd during the period October 2008 to July 2009 as indicated in Table 2. Table 2 Kiln stack monitoring program conducted by ECS Kiln number Stack emission monitoring dates Kiln 2 baseline program 12 January 5 March 2009 Kiln 3 baseline program October 2008 Kiln 4 baseline program 25 June 30 July 2009 Kiln 5 baseline program 16 October 4 December 2008 Kiln 6 baseline program October 2008 This assessment represents emissions for the five kilns at the CCL Munster plant operating under typical baseline fuel burning conditions. CCL tested the emissions from the cement and lime kilns which burn gas and coal ensuring the full range of NPI compounds were analysed. The modelling showed the concentration of compounds that could be found at ground level outside the boundaries of the Munster plant. All the testing, analysis and modelling were carried out by independent experts.

4 Ambient air quality objectives The ambient air quality assessment criteria for the air pollutants that have been considered in this study are presented in Table 3. These criteria have been selected from a review of various state, national and international air quality standards and guidelines. The air quality criteria used in this impact assessment have been sourced from the following standards and goals: National Environment Protection Council (NEPM), (2003), National Environment Protection Measure for ambient air quality. World Health Organisation (2000), "Guidelines for Air Quality". WHO, Geneva. WA Department of Environment (DoE) Arizona Department of Health Services (1999), Draft 1999 update Arizona Ambient Air Quality Guidelines. Florida Air Toxics Working List, 1992 European Environment Agency ( NHMRC (1995) Indoor Air Quality Goals National Environment Protection Council (NEPM), (December 2004), National Environment Protection (Air Toxics) Measure. Monitoring investigation level with an 8-year goal to obtain sufficient monitoring data to develop a standard. NSW DECC (2005) Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, NSW Department of Environment and Climate Change, NSWQ Government Gazette, Sydney.

5 Table 3 Ambient air quality objectives for modelled pollutants Pollutant Air quality Averaging standard period Source Particulates Total particulates as PM hour 50 NEPM 1 Organic compounds Dioxins and Furans 24-hour WHO 2, 9 Acid gases Nitrogen dioxide 1-hour 246 NEPM 1 Sulphur dioxide 1-hour 570 NEPM 1 Hydrogen chloride 1-hour 210 Draft AAAQG 5 24-hour 56 Draft AAAQG 5 Hydrogen fluorides 30-minute 200 European Environment Agency 7 24-hour 100 European Environment Agency 7 50 European Environment Agency 7 Combustion indicators Carbon monoxide 8-hour 11,247 NEPM 1 Polycyclic aromatic hydrocarbons Total PAHs 1 WA DOE 3 Benzo(a)pyrene as a marker for PAH NEPM Air Toxics 10 Volatile organic compounds Total VOCs as n-hexane 1-hour 500 NHMRC 8 Benzene 1-hour 29 NSW DECCW hour 1 WA DOE WA DOE 3 Ethylbenzene 1-hour 8,000 NSW DECCW 11 Toluene 1-hour 360 NSW DECCW 11 Xylene 1-hour 190 NSW DECCW 11 Toluene-2,4-diisocyanate 24-hour Florida Air Toxics 6 1,2 Dibromoethane Florida Air Toxics 6 Metals and metalloids Arsenic Advised by DOE based on WHO 4 Antimony 1-hour 15 Draft AAAQG 5 24-hour 4 Draft AAAQG 5 Cadmium WHO 2 Cobalt 8-hour 0.5 Florida Air Toxics 6 Chromium 1-hour 15 Draft AAAQG 5 24-hour 4 Draft AAAQG 5 Copper 1-hour 3 Draft AAAQG 5 24-hour 0.79 Draft AAAQG 5 Mercury 1 WHO 2 Manganese 0.15 WHO 2 Nickel Advised by DOE based on WHO 4 Lead 90-day 1.5 NHMRC NEPM 1 Thallium 1-hour 3 Draft AAAQG 5 24-hour 0.79 Draft AAAQG 5

6 1 National Environment Protection Council (NEPM), (2003), National Environment Protection Measure for ambient air quality. 2 WHO (2000), "Guidelines for Air Quality". WHO, Geneva. 3 WA DOE 4 Advised by WA DOE based on WHO (2000), "Guidelines for Air Quality". WHO, Geneva. 5 Arizona Department of Health Services (1999), Draft 1999 update Arizona Ambient Air Quality Guidelines. 6 Florida Air Toxics Working List, European Environment Agency ( 8 NHMRC (1995) Indoor Air Quality Goals 9 Based on 2pg/I-TEQ/kg-bw/day for a 70 kg person 10 National Environment Protection Council (NEPM), (December 2004), National Environment Protection (Air Toxics) Measure. Monitoring investigation level with an 8-year goal to obtain sufficient monitoring data to develop a standard. 11 NSW DECC Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, NSW Department of Environment and Climate Change, NSW Government Gazette, Sydney. Assessment made against the 99.9 th percentile ground-level concentration.

7 Pollutant Maximum off-site Maximum off-site Total (background plus maximum offsite) Table 4 - Predicted maximum concentrations outside the Cockburn Cement facility with background levels included 2003 JULY 2010 DEC Averaging Background Total (background Guideline period plus maximum offsite) CO 8-hour NO 2 1-hour ; 320 SO 2 1-hour Lead 90-days n/a n/a n/a n/a 0.5 Nickel < < n/a PM hour Not included 1.26 n/a 1.9 n/a 50 1,2-dibromoethane n/a n/a n/a Xylene 24-hour n/a n/a n/a 4800 PAH n/a n/a n/a 1 Arsenic n/a n/a n/a Beryllium n/a n/a n/a Cadmium n/a n/a n/a Chromium 1-hour n/a n/a n/a n/a hour n/a n/a n/a n/a 4 Cobalt 8-hour n/a n/a n/a 0.5 Benzene 1-hour n/a n/a n/a 0.2 n/a 29 Benzene 24-hour n/a n/a n/a 1 Benzene n/a n/a n/a 0.17 I-TEQ for PCDDs and PCDFs 24-hour n/a n/a n/a (based on 2pg/TEQ/bw/day for a 70 kg person) Table 4 is an extract from Katestone Environmental Air Quality Modeling Assessment into compounds released from the Cockburn Cement Limited Munster facility/ n/a = not available

8 The findings of the dispersion modelling study indicate the following: The maximum ground-level concentrations of all air pollutants emitted from the CCL kiln stacks, at any location at or beyond the plant boundary, are predicted to be well below the air quality criteria with most of the pollutants predicted to be less than 1% of the air quality standards and guidelines. For the incremental impact of the CCL plant for air pollutants monitored above the method limit of detection, the most important air pollutant in terms of its predicted ground-level concentration as a percentage of the air quality standard is NO 2, which is 12% of the NEPM(Air) standard of 246 µg/m 3. For the cumulative impact of the CCL plant and background combined, the most important air pollutant in terms of its predicted ground-level concentration as a percentage of the air quality standard is carbon monoxide (CO), which is 45% of the NEPM(Air) standard of 11,247 µg/m 3. A significant proportion of the maximum concentration of CO is contributed by the ambient background used for the assessment. The predicted maximum groundlevel concentration due to CCL in isolation is 37 µg/m 3, which is less than 1% of the NEPM(Air) standard. Figure 1 shows the predicted maximum 1-hour average ground-level concentrations of NO 2. The highest concentrations were predicted to occur close to the site boundary. Conclusions The dispersion modelling has been undertaken to predict ground-level concentrations of air pollutants due to the Cockburn Cement Munster facility. The dispersion modelling has utilised the results of baseline emissions tests undertaken by ECS between October 2008 and July The dispersion modelling indicates that: Predicted maximum concentrations of all pollutants at or beyond the plant boundary are well below air quality standards and guidelines using conservative modelling assumptions, with most of the pollutants predicted to be less than 1% of the air quality standards for the CCL plant in isolation. The highest 1-hour, 8-hour and 24 hour average ground-level concentrations are predicted to occur close to the site boundary.

9 Glossary Term Definition µm microns µg micrograms mg milligram g grams kg kilograms t tonnes m metre km kilometre m 2 m 3 m/s km/h m 3 /s µg/m 3 mg/m 3 mg/nm 3 mg/dscm tpa square metres cubic metres metres per second kilometre per hour cubic metres per second micrograms per cubic metre milligrams per cubic metre milligrams per normalised cubic metre milligrams per dry standard cubic metre tonnes per annum C degrees Celsius SO 2 Sulphur dioxide NO X Oxides of nitrogen NO 2 Nitrogen dioxide CO Carbon monoxide PM Particulate matter (fine dust) PM 2.5 and PM 10 Particulate matter less than 2.5 or 10 microns, respectively TSP Total suspended particles VOC Volatile organic compounds PAH Polycyclic aromatic hydrocarbons