Wasting the Nation.indd - Groundwork
Wasting the Nation.indd - Groundwork
Wasting the Nation.indd - Groundwork
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Chapter 4: The toxic cradle of productionputs it [2007: 50]. Harley notes estimates that South Africa’s used tyres could replaceabout 25% of <strong>the</strong> 1.2 million tonnes of coal used in kilns. The industry anticipatessomething better than cheap fuel. It anticipates receiving a tipping fee for disposingof tyres and has also lobbied government for an ‘establishment subsidy’ against <strong>the</strong>costs of modifying <strong>the</strong> kilns. A draft Memorandum of Agreement between <strong>the</strong> DEATand waste tyre handlers, negotiated in 2006, looks like a very good deal for both <strong>the</strong>waste and cement industries with costs paid by <strong>the</strong> public in taxes and in <strong>the</strong> price oftyres. The DEAT now says <strong>the</strong>re is no intention of signing an agreement but does notexplain why <strong>the</strong> negotiations were abandoned.Meanwhile, DEAT’s proposed waste tyre regulations, published for comment inApril 2008, give priority to reuse or recycling over energy recovery, and of energyrecovery over disposal. As noted in Chapter 3, incineration with energy recovery isthus lifted above disposal in <strong>the</strong> waste hierarchy. The regulations do not seriouslyaddress minimisation but <strong>the</strong>y do impose ‘extended producer responsibility’ on tyreproducers who must prepare integrated waste management plans. The regulationswere published one month after <strong>the</strong> final hearings on <strong>the</strong> Waste Bill. They are in factpublished in terms of <strong>the</strong> Environmental Conservation Act but clearly anticipate <strong>the</strong>Waste Bill’s enactment. It is less clear how ‘recovery of energy’ relates to <strong>the</strong> clauserequiring that any regulation pertaining to incineration be submitted to parliamentor whe<strong>the</strong>r, in fact, <strong>the</strong>ir early publication is designed to pre-empt that requirement.Assuming, however, that <strong>the</strong> parliamentary hurdle is ei<strong>the</strong>r crossed or by-passed and<strong>the</strong> cement industry invests in <strong>the</strong> modification of kilns, it can be anticipated that <strong>the</strong>ywill provide <strong>the</strong> easiest disposal option.Kilns fired by coal are dirty operations. Kilns fired by used tyres are even dirtier. Astudy cited by Harley compares <strong>the</strong> two. 86 It shows that tyre burning emissions ofhydrocarbons are lower but particulates and most gas emissions are higher whileemissions of most metals are two or more times higher. Tyres, however, will not replacecoal but be burnt with coal and whatever o<strong>the</strong>r wastes are allowed to be added to <strong>the</strong>mix. Emissions from <strong>the</strong> combination of fuels are likely to be dirtier than <strong>the</strong> sumof emissions from each. This is because more chemicals will be available to createmore toxic compounds. Spent pot liners, for example, would add a heavy charge offluoride.86 Carrasco, F., Bredin, N., and Heitz, M. 2002. Atmospheric Pollutants and Trace Gases – Gaseous ContaminantEmissions as Affected by Burning Scrap Tyres in Cement Manufacturing. Journal of Environmental Quality.31:1484–1490.- 124 - groundWork - <strong>Wasting</strong> <strong>the</strong> <strong>Nation</strong>