Wasting the Nation.indd - Groundwork

Chapter 4: The toxic cradle of productionputs it [2007: 50]. Harley notes estimates that South Africa’s used tyres could replaceabout 25% of the 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 thecosts of modifying the kilns. A draft Memorandum of Agreement between the DEATand waste tyre handlers, negotiated in 2006, looks like a very good deal for both thewaste and cement industries with costs paid by the public in taxes and in the price oftyres. The DEAT now says there is no intention of signing an agreement but does notexplain why the 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 the waste hierarchy. The regulations do not seriouslyaddress minimisation but they do impose ‘extended producer responsibility’ on tyreproducers who must prepare integrated waste management plans. The regulationswere published one month after the final hearings on the Waste Bill. They are in factpublished in terms of the Environmental Conservation Act but clearly anticipate theWaste Bill’s enactment. It is less clear how ‘recovery of energy’ relates to the clauserequiring that any regulation pertaining to incineration be submitted to parliamentor whether, in fact, their early publication is designed to pre-empt that requirement.Assuming, however, that the parliamentary hurdle is either crossed or by-passed andthe cement industry invests in the modification of kilns, it can be anticipated that theywill provide the easiest disposal option.Kilns fired by coal are dirty operations. Kilns fired by used tyres are even dirtier. Astudy cited by Harley compares the 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 other wastes are allowed to be added to themix. Emissions from the combination of fuels are likely to be dirtier than the 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 - Wasting the Nation