06 September 2006

Is the consumer going to pay for cement kilns to burn tyres?

September 7 was the Global Anti Incineration Alliance’s (GAIA) day of action against incineration and waste. In solidarity and support of this action, groundWork, a leading environmental justice NGO, is challenging the cement industry’s current push to burn waste, including tyres, in their kilns.

A draft memorandum between the Department of Environmental Affairs and Tourism (DEAT) and the South African Tyre Recycling Process Company (SATRP), who represents tyre suppliers and the waste tyre industry, suggests that it is quite possible that the buyer of new tyres will be funding cement kilns to upgrade their kilns in order to be able to burn used tyres and other waste.

The draft memorandum defines “tyre derived fuel users” as persons or institutions engaged in energy recovery from waste tyres, and “waste tyre recyclers” as persons or institutions who transform waste tyres into new products or raw materials. “Waste tyre users” are defined as tyre derived fuel users or waste tyre recyclers.

The upshot of the memo is that waste tyre users will be able to tender for waste tyres from SATRP. To encourage the waste tyre industry, an establishment subsidy of 38c per kilogram of waste will be paid to the waste tyre user, as well as a maximum disposal fee of 14c per kilogram. The monies for this will be raised through a Green Fee which will be levied on each new tyre sold in South Africa and passed on to SATRP.

Cement manufacturers are currently positioning themselves to be able to burn tyres and other wastes by starting Environmental Impact Assessment (EIA) processes throughout the country. Two EIAs have already been submitted by Holcim. One proposal, in the Northern Cape, was accepted and the other, in the Northern Province, was rejected. After groundWork appealed the former, the process has been halted for the time being. It is interesting to note that the rejection took place in the Northern Province based on the precautionary principle. Pretoria Portland Cement (PPC) has also recently given notice of their EIA process and it would seem that Holcim are poised to re-start theirs.

Between PPC and Holcim, the major players in the South African market, there are at least 14 active kilns. Cement kilns require huge amounts of energy in order for the correct chemical processes to take place, and their fuel bills amount to about 35% of their total costs. It would be very beneficial to the industry to be able to burn tyres, for which service they will be paid, rather than coal, for which they have to pay. As tyres and coal release similar amounts of energy when burned, a tonne of tyres would roughly replace a tonne of coal – and for a tonne of tyres the cement kiln operator would receive R520 rather than spend about R200.

While it is not possible to completely replace coal with tyres, it is estimated in their EIA Background Information Document that PPC could save up to 150 000 tons of coal per year. Even if they were not paid to burn tyres instead, this would represent a saving on fuel of approximately 30 million Rand each year. There is a small snag, however – South Africa only produces about 75 000 tonnes of waste tyres each year. In order to make up the short-fall, which the industry must surely want to do, other wastes such as used oil, plastic, sewage and biomass could be burned. It is also possible that spent tyres and other wastes could be imported from other countries in order to make up the deficit.

Incineration of waste, even when given the fancy name of secondary materials co-processing, should never be a primary option for the disposal of any kind of waste. Whenever anything is burned various chemicals are released, many of which are harmful to people and toxic ash is left behind although, in the case of cement kilns, this ash would be incorporated into the cement. Despite fancy technologies, cement kilns all over the world are being cited for exceeding their emission limits – and this when they are not even terribly well regulated. In the waste hierarchy, incineration, even when for energy reclamation, is the second least approved method of dealing with waste.

Even without burning hazardous waste, the cement industry is a dirty one. World wide, it is responsible for more than 5% of the total CO2 emissions, and 3% of all greenhouse gases (about 140 million tonnes every year). A disproportionate amount of mercury is also emitted by the industry, as well as large amounts of particulate matter. The burning of waste, while touted as the answer to many of the ills of the industry, is an unsustainable activity which has not been proven to be safe and which, logic dictates, is intrinsically dangerous. Even though PPC and Holcim characterise the practice as internationally accepted, cement kilns throughout the world are being challenged by the people who live next to them on the basis of real concerns regarding the polluted air that they breathe and their health.

In South Africa we have yet to finalise the waste bill and regulations and most provincial and local authorities have limited guidance on overall waste issues. A proper legal enforcement framework does not even exist and we have very few adequately trained government enforcement officers or inspectors knowledgeable and experienced in toxic/hazardous waste incineration. In addition, the South African cement industry does not have proven expertise to ensure effective and appropriate storage, handling and processing of hazardous waste and nor does it have the necessary guidelines, standards or expertise in order to ensure that the safety of its workforce, the environment and public health is protected when handling hazardous waste.

groundWork argues that in the absence of policy on the handling of Waste the EIA processes for burning ‘alternative fuels’ in cement kilns should be stopped.