In mid-November 2015, the KwaZulu-Natal Department for Economic Development, Tourism & Environmental Affairs (KZN DEDTEA) (Ugu District) granted an Environmental Authorisation for the use of alternative fuels and resources at NPC-Cimpor (NPC) Simuma.
NPC disguised the process of applying for authorization to incinerate hazardous waste into what they call a “Proposed Storage and Utilisation of Alternative Fuels and Resources’ at NPC’s Simuma Facility near Port Shepstone”. In reality, NPC are proposing to burn any hazardous industrial waste materials (called ‘alternative fuels’ by them), in their cement kilns to save costs (to them) by replacing coal and selected raw materials along with waste tyres and undefined hazardous wastes – this is effectively a cost saving initiative with disregard for any other social or environmental consequences. SRK Consulting are acting on behalf of NPC as the “independent environmental consultants”. It effectively puts the fox in charge of the henhouse!
At the outset we have to be absolutely clear that the global scientific literature unequivocally demonstrates that all hazardous waste incinerators produce the most toxic compound known to science, namely, 2,3,7,8-tetrachloro-dibenzo-p-dioxin and other similar compounds which we can simply call dioxins. These chemicals can bio accumulate in the food chain, are persistent in the environment and toxic at very low levels.
There is no such thing as “clean incineration”. All incinerators release toxic particulates, dioxins, greenhouse gases, and acid gases such as hydrogen chloride and toxic metals. Air pollution control devices are always needed to limit the releases to the air, but most of these pollution control devices such as filters and electrostatic precipitators merely move the pollutants from one environmental medium (the air) into another (solid filters or wastewater). If they are not maintained up to first world standards they invariably fail as has often happened with medical waste incinerators in South Africa over the past 10 years.
Furthermore, the toxic pollutants do not disappear; they are concentrated into other media that have to be treated as hazardous waste. Importantly, ash from incinerators is toxic, heavily contaminated with dioxins and leachable metals, and under the Stockholm Convention BAT/BEP guidelines, ash requires special land disposal as hazardous waste. Often, these added costs are not included in economic and human health analyses but they should be.
Dioxins are also proven to cause cancers including leukaemia, soft tissue sarcoma, non-Hodgkin’s lymphoma, prostate cancer, as well as cancers of the lungs, larynx and trachea. They can cause birth defects, alter the reproductive systems of foetuses, impact the IQ of children, suppress the immune system, decrease fertility, cause ovarian dysfunction, and reduce the sizes of male genitalia. They are highly persistent in the environment, so any dioxins produced today will remain for up to 150 years if on top of the soil, more than 500 years if in bodies of water, and up to 1000 years if the dioxins are covered by a few centimetres of soil surface.
South Africa is a party to the Stockholm Convention on Persistent Organic Pollutants. Under this treaty, South Africa is obligated to reduce and, where feasible, eliminate releases of dioxins to the environment. This authorisation as it currently exists does not take into account that no dioxins testing has been undertaken at this facility and makes no provision to meeting the objective of our obligation to reduce and, where feasible, eliminate releases of dioxins to the environment.
Furthermore, the KZN DEDTEA will not be able to enforce the current dioxin limit, much less a more stringent dioxin limit to protect public health currently, nor in the foreseeable future.
This is because South Africa does not have the technical in-country capacity to analyze for dioxins from incinerators. Globally there are limited the number of approved laboratories capable of testing for dioxins since it is a very difficult test to conduct. There are currently no labs in South Africa that can analyze for dioxins. Samples have to be sent to the EU, the US, Japan or other countries to undergo these expensive tests.
Most industrialized countries require testing for dioxin emissions every 6 months or every year. Some countries conduct frequent spot checks of dioxin emissions, since high levels of dioxins are formed during transient conditions in incinerators waste-to-energy plants and many manufacturers submit dioxin results under ideal conditions. Spot tests are how many incinerator facilities in the US and elsewhere have been shut down or heavily penalized for violations.
Given that South Africa does not have the in-country capability to conduct regular testing for dioxins of incinerators, much less frequent independent spot checks by regulatory bodies, these dioxin limits may just be limits in paper and not in reality thereby threatening public health.
Additionally this authorisation is effectively a move away from environmentally sound best practices of segregation, waste minimization, and environmental protection. By their very nature, hazardous waste incinerators are technologies that need waste as an input to operate. Therefore, they encourage generation of more waste in order for the operators to make a profit. There are case studies worldwide that have shown that when industries and communities decide to reduce waste, increase recycling, improve composting, etc., incinerators and waste-to-energy plants end up losing money and have to shut down.
Relying on hazardous incinerators will do the opposite – discourage less segregation and produce more waste so that incinerator operators can make more profits. Moreover, investing in incineration and waste-to-energy plants commit communities to these dirtier technologies for the long term, commitments that require communities to generate more waste for incinerators to operate profitably. We should be moving in the opposite direction: encouraging less consumption of materials, greater demand side management, minimization of waste, and more protection of the environment and public health.
Good waste management begins with preventing waste being generated in the first place — after all, what is not produced does not have to be disposed of. Hence, waste prevention and minimisation should have top priority in any waste management plan. Where waste material is produced, planners and managers must always choose the optimal treatment option with the lowest possible risks to human health and the environment. Each treatment option brings with it different impacts to different parts of the environment.
There is no blueprint which can be applied in every situation but there are firm principles upon which an approach to waste management is based, namely:
• Prevention principle — waste production must be minimised and avoided where possible.
• Producer responsibility and polluter pays principle — those who produce the waste or contaminate the environment should pay the full costs of their actions.
• Precautionary principle — we should anticipate potential problems.
• Proximity principle — waste should be disposed of as closely as possible to where it is produced through reduced waste movements and improved waste transport regulation.
This authorisation flies in the face of implementing these principles in KZN. Furthermore the NPC cement kilns are neither properly designed for the purpose for incinerating hazardous waste, nor will they be held to the same regulatory standard as other purpose built hazardous waste incinerators in similar jurisdictions. While it is claimed by NPC-Cimpor that the very high temperatures and long residency times within NPC’s cement kilns result in high incineration efficiency and low emissions, the NPC cement kilns are simply not designed for burning heterogeneous waste streams in the first place.
And because they are not regarded as hazardous waste incinerators, they will generally avoid having to meet stringent emissions regulations!