This is a final version submitted for publication. Minor editorial changes may have subsequently been made.
This paper argues that the construction of a high temperature incinerator in Australia is an end-of-pipe solution to a problem that would be better and more permanently solved through waste minimisation measures.
Everyone espouses the virtues of waste minimisation, from the greenest environmentalist to the most conservative bureaucrat. Who can argue with the view that it would be better not to have to deal with hazardous wastes in the first place? Indeed, the Joint Taskforce on Intractable Waste puts forward a hierarchy of management processes in order of desirability:- prevention, minimisation, recycling, treatment (physical, chemical, biological, incineration) and finally landfill. (ref 1) We can all agree with this!
The question remains, however, whether such statements will be followed up with sufficient political will and industrial willingness for them to mean anything. The gap between the words and the actions is painfully obvious overseas. In the United States, despite a 1984 Congress commitment to hazardous waste reduction, their Environmental Protection Agency (EPA) only requested $398,000 (0.03% of their total budget) for waste minimisation projects in 1988. Moreover, studies undertaken in the United States have shown that although chemical companies could save money by reducing wastes at source they seldom do so. (ref 2)
And in Australia, most of the money and research apportioned to the Joint Taskforce on Intractable Waste has gone into investigations into a High Temperature Incinerator for South-East Australia; choosing the technology, finding a site for it, selling it to community groups. This proposed incinerator represents the traditional method of dealing with wastes that everyone agrees is low down on the acceptability scale. It is an "end-of-pipe" solution. But more than this, it is a solution that will actively impede waste minimisation in Australia.
There is some evidence that a waste treatment facility such as a high temperature incinerator creates a vested interest in waste creation. A high temperature incinerator is associated with high capital costs and running costs. It is only economical if it operates constantly. Some waste disposal operators in the US have expressed concern that high temperature incinerators may face shortages of, and competition for, wastes as energy and resource costs increase and recycling becomes more viable.
This may not be a problem for a government-owned facility. A government may happily endeavour to reduce the feedstocks for a multi-million dollar facility although it is becoming more and more uneconomical to run. But the mere existence of the facility will have a dampening effect on research towards alternative ways of dealing with intractable wastes, particularly damaging the incentive to change production processes and products so as to eliminate and minimise intractable wastes.
WHY WASTE MINIMISATION?
There are many reasons why it is preferable to minimise wastes rather than deal with them after they have been generated. The most compelling is that creation and subsequent destruction of waste materials is inefficient in terms of energy, resources, capital, labour and any other input quantity that might be considered. This inefficiency is too often ignored by companies which merely pass on the costs to the consumer; there is no incentive to be more efficient whilst the price of the product is able to include the immediate costs of inefficiency.
There is, however, a more long-term price to be paid for inefficiency in energy and resources. This price is beginning to be felt as energy and resource scarcity becomes more pronounced and the marginal cost of extracting oil and minerals increases exponentially. The environmental costs of inefficient and wasteful resource and energy use is also being felt in terms of global climatic problems.
Whilst wastes are being produced they continue to offer the opportunity for pollution and occupational exposure. The reduction of wastes being generated provides a permanent cure to the waste problem in a way that "end-of-pipe" solutions cannot. Once the wastes are generated they create a continuing problem to be dealt with. They must be handled, transported, treated and disposed of perpetually. And at each stage there is an opportunity for low level, accidental or unwitting human and environmental exposure and consequent damage.
Alternatives to "end-of-pipe" technologies include the following (ref 3),
1. Input Substitution (replacing a substance used in a production process
with one that will not yield toxic waste);
2. Product Reformulation or Substitution (substituting for the existing end-product an end-product which requires a less waste-intensive manufacturing process);
3. Production Process Redesign (developing and using production processes of a fundamentally different design than those currently used, and which generate less waste);
4. Production Process Modernisation (replacing existing equipment based on the same production methods but modified to generate less waste);
5. Improved Operation and Maintenance of Production Equipment (modifying existing equipment and/or methods for using that equipment in order to reduce waste generation, e.g. through good housekeeping practices, or addition of process control equipment);
Reuse and recycling are a compromise solution. They are preferable to treating and disposing of wastes in terms of resource usage but they nevertheless increase the risk of occupational exposure and can still leave a hazardous residue. Moreover reuse and recycling depend on the production of waste. The search for ways of utilising waste materials can lead to some dangerous situations such as the recent example in Oklahoma where the Kerr-McGee Corporation has sprayed thousand of hectares of pasture with a fertiliser recycled from radioactive wastes. (ref 4)
WHY NOT AN INCINERATOR?
A fair dinkum public policy that really wanted to push waste minimisation first would encourage industries to recognise the existing opportunities for reducing wastes at source and to would create the circumstances to promote appropriate research in that direction.
The widely respected economist, Nathan Rosenberg, has studied the process of innovation and in a paper on inducement mechanisms and focusing devices (ref 5) he points out that a firm could apply their research and development efforts to any number of areas and aspects of the production process. What they actually do is attack the most restrictive constraint. This constraint may be an imbalance between complementary processes, a labour shortage or uncertainties in the supply of an input material. Such constraints focus attention and direct technologies in certain directions.
In fact, the absence of a high temperature incinerator in Australia to destroy intractable wastes has placed just such a constraint on industries producing intractable wastes. At present these wastes must be stored as there is no legal way of disposing of them. The storage of intractable wastes poses an ever increasing and on-going cost to industry as wastes take up more and more space and are subject to higher and higher insurance premiums.
ICI Australia which generates most of Australia's intractable wastes (76%) and is responsible for the largest part of Australia's existing stockpile of these wastes, has been forced to spend considerable amounts of money on research aimed at minimising or recycling their wastes. This research would not have been undertaken if a high temperature incinerator had been available.
Until the mid-1970s ICI Australia directed its research and development towards recycling liquid wastes from its Ethylene Dichloride (EDC) Plant. By 1977 2400 t/year of liquid organochlorine compounds from the EDC plant were being recycled to produce solvents. Further research led to the establishment of a heavy ends treatment plant in 1977 to recycle the liquid portion of the waste from the solvents plant leaving only the solid hexachlorobenzene (HCB). In 1983 a thin film evaporator facilitated the recycling of a further 350 t/year of liquid waste from the EDC plant and a flash evaporator was planned for 1988 to recover the remaining EDC plant liquid waste. (ref 6)
An ICI spokesman stated in 1986 that
During the 1970's and early 1980's HTI [high temperature incineration] was regarded as the most appropriate disposal option for both technical and economic reasons. The economic justification is not so obvious now by comparison with recycling processes. (ref 7)
ICI Australia has therefore been forced to solve its liquid waste problem in a way that its operations overseas have not because a high temperature incinerator was not available. Overseas, rather than recycling the liquid waste from similar plants, high temperature incinerators were just slotted onto the end of the manufacturing process. Until an Australian high temperature incinerator became a real possibility ICI Australia was directing research towards solving the remaining problem of the solid HCB waste.
At present, ICI is proposing to close down its solvents plant and claims that it will no longer be producing HCB in a few years. But what new plants may be considered over the next few years? Whether the chemical industry will still be generating intractable wastes after the closure of ICI's solvents plant will depend even more on the availability of a high temperature incinerator in Australia than it does now. It will also affect the decision of any other company to set up a production process that generates intractable waste.
As mentioned above, recycling of wastes is not ideal method of dealing with them but it is nevertheless more resource efficient than incineration. The continued non-availability of an incinerator has been a constraint upon ICI which encourages research into waste generation reduction, recycling and treatment methodologies and which may lead to beneficial technological innovation.
The establishment of an incinerator by facilitating the manufacture of products that have intractable wastes may also impede the development and introduction of new substitute products which could be competing with those products in the near future. Substitute refrigerants and solvents which do not rely on chlorine for a feedstock would not only overcome the problem of creating intractable organochlorines as by-products but would also be less threatening to the planet's ozone layer and climatic balance.
If the existing stockpile of intractable waste is stored securely until the generation of intractable waste has ceased then at that time there may well be better methods of disposal for that waste than incineration. The chemical solution being developed at Sydney University by Professor Jim Beattie and Dr. Robert Kaziro may be one such option.
Now is not the time to build a high temperature incinerator. Sure the existing stockpile of intractable wastes will eventually have to be dealt with. But first priority should be given to ceasing the production of intractable wastes. Once this has been achieved then a solution for dealing with the stockpile can be found. It will not work the other way round. The Taskforce hopes that the high charges will act as a constraint on industry providing an incentive for waste minimisation and they intend that a ten year life span for the incinerator will ensure that intractable waste will no longer be produced after that time.
All parties are well aware that such good intentions are necessary if the high temperature incinerator is to have any chance of getting sufficient acceptance for it to be built. Once the incinerator is established, however, and the Taskforce disbanded, such pressures will disappear to be replaced by industrial, economic and political pressures to keep prices down, and the facility open. The establishment of a high temperature incinerator in Australia at this time will spell the end to our chances of finally eliminating intractable waste production here despite the best intentions of the Joint Taskforce on Intractable Waste.