2.6 Treatment and disposal

2.6(1)
This section describes the strategic priorities for treatment and disposal – Section 3.9 describes the practical details of implementation in terms of the instruments provided by the Act, and the associated organisational arrangements.

2.6(2)
Section.2(a)(iv) of the Waste Act clearly indicates that the treatment and disposal of waste is a “last resort” within the hierarchy of waste management measures. In terms of the definitions in the Waste Act:

• Treatment is any process that is designed to minimise the environmental impact of waste by changing the physical properties of waste or separating out and destroying toxic components of waste.
• Disposal refers specifically to the depositing or burial of waste onto, or into, land.

2.6(3)
Treatment, processing and disposal of waste must take place in accordance with the principles of environmental justice and equitable access to environmental services as articulated in the National Environmental Management Act 107 of 1998 (NEMA). This is particularly important in the light of the fact that landfill and waste treatment facilities tend to be located in close proximity to poor communities and informal settlements.

2.6(4)
Ensuring that waste is treated, processed and disposed of in an appropriate manner will be accomplished, in the first place, through the application of norms and standards that will:

• Determine appropriate operational standards for landfills, including monitoring and reporting requirements.
• Specify the types of waste that can be disposed of in particular categories of landfills.
• Determine operational standards for particular treatment and processing technologies.

2.6(5)
Norms and standards for the treatment and disposal of waste will be developed by DEA in terms of Section 7(1)(c) of the Waste Act, and will be promulgated during 2010.

2.6(6)
In terms of waste treatment and processing, DEA supports the development of alternatives to landfill, including incineration, gasification, and pyrolysis in so far as they generate energy. Thermal treatment of waste must conform to air emissions standards to mitigate the impact on health and the environment. While there are cost implications of conformant incineration as a waste processing technology, these need to be considered in relation to the rising costs of disposal to landfill as full cost accounting is implemented. It is anticipated that appropriate incineration, gasification and pyrolysis facilities will increase over time and ultimately replace landfills as the primary disposal mechanism for waste.

2.6(7)
The strategic approach to incineration, gasification and pyrolysis as energy recovery mechanisms is discussed in Section 2.4 of this strategy and the regulatory instruments are described in 3.7. 

2.6(8)
Landfill capacity, licensing compliance and shortfalls in treatment and disposal facilities have been identified as strategic challenges in Section 1.6 of this strategy.  It is the primary responsibility of municipalities to make sure that the landfills are properly managed according to national standards, and that they are permitted and are compliant with the conditions of their permits. At the same time municipalities need to plan proactively for future airspace requirements, and to make the necessary investments in capital infrastructure for this purpose. In addressing this challenge, DEA and the provinces will implement a programme for the licensing of landfills and compliance monitoring of licensing that:

• Provides a schedule for the licensing in terms of the Waste Act of treatment, processing and disposal facilities currently permitted in terms of Section 24 of NEMA.
• Includes targets for the licensing of currently unlicensed treatment, processing and disposal facilities.
• Establishes a task force in each province to systematically visit each municipality, establish the current status of the management of the existing landfills and planning for new landfills, and provide a recommendation report for each municipality, indicating the steps that must be taken to regularise the management and permitting of the existing landfills, and steps required to initiate planning for new landfill sites. This countrywide evaluation will be completed by 2011.
• Following the conclusion of the work of the above task force, a programme of work for the newly appointed EMIs from provincial and national government will focus on enforcing compliance with norms and standards for waste treatment and disposal that includes proactive monitoring of compliance by each municipality.
• Includes incentives for compliance by municipalities in terms of a redesigned “Cleanest Town” campaign as described in Section 5.6.

2.6(9)
The Waste Act permits the Minister to set norms and standards for the regionalisation of waste management services, which include treatment, processing and disposal. The primary focus of such regionalisation would be the establishment of regional landfills that service a number of local municipalities. These would be best managed by district municipalities, or by local municipalities within a district acting on behalf of a number of contiguous municipalities. The environmental benefits of regional landfills need to be off-set against the additional costs arising from transport of waste from local transfer stations and the potential for reduced local accountability for service delivery due to the greater scale at which decisions are taken. DEA will undertake a detailed cost-benefit analysis of regionalisation, and on the basis of this will prepare guidelines for use by district and local councils in evaluating whether and how to regionalise waste services, and in which instances the function of waste collection services should be shifted from local to district level. The guidelines will:

• Examine the environmental benefits and cost efficiencies derived from regionalisation.
• Provide an indicative cost model for planning purposes that can be used for calculating the costs of transporting waste to transfer stations, and from transfer stations to landfill, as well as the costs of disposal at local vs. regional sites.
• Stipulate appropriate spatial planning guidelines for distance from populations per density for transfer stations, landfill sites and waste treatment and recycling centres.
• Provide the basis for calculating optimal catchment borders for waste transfer stations in terms of the costs of collecting and transporting waste.

2.6(10)
The use of the Municipal Infrastructure Grant to promote regionalisation will be considered by COGTA and DEA following the completion of the above cost-benefit analysis. In order to understand the scale of capital investment required, municipalities will be required to quantify current landfill capacity and estimate future need based on a district by district analysis in their integrated waste management plans. This information will provide the statistical basis for strategic planning in relation to the utilisation of MIG funding to invest in regional treatment and disposal infrastructure, and the results of the survey will also inform municipal and provincial IWMPs.

2.6(11)
In terms of the treatment and disposal of hazardous waste and Health Care Risk Waste there is an urgent need for additional treatment capacity to be developed by the private sector, especially bearing in mind the long term goal of phasing out onsite disposal of this waste. Currently, the lack of capacity has led to an untenable reliance on obsolete and unreliable facilities and is hampering efforts to divert waste from landfill and support the recovery of energy from waste. Most provinces have no hazardous waste facilities, and where a proven need for these facilities exists, measures to address this must be included in provincial IWMPs.

2.6(12)
The requirements for thermal Health Care Risk Waste treatment facilities have been gazetted through the air quality standards setting process. All the current permits for HCRW treatment plants will be reviewed to ensure that they meet the requirements. Where Health Care Risk Waste treatment facilities are not compliant with the standards for incinerators set in the National Air Quality standards, the Department will require plans be drawn up for decommissioning the facilities within a year, with a view to decommissioning them within three years. Once the standards for non-thermal HCRW treatment facilities have been developed, all permits for non-thermal HCRW treatment facilities will be reviewed to ensure alignment and compliance. Similarly non-thermal HCRW treatment facilities that do not comply with the standards will be required to draw up plans within one year of the publication of the HCRW regulations plans for decommissioning them within three years.

2.6(13)
Municipal landfills are largely underfunded, and as a consequence the necessary management features such as cell development, leachate management, weigh bridges, compaction, capping etc. are not performed. The proper financing of landfills and shortfalls in treatment and disposal capacity will be addressed as part of the fiscal regime for waste management that progressively incorporates full-cost accounting into waste tariffs. Over the next five years the costs of managing municipal landfills need to be fully accounted for, and the costs passed directly onto businesses and consumers in terms of waste service tariffs. DEA will incorporate this into the guidelines to be developed regarding municipal tariffs.

2.6(14)
The legislative and regulatory instruments, policy processes, and institutional arrangements that will be used to achieve the strategic priorities for treatment, processing and disposal are outlined in Section 3.9 of this strategy.