70 likes | 207 Views
POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CREMATION IN SA. WHO WE ARE. REPRESENTING ENVIROCIN PET CREMATORIUM > EST. 1996 > 35 JOBS REPRESENTING SA ASSOC. OF COMPANION ANIMAL CREMATORIES
E N D
POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CREMATION IN SA
WHO WE ARE • REPRESENTING ENVIROCIN PET CREMATORIUM > EST. 1996 > 35 JOBS • REPRESENTING SA ASSOC. OF COMPANION ANIMAL CREMATORIES • CREMATE ONLY ANIMAL BODIES > PREVIOUSLY LANDFILLED > HAZARDOUS! • 1 IN 3 PETS CREMATED ARE WELFARE PETS FROM SPCA’s etc.
HISTORICAL SNAPSHOT • ORIGINALLY INCLUDED IN CATEGORY 8: DISPOSAL OF HAZARDOUS & GENERAL WASTE 31 MARCH 2010 • COMMENTED 20 AUGUST 2009 • MEETING WITH MAZWI LUSHABA 2010 • COMMENTED 30 JULY 2010 • COMMENTED 30 JANUARY 2012 • S21 AMENDMENT 27 FEBRUARY 2012 • S21 AMENDMENT 23 NOVEMBER 2012 • COMMENTED 23 DECEMBER 2012
MAIN CONCERNS & REQUESTS • SEPARATION FROM CATEGORY 8: HAZ/GEN • CREATION OF CATEGORY FOR COMPANION ANIMAL CREMATORIA • CAPACITY THRESHOLD OF 10 TONNES PER DAY HOMOGENOUS ANIMAL MATTER (Directive 2000/76/EC of European Parliament) • REVIEW OF BI-ANNUAL TESTING REQ. > CONC VS VOLUME • SEEK CLARITY ON “VETERINARY WASTE” • THOUGHTFUL REVIEW OF EMISSIONS LIMITS • 3% O2 vs 10%?
RESEARCH & DATA • DETRIMENTAL EFFECT ON ENVIRONMENT? • WSP ENVIRONMENTAL & WNWN TECHNOLOGIES INDEPENDENT STUDIES • COST OF WET & DRY SCRUBBERS PROHIBITIVE • INTERNATIONAL > LESS RESTRICTIVE (WNWN) • 850°C & 1100°C PRIMARY & SECONDARY (US) • EPA INFO > “EMISSIONS FROM PC’S VERY LOW WHEN COMPARED WITH OTHER SOLID WASTE COMBUSTION UNITS” • EPA > “ADVERSE IMPACTS ASSOCIATED WITH REGULATION OF PC’s OUTWEIGHS BENEFITS OF REGULATION THEREFORE NOT INCLUDED IN OSWI” • WSP > DISPERSION MODELLING > “DO NOT POSE A CONCERN TO HUMAN HEALTH”
UNINTENDED CONSEQUENCES • PETS TO LANDFILL > ZINGISA SMALE • WELFARE ANIMALS TO LANDFILL • HUMAN RIGHTS/ENVIRONMENTAL ISSUE • NON-COMPLIANCE & ASSOCIATED PENALTIES • JOB LOSSES & UNEMPLOYMENT • PET OWNER UPROAR • HORSES • INHIBITING GROWTH & EXPANSION