EPA Decision Preservers Scrap Tire Markets

Rulemaking Safeguards 20 Years of RMA Advocacy and Environmental Success

For more information contact:
Dan Zielinski
(202) 682-4846
dzielinski@rma.org

WASHINGTON, D.C.February 23, 2011 - The U.S. Environmental Protection Agency today announced a rulemaking that will preserve scrap tire markets and ensure the continued success of scrap tire management advocacy by the Rubber Manufacturers Association over the past 20 years.

The rule allows annually generated scrap tires that are removed from vehicles to be used as fuel by an industrial facility. Cement kilns, pulp and paper mills and electric utilities are the major users of tire derived fuel (TDF).

In its proposed rule, EPA recommended that annually generated tires be processed to remove the metal before being considered a fuel under the Clean Air Act. However, that provision would have merely increased the energy consumption, air emissions and costs associated with delivering tire derived fuels to industrial customers without any environmental benefit.

RMA recognizes that EPA is still requiring processing of whole tires removed from historical scrap tire stockpiles. RMA continues to encourage EPA to consider a more expansive definition of processing to allow these whole tires to be combusted as tire derived fuel. RMA continues to evaluate the final rule for additional insights and impacts on the tire industry.

“EPA clearly listened to the arguments advocated by RMA and other key stakeholders to deliver a rule that ensures continued improvement in scrap tire management efforts in the U.S.,” said Charles A. Cannon, RMA president and CEO. “While we are still analyzing several aspects of this final rule, the big picture is that this is a victory for the environment and for RMA’s scrap tire advocacy efforts.

RMA efforts were instrumental in the outcome of this EPA rulemaking. The association recognized early in this process that to protect tire derived fuel markets, a coordinated, common sense approach was necessary.

RMA spearheaded efforts to promote the use of scrap tires as tire derived fuel, stressed the importance of this key market to the health of the overall all scrap tire marketplace and highlight the dire environmental consequences should scrap tire stockpiles again be allowed to grow. RMA coordinated outreach, education and advocacy to the EPA, the Administration and the states about the critical role tire derived fuel plays in managing scrap tires, economizing fuel resources and protecting the environment.

When RMA began its scrap tire efforts in 1990, about 11 percent of scrap tires went to end use markets, and one billion scrap tires were in stockpiles across the country. Today, fewer than 100 million tires remain in stockpiles and over 80 percent of scrap tires are utilized in end use markets. Tire derived fuel markets consume just over 50 percent of the scrap tires generated annually.

“Scrap tire markets are mature and stable; scrap tires are recognized as a valuable commodity and are used in a number of applications, including tire derived fuel,” Cannon said. “RMA is extremely proud of these accomplishments, thanks to sound state regulations, sustainable, cost-effective markets and steady industry efforts.”

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The Rubber Manufacturers Association is the national trade association for tire manufacturers that make tires in the U.S.

EPA Proposal is Anti-Environment, Anti-Business and Anti-Common Sense

Action Will Increase Stockpiled Scrap Tires, Risk to Public Health and Safety

For more information contact:
Dan Zielinski
(202) 682-4846
dzielinski@rma.org

WASHINGTON, D.C.August 5, 2010 - The U.S. Environmental Protection Agency (EPA) has proposed a rule that would significantly harm the existing infrastructure that manages scrap tires as well as reverse two decades of environmental cleanup success, according to the Rubber Manufacturers Association (RMA).

After decades of EPA-sanctioned use as a supplemental industrial fuel, EPA is proposing now to declare whole scrap tires a solid waste. The new designation would require facilities using whole tire-derived fuel (TDF) to add costly new emission controls that would not be required to burn traditional, less efficient fuels. Instead of this option, many TDF users, likely will opt to stop using TDF in favor of more costly, less efficient and higher emitting traditional fossil fuels, including coal. This will likely result in a dramatic reduction of TDF use while driving tens of millions of scrap tires back to landfills, stockpiles and illegal dumping sites.

At the same time, EPA will still allow the use of processed scrap tires to be used as fuel only if most of the steel content is removed, which would add costs to TDF use for facilities such as cement kilns, and increase the amount of energy needed and air pollutants emitted to supply TDF to these facilities. Steel content in tires does not affect overall emissions when consumed as TDF. Instead, the steel is used as a raw material in the manufacture of cement.

“EPA’s proposed regulatory scheme would devastate the tire-derived fuel market in the U.S. which will ripple across the entire scrap tire market infrastructure,” said Tracey Norberg, RMA senior vice president. “Worse, the proposal will drive scrap tires back to stockpiles and illegal tire dumps after two decades of success in cleaning up stockpiles and promoting safe, viable, effective markets for scrap tires.”

Scrap tire management is an environmental success story in the U.S. In 1990, more than one billion tires were stockpiled across the country while only 11 percent of annually generated scrap tires were reused. Today, fewer than 100 million tires remain stockpiled and nearly 90 percent of annually generated scrap tires are reused. Each year, about 300 million scrap tires are generated in the U.S. Of those, about 52 percent are used as TDF in the cement industry, pulp and paper mills and by some utility and industrial boilers.

In comments filed today, RMA said that EPA does not have the legal authority to declare TDF as a “solid waste” instead of a fuel. TDF has a long history as a fuel, which is recognized by EPA. The agency’s own data indicates that the combustion of TDF, whether whole or minimally processed without removal of metal beads, not only provides better fuel value than coal (12,000 – 16,000 Btu/lb) but also results in comparable or even lower emissions than coal combustion.

“EPA’s proposal turns common sense on its head and would harm the environment while causing potentially thousands of jobs to be lost in the scrap tire industry,” Norberg said.

More tire stockpiles increases the risk of fire and mosquito infestation. Unlike the controlled, extreme heat combustion when TDF is used as a fuel, a burning pile of scrap tires can cause considerable environmental harm. Such fires can burn for days or weeks. Stockpiled tires also collect rainwater which then becomes an ideal breeding ground for mosquitoes that carry diseases.

RMA advocated that EPA should consider TDF an historical fuel, regardless of whether the scrap tires have been discarded, which would allow states to continue to regulate those scrap tires not used as TDF under state waste management regulations. Alternatively, RMA indicated it supported an approach initially outlined by EPA in January 2009 that would have allowed annually generated scrap tires to be continue to be used as a fuel but stockpiled scrap tires would be considered “discarded” and therefore be a solid waste subject to new emission controls if combusted.

“EPA should reconsider this deeply flawed, anti-environment, anti-business and anti-common sense proposal,” Norberg said.

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The Rubber Manufacturers Association is the national trade association for the rubber products industry. Its members include companies that manufacture various rubber products, including tires, hoses, belts, seals, molded goods, and other finished rubber products.

RMA Says Proposed Federal Ozone Rule is “Inappropriate”

 EPA “Short Circuiting” Regulatory Process; Will Add Huge Costs, Little Benefit

For more information contact:
Dan Zielinski
(202) 682-4846
dzielinski@rma.org

WASHINGTON, D.C.April 19, 2010 - A new proposed federal regulation aimed at reducing ozone short circuits the regulatory process, adds as much as $90 billion in costs to businesses and has an adverse effect on air quality, according to comments filed by the Rubber Manufacturers Association.

Under the federal Clean Air Act, the U.S. Environmental Protection Agency (EPA) is required to evaluate National Ambient Air Quality Standards (NAAQS) for ground level ozone. In 2008, President Bush’s Administration issued new ozone standards. Eighteen months later, the Obama Administration decided to reconsider the new standards.

“EPA’s decision to revise the NAAQS for ground level ozone short cuts the process for revising the NAAQS established in the CAA (Clean Air Act) and in the process the [EPA] Administrator is not relying on the “latest scientific knowledge” regarding the public health and welfare as the statute requires,” RMA wrote. “The Clean Air Act establishes a clear process for reviewing and revising NAAQS over a five-year period. EPA’s proposed revised ozone NAAQS bypass that statutorily mandated process.”

RMA also said that the health science evidence does not demonstrate that a new standard is justified. “In simple terms, EPA is proposing to reduce the primary ozone NAAQS based largely on clinical studies showing respiratory effects—but no apparent health effects—in sensitive individuals at 0.060 ppm (parts per million), and on epidemiology studies that EPA believes suggest there may be effects of exposure to ozone concentrations below 0.075 ppm,” RMA said in its comments. “The clinical studies, however, did not demonstrate a clear adverse health effect from exposure to ozone concentrations below 0.075 ppm, even in the harsh conditions of the clinical tests.

“Furthermore, these same clinical studies were reviewed as part of the 2008 Ozone NAAQS final rule and did not justify a lower standard at that time. It is inappropriate for EPA to now use this dated information to justify lowering the 2008 ground level ozone standard.”

Worse, EPA’s decision to revise the 2008 ozone standards will result in less improvement to ground level ozone concentrations and increased burdens on state and local agencies.

“EPA’s decision to revise the 2008 ozone standards to a more stringent limit of 0.060 – 0.070 ppm will, under the circumstances, impede rather than improve human health protection measures,” RMA said.

EPA’s rulemaking schedule would have a final rule by August 31, 2010; final designations by August 2011 and; state implementation plans for the reconsidered standards by December 2013.

“This abbreviated schedule is unrealistic, in RMA’s view, in light of experience and especially for the completely new form of the secondary standard,” RMA said. “And in any event, litigation over the proposed revisions could further delay implementation of the revised NAAQS standards. The effect of delaying implementation will result in less improvement in ground level ozone concentrations because states will continue to implement the 1997 8-hour standard of 0.08 (effectively 0.084) ppm rather than the 2008 8-hour standard of 0.0750 ppm.”

For the tire industry, the effect of this revised standard will be extremely burdensome.
RMA member facilities are predominantly located in rural areas that are currently designated as attainment areas. An attainment area is one that has “attained” an ozone level that complies with federal regulations. A “non-attainment area” is one that exceeds federal regulations for ozone.

Under the EPA proposed revision, many RMA member facilities will be in non-attainment areas. Facilities located in a non-attainment area face increased operating costs, permitting delays, and restrictions on expansions. Additionally, facilities located in counties that are designated as “severe” or “extreme” non-attainment face significant penalty fees under the Clean Air Act. An increase in the number of non-attainment areas as a result of the proposed rule will significantly impact states and counties that must find the resources to comply with the additional burdens of being in non-attainment.

The costs for a revised ozone rule are estimated to be significant while the benefits are limited. EPA estimates that revising the primary standard to a level at or near 0.060 ppm would produce annual benefits of $35-100 billion in 2020. Annual costs, however, are projected to be $52-90 billion.

“In other words, even using EPA’s optimistic assumptions about attainment status, costs, and benefits, there is a good chance that the costs of meeting the revised NAAQS would exceed the benefits by billions of dollars,” RMA said. “If EPA lowers the primary ozone NAAQS to a level at or near 0.070 ppm, EPA projects annual benefits of $13-37 billion and annual costs of $19-25 billion. Again, even with EPA’s dubious assumptions it is entirely possible that the costs would exceed any benefits.”

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The Rubber Manufacturers Association is the national trade association for the rubber products industry. Its members include companies that manufacture various rubber products, including tires, hoses, belts, seals, molded goods, and other finished rubber products.

RMA Says New EPA Report Again Demonstrates Tire Rubber As Environmentally Sound

No Adverse Human, Ecological Health Effects

For more information contact:
Dan Zielinski
(202) 682-4846
dzielinski@rma.org

WASHINGTON, D.C.December 10, 2009 - A study released today by the U.S. Environmental Protection Agency found no cause for human health or environmental concerns with the use of tire rubber used in construction of athletic fields and playgrounds.

While the EPA study was limited in its scope, it adds to a growing list of scientific data showing that ground rubber from waste tires does not pose any adverse health or ecological risks.

“Today’s report by EPA is not a surprise,” said Michael Blumenthal, RMA vice president. “Many studies and tests have shown over many years that the use of recycled tire rubber in consumer applications such as playground and athletic fields are not only safe by have several significant safety benefits.”

Last year, RMA sponsored a review of available literature on the potential health and environmental effects of tire rubber, which is produced from scrap tires.

The RMA-sponsored report evaluated the health and ecological risks associated with the use of recycled tire rubber in consumer applications, particularly playgrounds and athletic fields. A thorough review of available literature was conducted including studies from both advocates and opponents to the use of recycled tire materials. An examination of the weight of evidence across all of the available studies was conducted to enable a comprehensive assessment of potential risk.

The use of recycled tire rubber is widely used as an infill material for synthetic sports fields and as a floor cover for playgrounds. Both applications take advantage of the exceptional cushioning characteristics of tire rubber and provide increased safety relative to other materials. Athletic fields and playground cover are two of the fastest growing and largest end uses for recycled ground tire rubber. Approximately 13 million scrap tires are used in these applications annually.

“Although EPA stated that hope to conduct further review of available scientific literature, we remain confident that any additional research will show that playgrounds and athletic fields and other consumer products made from tire rubber are environmentally sound,” Blumenthal said.

RMA’s report, Review of the Human Health & Ecological Safety of Exposure to Recycled Tire Rubber found at Playgrounds and Synthetic Turf Fields, is available for download at www.rma.orgClick here to review the report.

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The Rubber Manufacturers Association is the national trade association for the rubber products industry. Its members include companies that manufacture various rubber products, including tires, hoses, belts, seals, molded goods, and other finished rubber products.

RMA to Coordinate and Participate in Industrial Byproducts Workshop

For more information contact:
Dan Zielinski
(202) 682-4846
dzielinski@rma.org

WASHINGTON, D.C.October 10, 2006 - The Rubber Manufacturers Association (RMA), as part of the Industrial Resources Council, is coordinating a one day workshop on the use of industrial byproducts in highway construction in Little Rock, Arkansas on February 1, 2007.

“RMA has always sought to work with other stakeholders in an effort to provide the most timely information that will allow us to expand markets for scrap tires,” stated RMA’s Senior Technical Director Michael Blumenthal. “We are very pleased to have the opportunity to return to Arkansas and provide a venue where new market opportunities can be explored.”

The workshop is being co-sponsored by the Arkansas Department of Environmental Quality and EPA Regions 4 & 6 Office of Solid Waste & Recycling, as well as the Industrial Resource Council (IRC). The IRC is comprised of organizations representing industrial byproducts. Currently the members of the IRC are: American Coal Ash Association; Construction Materials Recycling Association; Foundry Industry Recycling Starts Today (FIRST); National Council for Air & Stream Improvement (NCASI); National Slag Association (NSA) and Rubber Manufacturers Association (RMA).

The workshop will be held at the Arkansas Highway & Transportation Department, 10324 Interstate 30, in Little Rock, Arkansas from 8:30 AM until 5:00 PM on Thursday, February 1, 2007. There is no cost to attend the workshop, but attendees must register with RMA to attend.

Increasing the use of industrial byproducts is a priority goal of the EPA’s solid waste and recycling program. The EPA Resource Conservation Challenge has identified industrial byproducts as an underutilized resource and is seeking ways to get industry and government working together to take advantage of this resource. The Arkansas workshop is the first effort by the IRC to engage state and local officials in this process.

“The workshop offers a one-stop learning experience to educate the highway community, state and county officials on the benefits of using industrial byproducts in highway construction,” Blumenthal said.

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The Rubber Manufacturers Association is the national trade association for the rubber products industry. Its members include more than 100 companies that manufacture various rubber products, including tires, hoses, belts, seals, molded goods, and other finished rubber products. RMA members employ over 120,000 workers and account for more than $21 billion in annual sales. All RMA press releases are available at www.rma.org.