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 to Sponsor 3rd Conference on Ground Rubber Recycling

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

WASHINGTON, D.C.February 9, 2009 - The Rubber Manufacturers Association (RMA), Clemson University Asphalt Rubber Technology Service, the Rubber Association of Canada and Empire State Development will sponsor “Scrap to Profit 3” — Using Ground Rubber in Rubber and Plastic Products on June, 3-4, at the Hyatt in Buffalo, New York. The conference theme is “Learn, Network, Share and Promote.”

“We are very pleased to continue the effort of advancing higher-valued added markets and building upon the success of the last two conferences,” said Michael Blumenthal, RMA vice president. “At this conference we are expanding the products to be discussed, and will have in-depth panels and discussions on playgrounds, infill and mulch, three of the faster growing markets in our industry. These markets have come under considerable pressure in the marketplace and this event will provide a suitable venue where the industry can discuss these matters,” Blumenthal added.

The “Scrap to Profit 3” conference will have presentations on each of four major ground rubber markets plus an update on the Ontario scrap tire program. Topics to be discussed include:

  • Addressing the Health Impact Concerns
  • Marketing to Mass Merchandisers
  • Quality Assurance for Mulch
  • Market Issues for Playground Cover
  • ASTM Standards for Playground Cover
  • Quality Issues for Loose fill Playground
  • Market Issues for Infill Material
  • Standards for Infill Material
  • Tire Supply Issues
  • Compounding Recycled Rubber
  • Equipment for Molding and Extruding Rubber
  • 3 Case Studies
  • Update on the Ontario Tire Stewardship plan

A website has been created to obtain more information and to register:www.scraptoprofit.com

The STP3 will be held in conjunction with the first annual New York State Tire Derived Aggregate Workshop sponsored by Empire State Development and the Center for Integrated Waste Management – University at Buffalo. The NYS TDA Workshop will be held on Tuesday, June 2, 2009, also at the Hyatt. Program and registration information for the NYS TDA Workshop can be obtained at:www.tdanys.buffalo.edu.

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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. All RMA press releases are available at www.rma.org.

Pennsylvania Scrap Tire Pile Cleanup a Significant Step Forward

RMA Urges State to Continue Successful Effort by Dedicating Cleanup Funds

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

WASHINGTON, D.C.November 13, 2007 - Tire manufacturers hailed the recent announcement that a major Pennsylvania scrap tire stockpile would soon be cleaned up and urged state policymakers to build upon that progress by dedicating funds to remediate remaining scrap tire piles.

The Pennsylvania Department of Environmental Protection (DEP) said recently that the state’s largest scrap tire stockpile, the Max and Martha Starr site in Columbia County, would be cleaned up by June 2008.

“While more work remains, the Starr pile success represents an opportunity for the state to build on its momentum,” said Chris Gullott, RMA vice president, state government affairs. “A dedicated source of funding for stockpile abatement would help ensure that the DEP has the resources necessary to continue clean up efforts.”

Legislation introduced by Sen. Lisa Baker (R-Dallas), S.B. 1050, would direct $3 million per year over five years to scrap tire abatement. Pennsylvania still has millions of stockpiled scrap tires.

Sen. Baker’s legislation has broad bipartisan support including Senate Environmental Resources and Energy Chair Mary Jo White (R), Senate Democratic Minority Leader Robert Mellow (D), and Sen. John Gordner (R). Sen. Gordner is a longtime champion of scrap tire issues and was instrumental in pushing for the cleanup of the Starr pile, which is located in his district.

“With Starr nearly complete, we encourage the General Assembly and Governor Rendell to support dedicated resources for scrap tire cleanup,” Gullott said. “A concerted effort could render Pennsylvania’s scrap tire stockpiles a thing of the past.”

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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 members employ over 120,000 workers and account for more than $21 billion in annual sales.

Proposal to Hike Tennessee Tire Fee Draws Industry Concern

RMA Says “Significant Review” Needed of TN Scrap Tire Program

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

WASHINGTON, D.C.January 11, 2007 - A proposal under consideration by Tennessee’s Solid Waste Advisory Committee (SWAC) that includes increased consumer fees on new tire purchases should include a significant review of the limitations of the state’s scrap tire program, according to a tire industry organization.

The Rubber Manufacturers Association said in a letter to state officials that Tennessee’s program, funding, and markets for scrap tires remain insufficient.

SWAC is considering an increase and expansion of the state’s tire fee by increasing the fee on new passenger and light truck tires from $1.00 per tire to $1.25 per tire, increasing the fee on large truck tires from $1.00 per tire to $5.00 per tire, and initiating a $1.25 fee per tire on all new car sales.

Preliminary estimates of the proposed fee expansion indicate a potential increase in tire revenues from $4.1 million to $6.2 million per year. RMA has urged SWAC to provide greater detail regarding the additional funds needed and how those funds may be allocated.

Consumer fees on new tires are used in many states to fund cleanup, enforcement and market development activities for scrap tires. Some states have diverted tire fee revenues to other purposes, which RMA says endangers scrap tire programs.

RMA said that increased revenues for Tennessee’s scrap tire program should stem from a review of the current program’s inefficiencies. “We believe that the current structure of the scrap tire program remains an inherent challenge to the efficient use of tire fee revenues,” says Christian Gullott, RMA director, government affairs.

According to RMA, Tennessee’s program costs, particularly for transportation of scrap tires, exceed other state programs. “Tennessee’s current fees do not meet the financial needs of the counties to administer their scrap tire programs,” Gullott wrote. He explained that counties are using the total amount of their funds to fund tire disposal, and therefore state funds are largely unavailable for enforcement activity, pile abatement, or market development.

“State scrap tire programs should be focused on the development and stimulation of sustainable markets for scrap tires. This must be both a central goal and a key component of any viable program,” explained Gullott. RMA has long known that developing efficient and self sustaining markets for scrap tires is the best management practice over the long term.”

According to RMA’s 2005 Scrap Tire Report Tennessee generates 5.9 millions tires annually with 72 percent of scrap tires sent to market. Overall, 290 million scrap tires are generated annually in the U.S. and nearly 87 percent are put to new uses in other markets such as fuel, civil engineering or used to make new products.

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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.