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

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.

Tire Industry Report Rankes States on Scrap Tire Progress

More Tires Put to New Uses; Stockpiled Scrap Tires Down 80% Since 1990

For more information contact:
Dan Zielinski
(202) 682-4846

WASHINGTON, D.C.December 5, 2006 – State cleanup laws and growing markets are helping to alleviate a serious environmental issue – scrap tires. According to a report by the Rubber Manufacturers Association, nearly 87 percent of disposed tires each year are put to a new use. In 1990, only 11 percent of scrap tires was consumed by a market.

Additionally, the number of tires sitting in stockpiles shrunk to 188 million from 275 million in 2003. More than 1 billion scrap tires were stockpiled in 1990.

RMA, which represents tire manufacturers, ranked states by their overall performance in dealing with scrap tire issues and how states improved since the previous scrap tire report in 2003.

South Carolina, North Carolina and Maine lead the nation in a performance ranking of dealing with scrap tires. Rankings are based on percent of tires going to end use markets, number of stockpiled tires, stockpiled tires per capita, number of tires land-disposed and the percent of the number of tires/per capita land-disposed in 2005.

Texas, Alabama, Michigan and Ohio were tops in improving the scrap tire situation in 2005 as compared to 2003.

“Tire manufacturers have been working hard for 16 years to promote environmentally and economically sound solutions to reduce scrap tire waste,” said Michael Blumenthal, RMA senior technical director. “Additionally, states’ scrap tire cleanup laws and regulations and market development efforts have substantially reduced the nation’s scrap tire piles.”

RMA’s report, based upon a comprehensive survey of state scrap tire and solid waste officials and industry participants, says that 259 million of 299 million scrap tires generated in 2005 went to an end use market.

The largest markets for scrap tires include:

  • Ground rubber — One of the largest markets for scrap tires is ground rubber, which consumed more than 30 million tires in 2005. Ground rubber is used in athletic and recreational surfaces, rubber-modified asphalt, carpet underlay, flooring material, dock bumpers and railroad crossing blocks.
  • Civil engineering — Projects such as road and landfill construction, septic tank leach fields and other construction applications consumed nearly 50 million tires. Tires add positive properties in these applications such as vibration and sound control, lightweight alternatives to prevent erosion and landslides and drainage in leachate systems.
  • Tire-derived fuel (TDF) — TDF is the leading use of scrap tires, especially as a supplemental fuel for cement kilns, electric utilities and pulp and paper mills. TDF use has increased almost 20 percent to 155 million scrap tires since 2003.

Since 1990, the number of scrap tires in stockpiles has been reduced by 81 percent. Of the remaining stockpiles, 85 percent are concentrated in 7 states: Alabama, Colorado, Connecticut, Michigan, New York, Pennsylvania and Texas. Alabama and New York have recently begun efforts to cleanup existing stockpiles.

In previous scrap tire market reports, RMA listed information only in millions of tires. This year, RMA added a weight category. Many other industries use weight when calculating reuse or recycling of waste materials. Under this measurement, 82 percent of scrap tires were used in a market application. The slightly smaller percentage is due to the varying sizes of tires which range from typical passenger-size tires weighing about 22.5 pounds to large commercial truck tires that can weigh more than 100 pounds.

The 2005 U.S. Scrap Tire Markets report is the eighth biennial report researched and published by RMA. The report shows the status, progress and challenges of the U.S. scrap tire industry.

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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.