RMA claims EPA scrap tire proposal is anti-environment

The United States 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 United States 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 United States. 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 United States. 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, 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 to 16,000 Btu/lb) but also results in comparable or even lower emissions than coal combustion.

RMA advocated that EPA should consider TDF a 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.