EPA Scrap Tyre Proposal – 20 Years of US Environmental Progress up in Smoke?

Responding to a US Environmental Protection Agency (EPA) proposal to declare whole scrap tyres as a solid waste, the Rubber Manufacturers Association (RMA) has declared the potential change in policy a measure that would “significantly harm the existing infrastructure that manages scrap tyres.” The association also believes two decades of environmental cleanup success is at risk of being reversed as a result.

For many years the EPA has sanctioned whole scrap tyres for use as a supplemental solid fuel, and the RMA believes their re-designation as a solid waste will force facilities that wish to continue using whole tyre-derived fuel (TDF) to add costly new emission controls that are not required for other, less efficient fuels. Instead of this, the association believes many TDF users will change over to costlier, less efficient and higher emission fossil fuels such as coal. The RMA states that such as situation “will likely result in a dramatic reduction of TDF use while driving tens of millions of scrap tyres back to landfills, stockpiles and illegal dumping sites.”

A further EPA proposal of concern to the RMA is to permit the use of processed scrap tyres as fuel only if most of their steel content is removed. This would, the association states, increase the cost of using TDF in facilities such as cement kilns and increase the amount of energy required for and air pollutants emitted in their supply.  “Steel content in tyres does not affect overall emissions when consumed as TDF,” comments the RMA in a statement, adding that the steel is used as a raw material in the manufacture of cement.

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

Scrap tyre management, comments the RMA, has been an “environmental success story” in the US: In 1990, more than one billion tyres were stockpiled across the country while only 11 per cent of scrap tyres generated each year were reused.  Today, fewer than 100 million tyres remain stockpiled and nearly 90 per cent of all scrap tyres generated annually are reused.  Each year, about 300 million scrap tyres are generated in the US.  Of those, about 52 per cent are used as TDF in the cement industry, pulp and paper mills and by some utility and industrial boilers.

The RMA believes that the EPA does not have the legal authority to declare TDF a “solid waste” instead of a fuel, and comments that TDF has a long history as a fuel – a history that is recognised by the 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,” reports the RMA statement on its response to the proposed changes.   

“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 tyre industry,” Norberg stated, adding the agency “should reconsider this deeply flawed, anti-environment, anti-business and anti-common sense proposal.” Instead of this proposed measure the RMA advocates the classification of TDF as a ‘historic fuel’, enabling states to continue regulating scrap tyres not used as TDF under state waste management regulations.  Alternatively, the RMA has indicated its support for an approach initially outlined by the EPA in January 2009 that would have allowed annually generated scrap tyres to continue to be used as a fuel while stockpiled scrap tyres would be considered “discarded” and therefore be a solid waste subject to new emission controls if combusted.