The Rubber Manufacturers Association (RMA), Washington, D.C., says 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.”
After decades of the EPA having sanctioned scrap tires for use as a supplemental industrial fuel, the agency is now proposing 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,” according to RMA.
“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,” says the RMA in a news release. “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,” says the group.
The EPA would still allow processed scrap tires to be used as fuel if most of the steel content is removed. But this would add costs to TDF use at facilities such as cement kilns and increase the amount of energy needed and air pollutants emitted to supply TDF to these facilities, says the RMA. Steel content in tires does not affect overall emissions when consumed as TDF, according to the RMA, which says the steel is simply 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,” says 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.”
The RMA calls scrap tire management “an environmental success story in the U.S.” In 1990, the groups says, more than 1 billion tires were stockpiled across the country while only 11 percent of annually generated scrap tires were re-used. Now, fewer than 100 million tires remain stockpiled, and nearly 90 percent of newly generated scrap tires are re-used. 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, according to the RMA.
In comments filed with the EPA, the RMA says the agency does not have the legal authority to declare TDF a solid waste instead of a fuel. TDF has a long history as a fuel, which has been recognized by EPA.
“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 states.
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 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.
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