WASHINGTON (Aug. 6, 2010)—The Rubber Manufacturers Association is blasting a proposed rule by the U.S. Environmental Protection Agency that it said would significantly harm the existing infrastructure that manages scrap tires and reverse two decades of environmental cleanup success.
After decades of EPA-sanctioned use as a supplemental industrial fuel, the EPA is proposing now to declare whole scrap tires a solid waste, the RMA said. The new designation would require facilities using whole tire-derived fuel to add costly new emission controls that would not be required to burn traditional, less efficient fuels.
“(The) 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.”
The RMA said many TDF users likely will opt to stop using TDF in favor of more costly and less efficient traditional fossil fuels.
The 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, the association said.
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.
In comments on the proposed rule filed today, the RMA said that the EPA does not have the legal authority to declare TDF as a “solid waste” instead of a fuel. TDF, it said, has a long history as a fuel and the agency's own data indicate 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/pound) but also results in comparable or even lower emissions than coal combustion.
The RMA is advocating that the EPA consider TDF as 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, the association indicated it supported an approach initially outlined by the 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.