 |
| Whole tyres are often used as fuel in Cement plants such as Medusa Cement plant pictured above Credit: TMI Systems |
The Rubber Manufacturers Association (RMA) has expressed its anger over U.S. Environmental Protection Agency (EPA) proposals.
After decades of use as an EPA-sanctioned, supplemental industrial fuel, the EPA is now proposing to declare whole scrap tyres a solid waste. The new designation would require facilities using whole Tyre Derived Fuel (TDF) to add costly new emission controls that would not be required to burn traditional, less efficient fuels, claim the RMA.
Instead of this option, many TDF users will likely opt to stop using it as a fuel in favour of more costly, less efficient and more polluting fossil fuels, including coal.
The RMA believes that this 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.
The EPA will still allow the use of processed scrap tyres to be used as fuel, but only if most of the steel content is removed. This 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 tyres does not affect overall emissions when consumed as TDF. Instead, the steel is used as a raw material in the manufacture of cement.
“The EPA’s proposed regulatory scheme would devastate the tyre-derived fuel market in the U.S. which will ripple across the entire scrap tyre market infrastructure,” said Tracey Norberg, RMA senior vice president. “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 is an environmental success story in the U.S. In 1990, more than one billion tyres were stockpiled across the country while only 11% of annually generated scrap tyres were reused. Today, fewer than 100 million tyres remain stockpiled and nearly 90% of annually generated scrap tyres are reused. Each year, about 300 million scrap tyres are generated in the U.S. Of those, about 52% are used as TDF in the cement industry, pulp and paper mills and by some utility and industrial boilers.
Commenting on the proposal, the RMA said that the 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 but also results in comparable or even lower emissions than coal combustion.
“The 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 said.
More tyre 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 tyres can cause considerable environmental harm. Such fires can burn for days or weeks. Stockpiled tyres 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 tyres have been discarded, which would allow states to continue to regulate those scrap tyres 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 tyres to be continue to be used as a fuel but stockpiled scrap tyres 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.
