11.1.nited 95tates ~cnatc 

WASHINGTON, DC 20510 

December 15, 2010 

The Honorable Lisa P. Jackson 

Administrator 

U.S . Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Dear Administrator Jackson : 

We are writing to ask for clarification regarding the June 4, 2010 proposed rule by 

the Environmental Protection Agency (EPA) entitled the "Identification of NonHazardous Secondary Materials That Are Solid Waste." 

Electric generating facilities in Michigan and Ohio have recently installed new 

technology to allow the direct conversion of whole tires into gaseous fuel . This 

technology, also called tire fractionation, importantly removes metals from the tires, 

which are collected for reuse. The reuse of tires reduces the amount of coal needed to 

generate electricity and also reduces emissions such as S02 and NO,. 

We have enclosed correspondence from David Northrop, Attorney for Symbiotic 

Energy, Inc. that has developed the tire fractionation technology, which we ask you to 

consider as you finalize the rule . We also ask if you plan to address this technology in 

your final rule . Thank you. 
David E. Northrop 

Of Counsel 

dnorthrop(Mporterwright .com 

Porter Wright 

Morris & Arthur LLP 

41 South High Street 

Suites 2800-3200 

Col,umbus, Ohio 43215-8194 

Direct: 814-227-2072 

Fax: 614-227-2100 

Toll free : 800-633-2794 

www.porterwrlght.com 

porter wright 

CINCINNATI 

CLEVELAND 

COLUMBUS 

DAYTON 

NAPLES 

WASHINGTON, DC 

December 1, 2010 

VIA E-MAIL AND REGULAR MAIL 

Mr. George Faison 

Program Implementation and Information Division 

Office of Resource Conservation and Recovery, 5303P 

United States EPA 

Ariel Rios Building 

1200 Pennsylvania Ave., NW 

Washington, DC 20460-0002 

RE: Rules for the Identification of Non-Hazardous 

Secondary Materials that are Solid Waste---Tire 

Fractionation (Symbiotic Energy) 

Dear Mr. Faison; 

I represent Symbiotic Energy Inc., which has developed a process for 

the direct conversion of used tires to gaseous supplemental boiler fuel without 

combustion. I spoke with you briefly by telephone on November 19, 2010, to 

express Symbiotic's concern that the preamble to the proposed solid waste 

identification rules (75 Fed. Reg . 31843, June 4, 2010) does not with 

sufficient clarity provide that gaseous fuel produced through tire fractionation 

qualifies as processed material that is not solid waste. I am writing to further 

explain that concern, and propose language for your consideration for 

inclusion in the preamble to the final rule . 

Tire fractionation is described in detail in Symbiotic Energy's 

comments on the proposed rule, submitted on August 2, 2010 (copy 

enclosed). I have also enclosed a "white paper" describing the process and 

its many environmental benefits . In short, the process involves the installation 

of a vertical column on a utility coal-fired boiler . Heated off-gasses from the 

boiler are directed 'into the bottom of the cylinder while whole used tires are 

lowered into it near the top of the column. The heat directly converts 

(vaporizes) the tires into gaseous fuel without combustion. The gas is then 

directed into the boiler as a supplemental fuel. The gas is both less expensive 

per Btu and contains fewer contaminants than coal, and serves to displace a 

significant portion of coal to fuel the boiler. Also, in Ohio, and perhaps 

elsewhere, the tire fractionation fuel qualifies as a "renewable energy" for 

purpose of meeting requirements for diversifying the sources of energy for 

generating electricity . Tire fractionation is a beneficial process in producing a 

desirable, renewable fuel and providing a means of safe disposal of large 

quantities of used tires . 

Tire fractionation is a proven and existing technology. A 

demonstration fractionation unit was prototyped at Dayton Power & Light's 

O.H. Hutchings Station in Ohio, and a full-scale unit is nearing completion of 

installation at a generating plant operated by the Michigan South Central 

Power Agency. I have enclosed photographs of that installation . 
Mr. George Faison 

December 1, 2010 

Page 2 

We believe that tire fractionation meets that definition of "processing" in the proposed rules. 

However, there is no mention in the preamble to the proposed rules of tire fractionation by name or the 

process of directly converting whole tires to gaseous fuel as meeting the definition of "processing" . The 

discussion of used tires beginning at 75 Fed. Reg. 31877 discusses mechanical shredding of tires and 

removal of metal belts as qualifying as "processing", but does not discuss fractionation . Also, the 

discussion of "syngas" at 75 Fed . Reg . 31878, including references to reactors and gas polishing to 

remove contaminants, is close, but not quite on point. As noted, tire fractionation fuel needs no polishing 

prior to introduction into coal-fired boilers, since its contaminant concentrations are lower than coal and 

easily controlled by the boilers' air contaminant control equipment. 

Accordingly, we request that the preamble to the final rule make specific reference to tire 

fractionation or, alternatively, direct conversion of used tires to gaseous boiler fuel, so that utility 

generation station operators have a clear indication from EPA that tire fractionation fuel meets the 

definition of processing and is not solid waste. Failure to include such a reference may cause utilities to 

erroneously conclude that tire fractionation gas is regulated as solid waste, or have sufficient uncertainty 

on that point to cause them to decline to use this beneficial process to avoid stringent regulation as a 

solid waste combustion unit. I have enclosed a long and short form of suggested language for your 

consideration . 

I would greatly appreciate an opportunity to discuss this with you further, and will call you soon to 

discuss this . Please contact me if you have any questions about this process or if I can provide additional 

information . 

Thank you for your assistance on this . 

Yours truly, 

ezLz ~, 

David E. Northrop 

Attorney for Symbiotic Energy, Inc. 

DEN:clk 

COLUMBUS/1 585853v .1 
~y~it' ~~'" / 

Symbiotic Energy 

August 2, 2010 

3508 Wilmington Pike 

Dayton, Ohio 45429-4841 

1-937-859-8998 

Delivered Via FedEx 859806252614 

U.S . EPA West - Docket 28221T Also delivered electronically : 

1301 Constitution Ave., NW http .//www.rcra-docket(cr~epa .gov 

Washington, DC 20460 

Comments on: Notice of Proposed Rulemaking - Identification of Non-Hazardous 

Secondary Materials That Are Solid Waste - Docket EPA-HQ-RCRA2008-0329 

Dear Ms. Jackson, 

EPA is proposing a definition of non-hazardous solid waste that would be used to identify 

whether non-hazardous secondary materials burned as fuels or used as ingredients in combustion 

units are solid waste. EPA is also proposing that non-hazardous secondary materials that have 

been discarded, and are therefore solid wastes, may be rendered products after they have been 

processed (altered chemically or physically) into a fuel or ingredient product. These rules will 

directly affect Symbiotic Energy, LLC. The enclosure with this letter provides comments and 

makes suggestions and recommendations on the proposed rules. As instructed in the Notice of 

Proposed Rule Making, we are submitting two copies of this letter . 

Thank you for the opportunity to comment on these important matters. If there are any 

questions, please contact: 

Mr. Robert L. Kohnen, P.E. 

Vice President 

Symbiotic Energy, LLC 

3508 Wilmington Pike 

Dayton, Ohio 45429 (937) 859-8998 x 2 rkohnen@symbiotic-energy .com 

Sincerely, 

< I ~- 

Robert L. Kohnen, P.E., Vice President 

Symbiotic Energy, LLC 

Enclosures : Duplicate copy of this letter 

Comments and Recommendations Concerning EPA's Notice of Proposed 

Rulemaking - Identification of Non-Hazardous Secondary Materials That Are 

Solid Waste - Docket EPA-HQ-RCRA-2008-0329 
Comments and Recommendations Concerning EPA's 

Notice of Proposed Rulemaking - 

Identification of Non-Hazardous Secondary Materials That Are Solid Waste 

Docket EPA-HQ-RCRA-2008-0329 

Submitted by 

Symbiotic Energy, LLC 

3508 Wilmington Pike 

Dayton, Ohio 45429 

Symbiotic Energy, LLC supports EPA's proposal, described at 75 Fed. 

Reg. 31849, to facilitate materials management through the establishment of a regulatory 

framework that guides the beneficial use of energy-containing secondary materials, while 

ensuring that such use is protective of human health and the environment. Symbiotic 

Energy supports EPA's stated policy objectives of sustainable materials management, 

resource conservation, and improved industrial efficiency . Symbiotic Energy 

respectfully recommends that EPA's June 4, 2010 proposed interpretations of the 

definition of "solid waste" be improved with respect to facilitating the conservation and 

recovery of the fuel value and steel from tires, as set forth below, to better effectuate the 

purposes of RCRA and the Agency's stated intentions and policy preferences. 

Symbiotic Energy, LLC has pioneered an innovative, proprietary technology for 

fractionation of manufactured tires, to recover and beneficially utilize the energy and 

steel content of tires in lieu of discarding these valuable resources, with the co-benefit of 

contributing to reductions in greenhouse gas (GHG) and other air pollutant emissions . 

The process itself has zero emissions, and delivers all of the combustible volatiles and 

fixed carbon content of the tires as a gasified fuel to an adjacent host coal-fired boiler . 

Tire fractionation technology does not involve shredding or burning tires, but rather 

converts whole tires directly into a clean gaseous fuel while separating steel belts for 

reuse. Symbiotic Energy's tire fractionation technology substitutes tire-derived Btu's for 

coal-derived Btu's, and substitutes reclaimed steel for newly-manufactured steel. This 

resource recovery avoids the energy consumption and negative environmental impacts 

inherent in extracting and processing coal, and in manufacturing steel. It also avoids the 

negative environmental impacts of dumping tires. Symbiotic Energy's tire fractionation 

technology is currently being used to generate supplemental fuel for coal-fired electric 

generating units. 

The tire-derived fuel produced from Symbiotic Energy's tire fractionation process 

has a heat value of approximately 215 Btu per SCF, as fired. This compares favorably 

with the heat value of blast furnace gas 92 Btu per SCF which EPA properly recognizes 

as a legitimate and historical fuel that is not deemed a solid waste (see 75 Fed. Reg. at 

31852) . As practiced by Symbiotic Energy, the tire fractionation system beneficially 

reuses whole tires without the intermediate steps to remove the scrap steel or size the tire . 

The tires are volatilized and all of the energy value of the tires is carried in the carrier gas 
to the burning zone of a boiler where it is combusted. There are no process emissions 

from the fractionation units. The fixed carbon is suspended in the flue gas and fed back 

to the boiler where it is also combusted for its energy value. The fixed carbon has 

properties similar to pet coke and it is a valuable solid fuel . The recovered and recycled 

scrap metal is sold on the open market. Scrap metal is not a hazardous waste. 

Wastewater is not generated. A more detailed description of Symbiotic Energy's tire 

fractionation process is set forth in Attachment A. 

Symbiotic Energy has made a substantial investment of intellectual and financial 

capital to make recovery of tire-derived energy and steel profitable . Symbiotic Energy's 

business model depends on revenues from tipping fees associated with processing and 

managing the tires, the sale of the energy and steel recovered from tires. Symbiotic 

Energy incurs costs to obtain delivered tire feed stocks, primarily from tire dealerships, to 

its tire fractionation locations. Symbiotic Energy's tire fractionation technology is in no 

way tire disposal in the guise of recycling (which would inherently involve costs without 

revenues). 

EPA should define "solid waste" in a manner that recognizes the full useful life 

cycle of the resources (energy potential and steel) in manufactured tires that have not in 

fact been discarded or abandoned. EPA's definition of "solid waste" should encourage 

more sustainable resource management and innovative technologies that more efficiently 

recover energy and materials from tires. The promise of Symbiotic Energy's tire 

fractionation technology and similar advanced technologies will be crushed if EPA 

defines "solid waste" in a manner that has the practical effect of discouraging innovation 

and favoring disposal over resource recovery and reuse. Uncertainty about whether 

energy and steel recovery through fractionation of tires will result in classification of the 

tires as a waste stream, or delay in finalizing a definitive regulatory interpretation, would 

be highly prejudicial, and potentially fatal, to the implementation of Symbiotic Energy's 

tire fractionation technology . 

Symbiotic Energy continues the useful life cycle of tires before they are discarded 

or abandoned. The most helpful way EPA should facilitate beneficial recovery and reuse 

of the energy and steel contained in tires is to interpret "discarded material" in the RCRA 

definition of "solid waste" (42 U.S .C. section 6903(27)) to exclude off-spec tires and tires 

obtained from tire dealerships or vehicle service facilities for processing at a tire 

fractionation unit that sells or beneficially uses the fuel value extracted from such tires to 

provide Btu's in an adjacent boiler predominantly fueled by coal or other traditional 

fossil fuel, and also sells or beneficially uses the steel recovered from fractionation of 

such tires. Tires that are fractionated to separate the steel content from the usable fuel 

content, with no combustion of the tires themselves, are not "solid waste" if they are not 

"discarded material." Symbiotic Energy respectfully submits that this interpretation of 

"discarded material" is factually accurate, reasonable, and consistent with RCRA's 

statutory purpose, especially the Congressional goals of recovery and conservation of 

usable materials (see, e.g ., 42 U.S .C. section 6901(c)) . Indeed, the name of the statute is 

"Resource Conservation and Recovery," which is exactly what Symbiotic Energy's tire 

fractionation technology does. 
The final rules must clearly indicate that whole tires that have been gathered and 

transported to a facility which beneficially uses them in energy and/or material recovery 

processes are not solid waste. EPA should facilitate beneficial recovery and reuse of the 

energy and steel contained in tires by interpreting "discarded material" in the RCRA 

definition of "solid waste" (42 U.S .C. section 6903(27)) to exclude tires obtained from 

tire dealerships or vehicle service facilities that : 1) send the tires to a fractionation unit 

that delivers the fuel value extracted from such tires to a boiler that is predominantly 

fueled by coal or other traditional fossil fuels; and 2) the material/energy recovery facility 

sells or beneficially uses the steel recovered from fractionation of such tires. 

The ability to process and beneficially recover all of the fuel and steel value in 

whole tires is the essence of the fractionation process used by Symbiotic Energy, LLC. 

To the extent that self-implementing legitimacy criteria are needed for Symbiotic 

Energy's tire fractionation technology, they should be as clear, certain, and reasonable as 

possible. As an alternative or a supplement to the more straightforward exclusions from 

the definition of "solid waste" recommended above, Symbiotic Energy suggests the 

following legitimacy criteria for process like tire fractionation that recovers both the 

energy and steel content of tires: 

The energy and material recovery processor manages the used tires as a 

valuable commodity by maintaining an inventory management system that 

accounts for the value and quantity of materials received, stored, and 

processed). 

The energy and material recovery processor maintains insurance or other 

financial resources to properly and lawfully manage its inventory of 

unprocessed tires in the event the energy and material recovery facility 

ceases operation. 

" There is contract(s) between the energy/material recovery facility that is 

receiving the tires for beneficial reuse and the owner(s) of the used tires. 

" There are specifications that establish limitations on the type of tires that 

can be received at the energy/material recovery facility . 

" There are documents (e .g ., shipping manifest or bill of lading) indicating 

the quantity of tires being transported from the owner of the tires to the 

energy and/or material recovery facility . 

" There are inspection and characterization procedures with recordkeeping 

that is capable of demonstrating that only "on specification" materials 

have been received at the energy/material recovery facility. 

The energy and material recovery processor maintains records 

demonstrating that the heat content of the used tire has been beneficially 
used to reduce the quantity of traditional fuels and the recovered steel is 

beneficially used. 

EPA's conclusion that whole used tires (even if only collected from tire 

dealerships, automotive shops, and tire manufacturers that are overseen by a state tire 

collection program) have been abandoned and thus meet the meaning of discard causes 

an absurd result that in our opinion encourages illegal disposal and is detrimental to a 

sustainable environment. Using the Agency's stated rationale, one would differentiate 

between whole used tires and those that that have been shredded or chipped and had the 

steel belts removed. The tire fractionation system, as practiced by Symbiotic Energy, 

beneficially reuses whole tires without the intermediate steps to remove the scrap steel or 

to resize the tire . The tires are volatilized and all of the energy value of the tires is carried 

in the carrier gas to the burning zone of a boiler where it is combusted. There are no 

process emissions from the fractionation units. The fixed carbon is suspended in the flue 

gas and fed back to the boiler where it is also combusted for its energy value. The fixed 

carbon has properties similar to pet coke and it is a valuable solid fuel . The recovered 

and recycled scrap metal is sold on the open market . Scrap metal is not a hazardous 

waste. Wastewater is not generated. 

Symbiotic Energy believes that used tires that have been received by an 

energy/material recovery facility that satisfies the legitimacy criteria are not solid waste 

and the combustion units that use tire-derived fuels should not be subject to the Clean Air 

Act Section 129 Commercial Solid Waste Incinerator rules. 

EPA requested comment on whether the term "reasonable time" should be 

defined specifically or within a range of time frames with respect to how long nonhazardous materials may be stored before speculative accumulation occurs and that the 

material is no longer being managed as a valuable commodity. Symbiotic Energy 

believes that a time frame should be established. We recommend that no more than 180 

days of inventory using the design process rate be stored at any given time and no more 

than 49 percent of the inventory be in storage for more than 2 years . These time frames 

allow the energy/material recovery facility a reasonable amount of time to establish, buy, 

and sell arrangements . 

In regard to EPA's request for comments on the list of contaminants that would be 

used for fuel comparisons. Symbiotic Energy believes that routine testing using the 

Appendix Viii listing is impracticable and unnecessary. Appendix Viii lists over 350 

distinct elements and chemical compounds, most of which are not present in tires or any 

other material. The number of analytical methods and the sophistication of the laboratory 

required to perform these analyses is beyond that which can be placed at a typical 

energy/material reclamation facility. We believe that the reasonable application of 

testing data from published literature should be sufficient . If contaminant testing is 

required ; it should be limited to those chemicals that are known to be or reasonably 

suspected of being present in both the used tire and the comparable natural fuel . 
EPA also requests comments on whether it would be more appropriate to 

establish, in lieu of specific contaminant levels that non-hazardous secondary materials 

would have to meet, bright-line levels of various contaminants in traditional fuels or a 

single set of contaminant levels that would apply regardless of the type of traditional fuel 

that is burned. Symbiotic Energy believes that the characteristics of the fuel, combustion 

system process controls and the performance efficiency of the air pollution control 

equipment determine the emission profile. The acceptable emission limits are 

accomplished via air permitting for the combustion source and not solely by the fuel 

characteristics. Symbiotic Energy recommends that the Agency establish reasonable 

bright-line levels of the chemicals of concern regardless of the type of traditional fuel 

being burned . 

EPA requested comments on whether the Agency should quantitatively define 

how much of the non-hazardous material must be consumed or processed to provide a 

useful contribution . The market place will determine if an alternative energy (fuel) or 

material (ingredient) is useful . It is hard to imagine that EPA could establish a 

percentage that is reasonable, defensible, and credible for the broad spectrum of materials 

that are being reclaimed and reused. 

The definition of processing provided in the notice is not sufficiently clear to 

expect consistent self implementation . The definition indicates that operations that only 

modify the size of the material by shredding is not adequate processing, but it goes on to 

say that processing that includes sizing or drying in combination with other operations is 

sufficient processing to change a secondary material from that of being a solid waste to 

that of being a product. The rule does not explain the difference between shredding and 

sizing, nor does it define or illustrate what other operations are or might be. Additionally, 

the definition includes the terms "significantly improves the fuel characteristics" and 

"chemically improves the as fired energy content" and "improves the ingredient 

characteristics" without providing metrics that can be used to benchmark and quantify 

these qualitative terms. Symbiotic Energy suggests that the Agency use the legitimacy 

criteria referenced above as the only criteria for determining whether a used tire is a solid 

waste or not. The term processing should not require the removal of metal belts or wire 

as a condition of the tire being beneficially used as a non-solid-waste fuel or ingredient . 

Used tires that have been transported to an energy/material recovery facility that meets 

the legitimacy criteria are indistinguishable from used tires that were not discarded, 

abandoned, or otherwise disposed. The legitimacy criteria described above will ensure 

that the used tires are properly managed and not abandoned again. 
Appendix A 

The following is a brief description of Symbiotic Energy's Tire Fractionation 

System. 

Tire fractionation is an innovative technology that does not involve shredding or 

burning tires, and it has many environmental benefits. Tire fractionation technology 

converts tires directly into a clean gaseous high-Btu fuel, and it also recovers the highquality steel belts for reuse. Tire-derived clean gas fuel is as renewable and sustainable 

as the tire replacement cycle. Tire fractionation is a closed-loop system that generates 

zero emissions. All of the tire components are recovered either as a gaseous fuel or as 

recycled steel. The process involves the controlled exposure of tires to heat that converts 

the non-metallic portion of the tires to combustible gas containing fixed carbon particles . 

As an energy source, tires have a good potential compared to some other fuel 

sources. The most important thing to note is that tires have a higher heating fuel value of 

approximately 12,000 to 16,000 Btu per pound of tire as compared to 12,000 Btu per 

pound of coal and just 5,000 Btu per pound of wood. The steel content of a tire is 

approximately 15 % by weight . Hence, for a system processing 4,000,000 tires per year, 

approximately 6000 tons of steel is recovered and recycled by the iron and steel industry. 

The technology is presently being used to generate supplemental fuel for coalfired boilers at electric generation stations . Fractionated tire fuel also helps in reducing 

air contaminant emissions. When used as a supplemental fuel in a coal-fired boiler, 

fractionated tire fuel displaces a portion of the coal that otherwise would have been 

burned in the boiler. Fractionated tire fuel creates significantly lower pollutant emission 

profiles, when compared to coal. The lower emission profile, including carbon dioxide, 

sulfur dioxide, nitrogen oxides, and particulate matter, overall pollutant emissions from 

the boiler are reduced. Another advantage is that the reduced volume of coal burned in a 

boiler using fractionated tire fuel also reduces the amount of coal ash that must be 

managed in ash lagoons or disposed of in ash landfills, thereby extending the useful life 

of those facilities, requiring fewer new lagoons and landfills to be created, and reducing 

the hazard of coal ash spills. 

Whole scrap tires are delivered to the site by truck, rail, or barge depending on the 

availability and economics of the transportation network. The shipment is weighed, 

sorted, and inspected upon arrival. Arriving tires are stored in enclosed trailers or 

buildings. The tires are removed from storage and fed to the inclined conveyor at a feed 

rate of 600 tires per hour or approximately 12,000 pounds per hour. The fractionation 

column is a vertical cylindrical tower that is approximately 120 feet tall, and as depicted 

in Figure 1 the column is installed adjacent to the boiler . A slip stream of hot (750 to 850 

°F) boiler flue gas is directed to the base of the column as it rises through the column. As 

depicted in Figure 2, whole tires are suspended on a vertical conveyer system and 

lowered through the column. The hot boiler gas stream flow is countercurrent to the 

descending tires within the enclosed tower. The column operates at sub-stoichiometric 
oxygen levels, causing the tires to distill off the volatiles or gasify rather than burn. By 

the time a tire reaches the base of the column, the heat has converted the non-metallic 

portion of the tire to a volatile gas and fine carbon particles that are high in Btu content. 

The gas is capable of self-sustained fire and has a Btu value of approximately 215 Btu per 

cubic foot of gas. The metallic belts in the tire are not combusted or converted to gas, but 

rather accumulate at the bottom of the column where they are later removed for 

recycling. 
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Figure 2. Tire Fractionation Column 
Symbiotic Energy 

Fractionated Tire Fuel: Renewable Ener y Plus Resource Reuse 

Tire Fractionation Converts Whole Tires To Clean Fuel Without Burning The Tires. 

Tires are a fixture in our transportation infrastructure that have a predictable and reliable 

wear and replacement cycle. A large number of tires are replaced each year (on average, one per 

person in the U.S .), and that is likely to remain so for the foreseeable future . Absent proper 

management, used tires can create significant environmental, health, and safety problems. 

However, used tires can be reclaimed in the form of valuable energy and reusable steel in a 

sustainable and very competitive economic model. 

Combustion of tires to recover energy has been met with wide-spread opposition due to 

air pollution concerns, and fails to fully reuse tire resources. Tire fractionation is an innovative 

technology that does not involve shredding or burning tires and that has many environmental 

benefits . Tire fractionation technology converts tires directly into a clean gas fuel, and also 

recovers the high-quality steel belts for reuse. Tire-derived clean gas fuel is as renewable and 

sustainable as the tire replacement cycle. 

What Is Tire Fractionation Technology? 

Tire fractionation is a closed loop system that generates zero emissions. No combustion 

occurs in the process. All of the tire components are recovered either as a clean fuel or as 

recycled steel. The process involves the controlled exposure of tires to heat that converts the 

non-metallic portion of the tires to gaseous fuel and carbon particles. The technology is 

presently being used to generate supplemental fuel for coal-fired boilers at electric generation 

stations . As depicted in the attached conceptual diagram, a vertical column is installed adjacent 

to the boiler . A slip of surplus reheat cycle steam from the boiler is directed to the base of the 

column and rises through the column. Whole tires are suspended on a vertical conveyer system 

and lowered through the column. By the time a tire reaches the base of the column, the heat has 

converted all of the non-metallic portion of the tire to a gas and fine carbon particles. The gas 

has a sufficient energy value to serve as a fuel, and is conveyed to the boiler for combustion. 

The metallic belts in the tire are not combusted or converted to gas, but rather accumulate at the 

bottom of the column and are later removed for recycling. 

Tire Fractionation Has Many Environmental Benefits 

Management of tires as waste creates many environmental problems. Tires stored or 

discarded on the surface of the ground are ugly, do not decompose, and present the hazards of 

uncontrolled fires and the breeding of mosquitoes . Disposal of tires in landfills is little better, 

consuming valuable landfill capacity that is better devoted to putrescible waste that is not 

suitable for energy-recovery or recycling. By removing tires from waste streams, these serious 

environmental consequences are avoided. 
Fractionation also avoids the problems presented by burning tires for disposal or energy 

recovery . When burned, tires produce undesirable emissions that are difficult to control with 

current air pollution control technology . As a result, tire-burning incinerators and use of 

shredded tires as boiler fuel have met with significant public opposition. Fractionation, by 

converting the tires directly to a gas without burning the tires, avoids these significant problems, 

and produces zero emissions. 

Fractionation also allows for recovery and reuse of the high-quality steel used in the steel 

belts, thus reducing the economic demand for the mining of iron ore and production of new steel, 

with attendant adverse environmental impacts. 

Fractionated tire fuel also helps in reducing air contaminant emissions. When used as a 

supplemental fuel in a coal-fired boiler, fractionated tire fuel displaces a portion of the coal that 

otherwise would have been burned in the boiler. Because fractionated tire fuel creates 

significantly lower pollutant emissions per Btu than coal, including carbon dioxide, sulfur 

dioxide, nitrogen oxides, and particulate matter, overall pollutant emissions from the boiler are 

reduced. 

The reduced volume of coal burned in a boiler using fractionated tire fuel also reduces 

the amount of coal ash that must be managed in ash lagoons or disposed of in ash landfills, 

thereby extending the useful life of those facilities, requiring fewer new lagoons and landfills to 

be created, and reducing the hazard of coal ash spills . 

Fractionated Tire Fuel Is A Renewable Form Of Energy 

That Is An Alternative To The Burning Of Fossil Fuels 

The national commitment to developing renewable alternatives to the nation's 

dependence upon fossil fossils is growing and evolving . Congress has enacted a series of 

financial incentives for the development of renewable energy technologies in the Energy Policy 

Act of 2005 and the American Recovery and Reinvestment Act of 2009. The "American Clean 

Energy and Security Act" (the Waxman-Markey bill), passed by the House in June 2009, and the 

"Clean Energy, Jobs, and American Power Act" (the Kerry-Boxer bill) introduced in the Senate 

in September 2009, would, among other things, create the first-ever national renewable energy 

mandates for retail electric suppliers. Twenty-four states have mandatory renewable portfolio 

requirements in effect . 

The definition of what qualifies as "renewable energy" varies from state to state and 

among existing and proposed federal programs. As legislators consider new or revised 

definitions of renewable energy, care should be taken to avoid an unduly narrow definition of 

renewable energy so as not to stifle the development of a diverse menu of competitive and 

innovative renewable energy technologies . The public interest and good public policy are best 

served by a diversity of sustainable green energy technology options. Diversification enables 

market forces to stimulate dynamic improvement in the cost and quality of renewable energy 

technologies . Renewable energy diversification will also bring about new technologies sooner, 

and will encourage a mix of technologies tailored to specific needs and circumstances. 

Fractionated tire fuel is a an excellent example of the type of energy that should qualify 

to meet mandates for the development and use of renewable alternative energy. As an example, 
Ohio has recently adopted legislation that expressly includes fractionated tire fuel in its 

definition of renewable energy that electric utilities may use to meet the alternative energy 

portfolio requirements . Renewable energy is defined at Section 4928.01(A)(35) of the Ohio 

Revised Code to include "fuel derived from solid wastes, as defined in section 3734.01 of the 

Revised Code [that includes scrap tires], through fractionation . . . or other process that does not 

principally involve combustion . . . . . . Language defining renewable or alternative energy that 

includes fractionated tire fuel should be included in legislation at the federal level and in other 

states, given the sustainability and environmental benefits of the fuel 

Conclusion 

Fractionated tire fuel has many advantages as a supplemental boiler fuel . It is an 

excellent use of a waste product that otherwise presents many environmental problems, and can 

result in reduced emissions from utility boilers. It is an source of energy that is cleaner than coal 

and does not involve combustion of fossil fuels, thereby contributing to energy diversity and 

reduced emission of greenhouse gases.