Scrap Tire Cleanup 

Guidebook

A Resource for

Solid Waste Managers 

Across the United States

January 2006

U.S. EPA Region 5

Waste, Pesticides and Toxics Division

77 West Jackson Boulevard (DW-8J)

Chicago, Illinois 60604-3590

www.epa.gov/region5

Illinois EPA

Bureau of Land

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, Illinois 62794-9276

www.epa.state.il.us

EPA-905-B-06-001 


This guidebook was conceived during a planning session convened by U.S. Environmental Protection 

Agency Region 5 in February 2004. After consideration of the extensive input obtained during 

and after this session, U.S. EPA Region 5 and the Illinois EPA partnered to create and publish the 

guidebook. U.S. EPA Region 5 would like to specifically thank Mr. Terry Gray of T.A.G. Resource 

Recovery for providing his expertise in preparing this document. The following individuals also made 

significant contributions to the document:

Michael Blumenthal, Rubber Manufacturers Association

Larry Bowerman, U.S. EPA Region 9

Jack Brunner, Tetra Tech EM Inc.

Jan Rae Clark, Florida Department of Environmental Protection

Paul Crissman, North Carolina Department of Environmental and Natural Resources

Craig Detweiler, Entech, Inc.

Toni Duggan, New Mexico Environment Department 

Jeff Edwards, Nebraska Department of Environmental Quality

George Gilbert, Kentucky Department of Environmental Protection

Mike Giuranna, U.S. EPA Region 3

Mark Hope, Tire Disposal & Recovery Inc.

Paul Koziar, Wisconsin Department of Natural Resources

Bob Large, Ohio EPA

Allan Lassiter, Virginia DEQ

Todd Marvel, Illinois EPA

Ethan Mayeu, Mississippi DEQ 

Ken McDaniel, Indiana Department of Environmental Management

Pam Moore, North Carolina Division of Waste Management

Chris Newman, U.S. EPA Region 5 

Hope Pillsbury, U.S. EPA Office of Solid Waste

Mel Pins, Iowa DNR

Dave Quarterson, Liberty Tire Services Inc.

Paul Ruesch, U.S. EPA Region 5

Harry Smail, Ohio EPA

Pamela Swingle, U.S. EPA Region 4

Jim Waldron, Tri-Rinse, Inc.

Anne Weinkauf, Indiana DEM

Rhonda Zimmerman, Michigan DEQ

ACKNOWLEDGEMENTS 
ii

CONTENTS

Section Page

Acknowledgements .................................................................................................................................I

Acronyms and Abbreviations......................................................................................................... Iii

Disclaimers.................................................................................................................................................. Iv

Section 1 - Introduction........................................................................................................................ 1

Section 2 - State Involvement........................................................................................................... 3

Scrap Tire Cleanup Programs And Funding........................................................................................... 3

Regulatory and Permitting Programs....................................................................................................... 5

Enforcement and Cost Recovery Tactics .................................................................................................. 7

Section 3 - Planning............................................................................................................................... 10

Stockpile Identification And Mapping.................................................................................................... 10

Quantity Estimation Techniques.............................................................................................................. 11

Stockpile Prioritization.............................................................................................................................. 15

Markets ........................................................................................................................................................ 18

Property Issues ........................................................................................................................................... 19

Communications ........................................................................................................................................ 20

Section 4 - Contractors ......................................................................................................................... 22

Evaluating Contractor Qualifications...................................................................................................... 22

Bidding and Award Process...................................................................................................................... 24

Contracts ...................................................................................................................................................... 25

Bonding And Insurance............................................................................................................................. 25

Capacity Assessment.................................................................................................................................. 26

Section 5 - Project Management.................................................................................................... 27

Site Survey................................................................................................................................................... 27

Equipment ................................................................................................................................................... 27

Transportation............................................................................................................................................. 28

Environmental Factors............................................................................................................................... 29

Security......................................................................................................................................................... 29

Safety ............................................................................................................................................................ 30

Fire Planning and Prevention................................................................................................................... 31

Communication .......................................................................................................................................... 32

Site Restoration ........................................................................................................................................... 33

Section 6 - Summary.............................................................................................................................. 35

Section 7 - Resources............................................................................................................................. 36

Appendix - Stockpile Characterization Form
iii

ACRONYMS

AND ABBREVIATIONS

CDC Centers for Disease Control and Prevention

DEM Department of Environmental Management

DENR Department of Environment and Natural Resources

DEP Department of Environmental Protection

DEQ Department of Environmental Quality

DNR Department of Natural Resources

DWM Division of Waste Management

DOT U.S. Department of Transportation

EPA Environmental Protection Agency

GIS Geographic information system

GPS Global positioning system

IFB Invitation for bid

IWMB Integrated Waste Management Board

PTE Passenger tire equivalent

RCC Resource Conservation Challenge

RFP Request for proposal

RFQ Request for qualifications

RMA Rubber Manufacturers Association

TDF Tire-derived fuel 

TRA Tire removal agreement
iv

DISCLAIMERS

This guidebook is intended for use as guidance only. The reference or use of any specific policy, 

process, procedure, trade name, commercial product, or equipment does not imply or constitute 

endorsement or recommendation by U.S. EPA or Illinois EPA. This guidebook is a summary of 

information compiled from multiple sources on the topic of scrap tire cleanup, and should be 

considered non-binding information that is open to use and interpretation by the user as they see fit, 

and at their own risk.

Several web links provided in this document are not contained in domains created or maintained by 

U.S. EPA or Illinois EPA. These links simply provide access to additional information in accordance 

with the intended purpose of this document. Neither U.S. EPA nor Illinois EPA can attest to the 

accuracy of information or the privacy protection provided by any external web site. Providing links 

to external web sites does not constitute an endorsement by U.S. EPA, Illinois EPA, or any of their 

employees of the site sponsors or the information or products presented on the sites.
Section 1: Introduction

SECTION 1 Introduction

Despite over 20 years of efforts to address scrap tires, 

large stockpiles continue to be a problem across the 

United States. Based on data compiled by the Rubber 

Manufacturers Association (RMA), it is estimated 

that 275 million tires remained in stockpiles across 

the United States in 2003 and that approximately 290 

million new scrap tires are generated each year. RMA 

also estimates that more than 90 percent of the illegal 

scrap tire accumulation and associated stockpiles are 

concentrated in 11 states. Although some of the states 

have abatement programs in place and are currently 

reducing stockpile inventories, others have yet to 

establish and consistently fund comprehensive waste 

tire management programs involving stockpile abatement.

Large scrap tire stockpiles present a threat 

to human health and the environment 

for several reasons. They provide an 

ideal breeding ground for mosquitoes, 

which can carry and transmit lifethreatening diseases such as dengue fever, 

encephalitis, and the West Nile virus. 

Stockpiles may also catch fire as a result of 

lightning strikes, equipment malfunctions, 

or arson. The longer a stockpile is 

unabated, the more likely it is to catch 

fire. Some experts no longer consider the question of “if” a stockpile will catch fire but “when” it 

will burn. Tire fires typically cause air, surface water, soil, groundwater, and residual contamination 

that has negative impacts on human, animal, and plant life. When ignited, scrap tire piles generate 

dense, black smoke containing partially 

combusted hydrocarbons. The smoke 

plume can negatively impact residences 

and businesses in its path as well as 

the air quality in a broad area for a 

long time. In addition to smoke, some 

tire fires produce large quantities of 

pyrolytic oils containing hazardous 

compounds. Under certain conditions, 

these oils can penetrate porous soils 

to contaminate groundwater that may 

be used as drinking water. The oils 

can also reach surface water and cause 

substantial fish kills, as the oils quickly 

deplete dissolved oxygen levels. Finally, 

the residuals (ash, wire, and unburned 

rubber) from a tire fire often require 

special handling and disposal. 

A dictionary definition of a stockpile is a supply 

of material intended for future use. However, the 

practical reality is that few waste tire stockpiles 

have future use without regulatory and enforcement 

programs. History has shown repeatedly that 

even stockpiles at operating processors have to be 

controlled. Therefore, a stockpile referred to in 

this guidebook is any accumulation of waste tires, 

regardless of intended use.

Photo courtesy of Paul Ruesch, U.S. EPA
Section 1: Introduction 

State, federal, and local agencies have spent 

hundreds of millions of dollars over the past 

several decades in responding to tire fires and as a 

general rule, it is five to ten times more expensive 

to remediate a fire site than to simply remove the 

tires before they catch fire. In addition, stockpiles 

in urban areas are impediments to redevelopment 

of brownfield properties for constructive use and 

for revitalization of economically stressed areas. 

Finally, scrap tire stockpiles encourage open 

dumping of other wastes.

Scrap tire stockpile cleanup has been given 

increased priority by many states and local 

jurisdictions as the threats described above manifest 

themselves over and over. Many state legislatures have established comprehensive programs and 

have committed funds to address the problem. In addition, stockpiles present an opportunity for tire 

recycling, reuse, and energy recovery. In response to requests for federal leadership, the U.S. EPA 

established a group of individuals representing manufacturers, processors, recyclers, and end users 

of tire products as well as state agencies to formulate a strategy for addressing scrap tires. As part of 

the Resource Conservation Challenge (RCC), the group established a goal for mitigation of 55 percent 

of stockpiled scrap tires by 2008. Because state governments have primary authority over scrap tire 

stockpiles, U.S. EPA is working on several projects designed to add value to efforts to mitigate the 

problem (see http://www.epa.gov/region5/solidwaste/tires.htm).

U.S. EPA, in cooperation with several 

states, developed a simple approach 

for conducting an inventory of 

scrap tire stockpiles and developing 

geographic information system (GIS)-

based maps of stockpile locations. The 

maps and associated GIS databases 

of site information, both maintained 

by individual states, will assist in 

establishing a baseline that can be 

used to foster the development of new 

markets for scrap tires and to prioritize, 

plan, budget, and track the progress of 

statewide cleanup efforts. In addition, 

U.S. EPA is holding forums in target 

states to convene key players in tire pile 

mitigation efforts in order to present best 

practices and case studies for successful 

tire cleanup and firefighting efforts (see http://www.epa.gov/epaoswer/non-hw/muncpl/tires/index.

htm).

The purpose of this guidebook is to document best practices for scrap tire stockpile mitigation in order 

to assist readers nationwide in planning, managing, and completing abatement projects in a safe, 

efficient, and cost-effective manner. The target audience includes state, county, and municipal health 

and solid waste officials as well as cleanup contractors across the United States. Currently, no federal 

laws or regulations exist that specifically define a “scrap tire” or address scrap tire management. 

Therefore, readers should contact the appropriate state agency to determine state-specific requirements 

and identify applicable cleanup or abatement programs.
Section 2: State Involvement 

States are the driving force behind control and abatement of scrap tire stockpiles. Broad state 

adoption of regulations and regional coordination of neighboring states and local governments 

have dramatically decreased the incidence of illegal scrap tire storage and disposal. However, local 

regulations have a limited impact on controlling statewide scrap tire movement and accumulation. 

Scrap tires can be transported short distances inexpensively, so they usually are moved to the nearest 

unregulated jurisdiction or the destination with the lowest disposal cost. Concerns over the costs and 

hazards associated with large stockpiles as well as the proliferation of new stockpiles have driven most 

legislation.

This section defines important regulatory and 

enforcement roles that states have assumed to control 

and abate scrap tire stockpiles. Many stockpiles 

were created decades ago when such storage was 

unregulated. As a result, many states are forced to fund 

the cleanup of these “legacy” stockpiles because those 

involved in creating the stockpiles lack the resources 

necessary to clean them up. Because states have 

different industrial, economic, political, and geographic 

characteristics, no single scrap tire program is 

universally applicable. Therefore, this section discusses 

alternatives that can be applied to specific conditions. 

A complete inventory of state scrap tire programs, 

including legislation, regulations, guidance, and 

contacts, can be found at http://www.rma.org/publications/scrap_tires/index. It is important to note 

that when state programs sunset without continuation of enforcement provisions, there is renewed 

vulnerability to illegal stockpile formation.

SCRAP TIRE CLEANUP PROGRAMS AND FUNDING

Unfortunately, scrap tire stockpiles do not have a positive net value, as abating stockpiles costs more 

than can be derived from product revenue. If stockpile owners are unable or unwilling to fund 

cleanups, the stockpiles become public liabilities, and funding to abate the associated public health and 

environmental hazards must be provided.

States generally establish funding mechanisms within the enabling legislation that initiates their 

scrap tire programs. These programs are implemented by the regulatory agencies that are typically 

responsible for the following activities:

Federal Scrap Tire Enforcement Authority 

Under Section 7003 of the Resource Conservation and Recovery Act, EPA has enforcement tools 

that can be used to decrease environmental conditions that present “imminent and substantial 

endangerment to health or the environment.” This authority specifically mentions scrap tire 

stock-piles and is a tool that can be used at the federal level to remediate scrap tire piles that pose 

the greatest endangerment to health or the environment. For more information, visit: http://www.

epa.gov/compliance/resources/policies/cleanup/rcra/971020.pdf.

SECTION 2 State Involvement

Photo courtesy of Mel Pins, Iowa DNR
Section 2: State Involvement 

• Creating, implementing, and enforcing 

regulations governing storage, transport, 

processing, and disposal of scrap tires

• Working with the private sector to 

develop the processing and market 

infrastructure required to use scrap tire 

resources 

• Abating existing stockpiles

• Addressing human health and 

environmental hazards associated with 

illegal scrap tire accumulations prior 

to cleanup (for example, mosquito 

prevention and abatement and fire 

prevention and planning)

In general, most programs begin by 

documenting the extent of the problem by 

identifying, quantifying, and prioritizing 

stockpiles. Because most abatement programs 

seek to constructively use scrap tires removed 

from stockpiles, the presence of a processing 

and market infrastructure is important. 

Moreover, one should bear in mind that in most 

cases, the responsibilities and activities listed 

above compete for limited financial and staff resources. 

Effective scrap tire programs generally have the financial management characteristics discussed below.

Dedicated Funding Source. Effective scrap tire programs require consistent and continuing funding. 

Ongoing monitoring and enforcement programs are required to prevent new stockpiles from forming 

after remediation of existing stockpiles. Variability in funding negatively impacts annual cleanup 

volumes, cash flow, capital utilization, and markets, thereby weakening the industry’s infrastructure 

as well as government monitoring and enforcement programs. Dedicated trust funds have been 

used successfully to achieve uniformity but are vulnerable to recapture or readjustment during state 

budget shortfalls. If recapture occurs during the early program stages, stockpile abatement may be 

delayed. Once stockpile abatement is completed and other program objectives are achieved, recapture 

of uncommitted and underutilized funds may be appropriate. However, trust fund residuals have also 

been successfully used to continue monitoring, enforcement, and abatement activities.

Factors Influencing a Scrap Tire 

Abatement Program

• Quantity: The number of stockpiles and 

the total scrap tire quantity affect the 

abatement schedule.

• Resources: Financial and staff resources 

required to plan, perform contracting 

for, and monitor multiple site abatement 

projects must be available.

• Access: Obtaining site access for 

abatement can be a prolonged legal 

process, depending on the procedures 

defined in the enabling legislation.

• Infrastructure: Capacity limitations of 

both contractors and markets must be 

recognized to avoid detrimental impacts 

on the use of scrap tires being generated. 

The overall objective should be to create a 

sustainable infrastructure for using scrap 

tire resources over the long term.

Using a Dedicated Trust Fund for Scrap Tire Abatement in Oregon

Oregon initiated its waste tire management program in 1988, placing the net revenue from its 

$1.00 per tire fee (minus $0.15 per tire for the dealer and $0.035 per tire in administrative costs) 

in a dedicated trust fund. Between 1988 and 1993, Oregon abated 3,823,440 tires at 63 sites at a 

cost of $3,749,041. An additional 101 voluntary cleanups involving 500,000 tires were performed. 

The fund also supported market development and established an ongoing regulatory framework 

for processors and haulers. When the program sunset in 1993, about $1.4 million remained in 

the trust fund. This fund (plus annual interest payments and small licensing fees) was used to 

support continuing regulatory licensing and enforcement activities as well as abatement of small, 

residual stockpiles. In 2003, approximately $600,000 remaining in the trust fund was recaptured 

by the legislature during a severe budget shortfall. Enforcement efforts are now supported under 

the general umbrella of solid waste management fees levied on landfills.
Section 2: State Involvement 

Adequate Resources. In general, funding levels equivalent to at least $1 per scrap tire have proven 

to be adequate to implement comprehensive programs, with 35 to 50 percent of the funds initially 

committed to stockpile abatement. Examples of states with successful abatement programs at this 

funding level include Florida, Illinois, Iowa, and Oregon among others.

Funding Flexibility and Accrual. Abatement funds are often accrued in the early program stages 

while scrap tire stockpiles are being identified, prioritized, and legally accessed. This funding allows 

subsequent contractual commitments to be met and provides contingency funds for unpredictable 

events. As abatement activities are completed, it is generally appropriate to shift funding to other 

program priorities or to reduce revenue in order to reflect the lower financial requirements associated 

with permitting, enforcement, and market development activities.

REGULATORY AND PERMITTING PROGRAMS

Regulations and infrastructure are necessary for an abatement program to be effective and efficient. 

If management, transport, and disposal of the scrap tires generated each day are not controlled by 

regulations, new stockpiles will be created as old ones are cleaned up. Regulatory and permitting 

requirements for scrap tire-related businesses vary widely from state to state. While some states 

have been successful with limited permitting or no permitting at all, others monitor tire movement 

with comprehensive manifest systems and require permits for all businesses involved. There have 

been successes and failures in both approaches. The primary objective of a regulatory or permitting 

program should be to ensure the proper transportation, storage, and disposal of scrap tires and prevent 

formation of illegal stockpiles. 

Processing and Storage Facilities. Some of the largest 

scrap tire stockpiles have been created at processing 

facilities or at storage facilities formed in anticipation 

of future processing, often before state programs were 

enacted. In some cases, the developer does not intend 

to create a viable facility, just to collect tipping fees 

as long as possible or until the facility is at capacity. 

In other cases, a viable facility encounters financial, 

equipment, or market problems, and if the problems 

cannot be resolved, the facility fails. In either case, the 

facility owner or operator ends up leaving behind a 

public liability. In an effort to prevent either situation, 

virtually all state programs regulate processing and 

storage locations to control scrap tire accumulation.

Storage facilities are generally required to be permitted or registered in order to store any scrap tire 

quantity above a stated minimum that can typically range from 50 to 10,000 tires. The minimum 

should be carefully considered. A low minimum forces many commercial tire stores to use inefficient 

collection methods such as frequent hauling of small quantities of scrap tires. A low minimum may 

also unnecessarily increase the burden on both the stores and regulators by requiring registration. 

Experience has shown the optimum quantity to be 1,500 to 2,500 tires, which allows a store to 

accumulate a truckload of tires for optimum hauling efficiency plus a limited additional scheduling 

buffer. The stored tires should be kept under cover and secure to control public health and fire 

hazards.

Processing and larger storage facilities should be permitted or registered. Moreover, they should be 

monitored regularly to ensure their conformance with appropriate regulatory criteria such as zoning, 

building, and fire codes as well as engineering criteria governing stockpile size and separation, fire 

control, mosquito and rodent control, runoff, and other critical factors. Maximum storage limits are 

normally established during permitting. Low limits can impair efficient operations by preventing 

Photo courtesy of Gary Melow, Primary Power
Section 2: State Involvement 

maintenance of adequate inventories to compensate for inherent variations in supply, equipment 

maintenance downtime, or market fluctuations. On the other hand, high limits can increase public 

liability.

An effective compromise allows accumulation of 2 to 4 weeks of scrap tire and/or product inventory 

based on a facility’s demonstrated operating and sales history, provided that the storage conforms to 

fire and safety codes and engineering criteria. In addition, financial assurance should be required to 

cover retrieval and disposal costs for the maximum permitted quantity of tires based on contractual 

disposal rates or third-party quotations. If third-party rates are used, they should include detailed 

descriptions of retrieval, transport, and disposal methods along with locations and costs to allow 

confirmation of their validity. Inadequate financial assurance for actual site abatement may result 

from third-party estimates that are grossly understated as a mutual favor between processors or a 

misunderstanding of financial assurance requirements. Therefore, it is advisable for a regulatory 

agency to require that removal cost estimates be based on contractual or historical costs.

Haulers. Haulers are generally considered to be the 

weak link in the scrap tire management chain. The 

business is extremely competitive, and ultimate disposal 

charges represent a major percentage of the revenue that 

haulers collect from tire dealers. The incentive to reduce 

cost is substantial, especially among smaller haulers 

with no long-term capital commitment to the business. 

For this reason, controls are often necessary to reduce 

the possibility of haulers using inappropriate disposal 

measures. 

One option is to register haulers annually and to provide a decal for display at a prescribed location 

on each transport vehicle. This option allows enforcement officials to check compliance from their 

vehicles. Haulers can submit quarterly, semiannual, or annual summaries of collected tire quantities 

and disposal locations, keeping detailed records for at least 3 years that are subject to spot audits. Also, 

requiring processors and disposal sites to maintain records by decal number provides a cross-checkable 

audit trail.

Some states require financial assurance for each scrap tire-related vehicle or business, with the amount 

ranging up to $20,000 per business. This measure can exempt small haulers; however this is the group 

that is most likely to illegally dump tires. This measure can also have a negative impact on smaller 

haulers operating in rural areas, which may be viewed as discriminatory against small business. Most 

states either do not require hauler bonds or keep them relatively small on a per-vehicle or per-business 

Florida Enforcement Efforts Targeting Haulers and Tire Store Owners

As part of its efforts to control illegal dumping and scrap tire stockpile formation, the Florida 

Department of Environmental Protection has developed regulations requiring scrap tire haulers 

to register with the state and tire stores to use only registered haulers. Enforcement officers in 

Hillsborough County, Florida, conducted a “sting” operation in which undercover officers posing 

as unregistered haulers offered to take scrap tires at below-market cost from tire stores. At the 

conclusion of the operation, 24 store managers who accepted the offer were served with warrants 

from the State Attorney’s Office for a statutory violation punishable by a fine of up to $1,500 and 

1 year in jail. The judge was generally lenient with the managers as first-time offenders but 

promised to exercise the full force of the law if the offense was repeated. The sting served as a 

warning to store owners and focused broad public attention on proper tire disposal practices. 

The county has had few repeat offenders and has stated that additional sting operations may be 

conducted if there are indications of illegal scrap tire hauling activity.

Image courtesy of Todd Marvel, Illinois EPA
Section 2: State Involvement 

basis. In addition, some states only require bonding or financial insurance for commercial car-for-hire 

businesses.

Tire Stores. Tire stores can play a key role in preventing illegal scrap tire disposal. When a store 

owner or operator receives a quote for tire disposal that is below the market price, it likely involves 

illegal disposal. If the owner or operator is required to keep records of the registered hauler decal 

numbers and the tire quantities handled, an auditable trail is maintained. Periodic record review, 

enforcement for noncompliance, and tracking tires collected by unregistered haulers back to the 

source are all useful deterrents to illegal tire disposal. A state with a manifest system can reinforce 

the responsibility of stores by requiring them to maintain a copy of each completed manifest showing 

the ultimate disposal site, as has been done in Oklahoma and Texas. Other states require hauling and 

disposal receipts to be maintained on the store’s property; however, the receipts are not required to be 

submitted to the regulatory agency. This still allows for the regulatory agency to conduct audits of a 

used tire store’s records without the administrative costs of a formal manifest system.

ENFORCEMENT AND COST RECOVERY TACTICS

Enforcement and cost recovery tactics are integrally linked. With a goal of facilitating site access and 

scrap tire stockpile removal, it is important to avoid creating legal and economic obstacles that may 

delay abatement activities. 

Several states have provisions allowing their agencies to enter into access and abatement agreements 

at public expense without cost recovery. This approach expedites site cleanup, and the site owner 

or operator usually welcomes the assistance. However, the approach increases public expense and 

provides no incentive to mitigate sites, many of which (1) are established and operated with no regard 

for regulatory compliance for many years or (2) were established before regulations were implemented. 

Such leniency may lead to additional stockpile formation, as the site owner simply opens another site 

nearby and resumes scrap tire collection and accumulation activities, typically under a different name.

On the other hand, states such as Illinois, Nebraska, New York, and Ohio have provisions that give 

their agencies site access to conduct stockpile abatement without forfeiting cost recovery. 

Most state programs require the regulatory agency to prove in court that a scrap tire stockpile 

represents a public health or environmental hazard. Furthermore, the state must prove that the 

landowner has been given every reasonable opportunity to achieve compliance and remedy the hazard. 

Illinois Use of Tire Removal Agreements

One option for avoiding enforcement and cost recovery obstacles is use of a voluntary tire removal 

agreement (TRA) between the owner of a property where scrap tires are located and the regulatory 

agency. This voluntary, written agreement, which is established pursuant to statutory authority, 

allows the removal of all scrap tires from the property at no cost to the state. 

Provisions must be established in the TRA to ensure that the removal action is conducted in a 

manner that is fully protective of human health and the environment during the entire period 

of the agreement. Statutory authority may allow for maximum removal schedules such as the 

following:

• Three months if the site contains 1,000 tires or less

• Six months if the site contains more than 1,000 but less than 10,000 tires

• One year if the site contains 10,000 or more tires

Extensions of the removal schedule may be allowed if the property owner is operating in good faith 

to execute the agreement.
Section 2: State Involvement 

Because of false starts on cleanups, repeated failures to comply, and court delays, this process can be 

time-consuming, cumbersome, and expensive. The measures discussed next can enhance the efficiency 

and effectiveness of the process.

Dedicated Legal Assistance. Gaining priority for legal resources within a regulatory agency can be a 

major obstacle. In addition, frequent changes in legal staff can further slow the process. Dedicating 

legal staff in both the regulatory agency and attorney general’s office can help to achieve successful 

legal efforts. Legal staff familiarity with the process, the players, and effective arguments is a key factor 

in winning repeated cases.

Initial Legal Support. Rigorously supporting the initial legal proceedings (complaints, testimony, 

and depositions) with sound preparation, good research, and expert testimony encourages defendant 

negotiation and capitulation. Furthermore, when the strength of cases and the commitment to follow 

through are recognized by others in the scrap tire industry, they are encouraged to comply with 

regulations in order to avoid similar confrontations.

Negotiations. When cases are strong and the regulatory agency is determined, some site owners 

recognize the economic advantage of mitigating their sites on their own. They can typically mobilize 

Dedicated Legal Support Services for Scrap Tire Cases in Wisconsin 

The Wisconsin DNR reimbursed the state Attorney General directly from its waste tire fund for 

a lawyer and support services dedicated to scrap tire cases. The dedicated attorney’s repeated 

experience with scrap tire cases enhanced efficiency and effectiveness, eliminating significant 

blockades in the legal process. During the 1988 to 1997 period of Wisconsin DNR’s program, the 

State of Wisconsin abated almost 11 million tires at 162 sites and encouraged removal of almost 

4 million tires from an additional 408 sites. The state pursued cost recovery for some sites and 

achieved judicial judgments or negotiated agreements for a total of $866,750, with about $330,000 

actually being collected as of program sunset.

Forced Removal Actions in Illinois

State of Illinois Compiled Statute 415, Title XIV, governs all used tire management practices (see 

http://www.epa.state.il.us/land/tires/index.html). Section 55.3d of this statute enables the Illinois 

EPA to notify a landowner of the environmental and public health hazards associated with a 

scrap tire stockpile. The landowner then has an opportunity to develop, submit to the Illinois 

EPA, and implement an abatement plan meeting the specific requirement outlined in the 55.3.d. 

Notice. If the landowner is unwilling or unable to comply with the removal schedule, or does not 

submit a removal schedule in response to the Notice, the state is granted access to the property via 

existing statutory authority. As an added precaution to confirm the protection of the landowner’s 

constitutional rights, the Illinois EPA uses an access agreement that is signed by the landowner 

prior to the removal action. If the landowner refuses to sign the access agreement, the Illinois EPA 

will then go into court to seek access from a judge. Illinois EPA’s access agreement is available at 

http://www.epa.gov/reg5rcra/wptdiv/solidwaste/tires/guidance/index.htm.

Under Illinois’ program, if the waste tire site contains in excess of 250,000 passenger tire 

equivalents (PTE) or 3,125 tons, then the landowner is given the opportunity to enter into a 

cost recovery reimbursement schedule not to exceed 5 years. This allows the recovery of costs 

without going through the full formal enforcement process, provided the landowner remains 

in compliance with the reimbursement schedule. The landowner has an incentive to reach an 

agreement because the Illinois EPA has a legal right to levy additional punitive damages not to 

exceed two times the actual expenditures associated with the stockpile abatement.
Section 2: State Involvement 

contractors and select disposal methods at a lower cost than the agency. Additionally, they can avoid 

the legal costs and state administrative expenses that would be incurred in legal cases. Providing a site 

owner with information on the difference in costs associated with different types of responses to the 

complaint can be compelling during initial negotiations. If a site owner lacks adequate resources but 

has income, an agreement covering reimbursement over time can be beneficial. For example, Florida 

encourages significant abatement activity through aggressive cost recovery. Nearly 9 million of the 15 

million stockpiled scrap tires in Florida were abated by site owners or responsible parties. The cost 

savings were substantial, which is critical for states with limited financial resources.

Judgment Collections. Only a small percentage of judgments rendered against site owners and 

operators are actually realized. Typically, offenders hide assets, declare bankruptcy, or disappear. A 

judgment can be a long-term nuisance to an offender, precluding accumulation of any assets subject to 

the judgment. Cost recovery’s primary value is to create an incentive for landowner abatement of a site, 

not to realize financial judgments against offenders without assets.

Liens. Liens can be the most effective method of cost recovery from site owners. Most states do not 

foreclose on liens but hope to gain some revenue from negotiated interim payments or from sale of 

the property (especially commercial property) in the future. For example, Florida files liens before 

beginning abatement activities and perfects the liens once all abatement costs have been compiled. 

Factors That May Limit the Applicability of Liens 

• Homestead: Some states allow primary residential property to be declared a homestead, 

protecting it from debt or judgments other than taxes. In such cases, liens have no practical 

value unless the property acreage exceeds homestead limits and can be separated for 

lien purposes. In some cases, excess acreage has been forfeited to the state as part of a 

negotiated settlement. In one case, a parcel was deeded to the county by the state for 

conversion into a park.

• Prior Judgments: Prior liens or judgments placed against a property by others may exceed 

the property value and effectively negate the usefulness of the state’s lien.

• Property Condition: Before a lien or partial settlement involving land transfer is exercised, 

it is important to carefully examine the property’s condition. This examination will 

ensure that liability is not assumed for contaminated property and additional remediation 

expenses. Many properties containing scrap tire stockpiles have suffered prior abuse or 

environmental damage. Two properties containing large stockpiles in New England and 

Wisconsin were also high-priority Superfund sites because chemical-filled drums were 

buried among and under the tires. Assuming additional liability for contaminated land 

requires a careful cost-benefit analysis.
Section 3: Planning 10

SECTION 3 Planning

Scrap tire stockpile abatement is a technical, economic, 

and political challenge. Cleanups involve elusive factors 

such as weather, stockpile contents, and underlying 

topography. Proper planning can limit adjustments 

that consume resources, thereby minimizing impacts 

on overall program performance and cost. This section 

presents critical planning considerations for both an 

overall cleanup program and individual abatement 

projects.

STOCKPILE IDENTIFICATION AND MAPPING

Stockpile identification is the first step in defining the magnitude of the scrap tire stockpile problem in 

any jurisdiction. The most effective identification methods have involved all levels of government and 

enforcement as well as industry groups and citizen reports.

State Government. State solid waste and public health agencies play a focal role in scrap tire stockpile 

identification efforts. These agencies have a broad range of organizational structures. Centralized 

agencies deploy personnel to each region of the state to work with county, city, and local officials 

in identifying and characterizing sites. Other agencies either designate one person in each regional 

office to identify stockpiles or distribute the responsibility to all staff based on their geographic or 

industry area of expertise. Smaller identification groups are easier to train and gain greater knowledge 

through in-depth experience. However, these advantages can be offset by greater travel time, cost, and 

difficulty in making regular visits to examine changing site conditions.

One effective compromise is to use a broad base of individuals to identify stockpiles in their service 

areas and then task a smaller group to characterize and prioritize stockpiles. Contractors or consultants 

may be useful for supplementing agency resources in the early stages of program implementation. 

Finally, other state or local authorities can be leveraged, such as forestry, park, wildlife, natural 

resource, and police agencies. Such authorities have field personnel with extensive knowledge of rural 

areas that often harbor stockpiles.

County and Local Governments. Most effective programs have drawn heavily upon county, city, 

and local governments to identify stockpiles. Police, code enforcement, mosquito control, solid waste 

management, public health, park, firefighting, forestry, and game and fish personnel have all helped to 

identify stockpiles encountered during their normal activities. 

One state sent surveys to all county and local governments (including those for municipalities with 

over 1,000 people) during initial scoping activities. The survey asked for stockpile sites to be identified 

by location, street address, and owner. Cooperation in such efforts can be enhanced by the survey 

objectives and methodology and by explaining the ability of the program to help local governments 

abate identified sites without consuming local resources.

Additional Identification Methods. Other creative methods can be used to support identification 

efforts, including the following approaches:

• A toll-free telephone number can be established to encourage residents to report stockpiles and 

illegal dumping activities. Local governments and industry organizations can be leveraged 

to disseminate information about the program. Many large stockpiles are found based on 

information provided in citizen complaints.
Section 3: Planning 11

• Both public service announcements and promotion of initial abatement activities encourage 

reporting of additional stockpiles.

• Committees consisting of representatives of tire dealers, salvage yards, and haulers can reach 

out within their respective industries to encourage stockpile identification.

Required Information. Once a stockpile is identified, characterization is conducted to gather 

information required for prioritization, stabilization, and abatement activities. The following 

information should be considered, especially for larger sites:

• Location, including street address, city, county, and global 

positioning system (GPS) coordinates

• Owner or operator, including name, address, telephone 

number, and involvement

• Stockpile characteristics such as dimensions, tire sizes, 

age, the presence of rims, possible compaction, existence 

of lacing (see photo at right) or stacking, the percentage of 

whole tires and shreds, and the presence of other wastes

• Site characteristics such as stockpile spacing, soil 

characteristics, topography, access, and drainage channels 

as well as nearby surface water, residences, businesses, 

and population densities. (Nearby schools, airports, and 

other large public facilities should also be identified to help define environmental impacts.)

• Site conditions impacting fire control, such as access roadways, water resources, perimeter and 

internal fire lanes, trees, and brush 

The information on site characteristics and conditions is useful for site stabilization and fire control 

planning for larger sites. An example site characterization form is provided in the Appendix of 

this guidebook. For smaller sites, only the location, owner or operator, and stockpile characteristic 

information is needed. 

Mapping. Stockpile mapping offers political, technical, and economic benefits. It allows public 

officials and citizens to understand the extent of the problem, as it graphically illustrates the broad 

distribution of scrap tire sites in the state. From a technical and economic standpoint, mapping 

enhances efficiency by supporting coordination of site-related activities such as inspections. In 

addition, contractor efficiency can be maximized by addressing several nearby sites under a single 

abatement contract if site access can be achieved concurrently. The combined volume encourages 

contractor interest, and the approach decreases mobilization and demobilization costs. Example 

stockpile maps prepared using GIS are shown on the following page.

QUANTITY ESTIMATION TECHNIQUES

Following stockpile identification, the scrap tire quantity is estimated for prioritization, program 

planning, budgeting, and contract management purposes. Stockpile estimating is relatively simple 

in principle, but can be impacted by many variables. Many early estimates were performed using 

the “gazer” technique. For example, a person would stare at a stockpile and state that it “looked like 

Mapping Tip 

Review of site background information, such as aerial photographs, topographic maps, or tax 

maps, before the scrap tire quantity is estimated can reduce the effort needed for field mapping. 

This information is often available in government or other Internet-accessible databases. 

Photo courtesy of Todd Marvel, Illinois EPA
Section 3: Planning 12

Using GIS to Map Stockpile Sites 

U.S. EPA Region 5 initiated a cooperative 

effort to map all the remaining stockpiles 

in several states. Stockpile sites are being 

identified based on GPS coordinates and other 

site features in cooperation with state and 

local authorities. The information collected 

was entered into a database that was used to 

develop GIS maps with color-coded pile size 

delineations. Such maps have been created 

for Alabama, Connecticut, Indiana, Michigan, 

New York, Ohio, and Pennsylvania. 
Section 3: Planning 13

about a million tires” when in reality it could have contained between 20,000 and 20 million tires. Some 

people still use this technique, resulting in estimates with extremely large margins of error.

Some basic science has been added to the “gazer” technique, resulting in significant improvements in 

estimate accuracy. During initial site identification and examination, the dimensions of each stockpile 

segment should be measured using one of several techniques, including a long tape, a measuring 

wheel, or a calibrated pace. A 100-foot, fiberglass tape requires two people for efficient use and is 

preferable for uneven terrain or in cases likely to require court testimony. A large-diameter measuring 

wheel can be used on firm, level terrain but is unusable on rough or muddy ground. A calibrated 

pace can be used efficiently on most terrain, but its accuracy depends on the ability of the measurer 

to maintain a uniform pace. Taking measurements from the midpoint of the pile slope simplifies 

subsequent calculations. In addition, photographs should be taken during field inspections to 

document site conditions, to monitor changes in site conditions between inspections, and to serve as 

legal evidence. An example stockpile characterization form that can be used to collect data is provided 

in the Appendix of this guidebook.

Estimating stockpile depth is often 

a challenge because the sides are 

sloped and not easily measured. 

One technique (see figure at right) 

is to have a person of known height 

stand as close to the pile as possible 

while an observer stands back and 

measures the pile depth in multiples 

of the first person’s height. The 

observer should be at least 10 times 

the estimated pile depth away to minimize angle distortion. A spotter’s scope or compact measuring 

device can also be used. A large pile should be climbed, and the top of major pile segments should be 

walked to observe top contours, pile characteristics, dimensions, and firmness (which reflects density 

variations associated with compaction, aging, and lacing). Tires in stockpiles are irregularly shaped, 

flexible, and unstable, so extreme care should be taken when climbing a tire pile.

Stockpiles pose other health risks that should be considered while estimators are on site. Scrap tires 

can support breeding of mosquito species that are capable of serving as vectors for potentially fatal 

diseases such as eastern equine encephalitis, West Nile virus, and dengue fever. While estimators are 

on site, protective clothing and mosquito spray should be used to minimize exposure. In addition, 

stockpiles typically harbor rodents and snakes, so estimators should be observant and move cautiously.

For a large stockpile, aerial photographs can be used to define its horizontal dimensions, but a scale 

must be established based on nearby objects. To be effective, aerial photographs must be taken 

vertically to avoid dimensional distortion. Depth and density estimation requires ground observation. 

Detailed aerial surveys can be conducted, but the ground topography under the pile must be known or 

assumed. Aerial surveys are expensive, and their accuracy is questionable unless a pile is deep enough 

to reduce the margin of error associated with surface depth irregularities. Ground surveys have also 

been performed with volume-integrating software, but they can be expensive and may not offer greater 

accuracy than manual measurements.

As a first step, the stockpile volume is estimated using calculations based on the dimensions. In some 

cases, irregular shapes can be converted into rectangles, circles, or other simple geometric shapes to 

simplify calculations without impairing accuracy. In other cases, a single irregularly shaped pile can 

be measured as two or more connected rectangular segments with different dimensions. If dimensions 

have been measured from the midpoint of the slope, the volume of a rectangular pile is simply the 

product of the length, width, and depth. Although this method is not geometrically perfect, the 

simplification does not significantly impact the total volume estimate.

@

@

Estimating Stockpile Depth
Section 3: Planning 14

The volume of other common stockpile shapes can be calculated using the following formulas:

• Circle: πr2d or 

3.14 x circle radius x circle radius x depth

• Triangle: 1⁄2 lwd or

1⁄2 x length x width at base x depth (from base to peak of pile)

• Trapezoid: 1⁄2 l (w1 + w2) d or

1⁄2 length x (width at base + width at top) x depth

The second step in estimating the tire quantity in a stockpile is determining the pile density, or the 

quantity of scrap tires contained in each cubic yard of the pile. Volume is translated into quantity or 

weight through assignment of a density. Because most tire stockpiles contain mixtures of various tire 

sizes, density is normally expressed in terms of the passenger tire equivalent (PTE), which is equal 

to 20 pounds by definition. Most scrap tires have roughly equivalent densities when expressed in 

terms of PTE/cubic yard. For instance, a medium truck tire weighs approximately 100 pounds (5 PTE) 

and occupies a volume equivalent to four to five passenger tires in a given stockpile. Because most 

abatement activities and other considerations are based on weight, the equivalency more accurately 

reflects future tire use, processing, and disposal.

The density of loose, shallow, whole-tire stockpiles is normally about 10 PTE /cubic yard but can 

range from 8 to 27 PTE/cubic yard. Densities below 10 PTE/cubic yard reflect rimmed tires that do not 

collapse but account for only the rubber weight under the assumption that rims will be removed before 

tire transport. Stacking or lacing increases the effective density to 12 to 15 PTE/cubic yard for passenger 

tires, and 13 to 18 PTE/cubic yard for medium truck tires. The highest density range rarely occurs 

but was encountered in a 40-year-old stockpile in a canyon that was over 100 feet deep near Modesto, 

California; the very hot climate caused the tires to be more flexible and easily compacted. Other factors 

that impact the density of whole-tire stockpiles are shown in the table on page 15.

The density of shredded-tire stockpiles can range from 30 to 90 PTE/cubic yard (600 to 1,800 pounds/

cubic yard). The lower density range represents shallow, uncompacted piles of uniformly large 

particles such as single-pass shreds. The higher range represents deep stockpiles of finer tire-derived 

fuel (TDF) that has been heavily compacted by repeated movement of heavy equipment during 

stacking. The highest range represents compacted shreds with extensive dirt contamination. Major 

factors that impact shredded-tire stockpile density are shown in the table on page 15.

Once the stockpile volume and density have been estimated, the tire quantity (or weight) is calculated 

by multiplying the volume (cubic yards) by the density (PTE/cubic yard). The result is a tire quantity 

expressed as PTE. The tire quantity can also be expressed as a weight (tons) by dividing by 
Section 3: Planning 15

100 PTE/ton. A schematic of a simple stockpile site is shown in Exhibit 1 and the quantity calculation 

logic is summarized in Exhibit 2.

Although the estimating methodology described above has been successfully applied to hundreds of 

scrap tire stockpiles, the following factors may affect its accuracy:

• Topography: The underlying topography 

can significantly affect pile volume and tire 

quantity but may not be apparent from surface 

observations. Larger tire piles are more difficult 

to estimate because they may conceal ravines or 

pits filled with tires. Piles located on hillsides 

are also difficult to estimate because the hillsides 

may curve or become steeper beneath the piles.

• Nonuniformity: A pile may appear to consist 

of loose tires on the surface, but laced tires or 

shreds may be present in the pile, significantly 

increasing pile density and tire quantity.

• Contamination: Piles can be contaminated with water, soil, automobile parts, or other waste 

that may not be visible from the surface. Water and dirt can significantly increase pile density 

and abatement costs. Also, the presence of whole vehicles or chemical-filled drums can 

complicate tire retrieval, especially if the vehicles are loaded with tires or the drums contain 

hazardous wastes.

STOCKPILE PRIORITIZATION

With the understanding that resources are limited, stockpile stabilization, abatement, or both should 

be initiated following a prioritized sequence based on the comparative hazards posed by various sites 

(see Section 1). A prioritization system should reflect current and potential impacts on citizens and the 

environment, particularly impacts on sensitive receptors such as schools, hospitals, daycare centers, 

and nursing homes.

One prioritization method uses stockpile size as a multiplier because it typically magnifies the impacts 

of a tire fire. The multiplier ranges should reflect the quantities of tires in the piles being prioritized. 

For example, the following size factors could be used for stockpiles with the numbers of tires indicated:

• Less than 100,000 tires = 1

• 100,000 to 250,000 tires = 2

• 250,000 to 1,000,000 tires = 3

• More than 1,000,000 tires = 4

Photo courtesy of Allan Lassiter, Virginia DEQ

Factors Affecting Tire Density
Section 3: Planning 16

Exhibit 1. Example Stockpile Site

Exhibit 2. Example Tire Quantity Calculation
Section 3: Planning 17

The potential impact on the general categories of air, water, and population are evaluated 

independently (based on data from the initial site evaluation) using a scale of 1 to 10 with 10 indicating 

the greatest potential impact. These three ratings are added and multiplied by the size factor. Factors 

to consider when evaluating the impact of a stockpile to air, water, and population density are shown 

in the figure above. Stockpile size is an important consideration, but impact is the controlling issue.

Stockpile sites are then prioritized based on the resulting rating totals, with the highest rating 

representing the highest priority. Sites generally fall into rating groups with numerical separations 

between the groups. Within groups, rating differences are generally small, and the abatement sequence 

can be based on site access, contractor availability, markets, or location. The figure below shows an 

example of the prioritization method. 

Consistency is an extremely important component of any stockpile prioritization system, so the 

smallest possible number of evaluators should be used. Nevertheless, it can be beneficial to have 

two or three evaluators compare their ratings so that subjective inconsistencies can be identified and 

corrected. Ratings generated by a variety of people can be reviewed by a small, central staff to increase 

the consistency of the ratings.

Example Stockpile Prioritization

Factors to Consider When Evaluating Impacts of Scrap Tire Stockpiles

• Population proximity

• Mosquito species

• Identified local/regional

 mosquito-borne diseases

• Rodent/snake infestation

• Stockpile characteristics

IMPACT Air Water Population

ISSUE

FACTORS 

TO CONSIDER 

Impact of fire plume

on residents, businesses,

and regional air quality

Impact of contaminants in oil

and residual ash on surface

water or groundwater 

Impact of existing stockpile

on area residents

• Prevailing wind direction 

• Stockpile characteristics 

 such as height, trees and 

 brush, and fire lanes 

• Surrounding land use 

• Sensitive receptors such as 

 schools, airports, and large 

 public facilities (within 

 0.5- and 5-mile perimeter) 

• Soil characteristics such 

 as permeability 

• Aquifer characteristics such 

 as water table depth and 

 drinking water use 

• Site drainage 

• Surface water proximity 

• Sensitive receptors suc 

 as wetlands, fisheries, 

 or endangered species 

• Stockpile characteristics 
Section 3: Planning 18

Some states use independent contractors or consultants to manage or perform stockpile prioritization 

in order to limit political influences. Using a technically sound prioritization process performed by 

unbiased evaluators also improves program effectiveness and efficiency.

MARKETS

Something has to be done with the scrap tires that are removed from stockpiles. Many states have 

constructively used scrap tires removed during remediation projects in civil engineering or other 

applications. Done properly, stockpile abatement can help to develop new markets or add supply 

volumes to existing markets. Done improperly, it can negatively impact existing markets and 

processors, even driving current-generation tires into stockpiles or landfills. Markets require various 

levels of processing ranging from shredding to metal and fiber removal, thus adding expense. 

Although it is not the preferred option, scrap tires may also be landfilled if their condition is not 

suitable for available markets.

Stockpiled tires are often contaminated with 

water, dirt, or other foreign materials that limit 

potential markets and increase processing costs. 

Some cement kilns that use whole tires and that 

can accept limited water and dirt contamination 

represent a market, but kiln capacity and 

fuel weighing can be negatively impacted by 

substantial contamination. 

Because contamination can damage processing 

equipment and increase maintenance expenses, 

contractors try to minimize damage by producing 

large tire shreds (for example, 4 inches or larger 

without steel belts removed) for civil engineering applications. Examples include large highway 

embankment or lightweight fill projects that can consume 500,000 to 1,500,000 tires per project. In use 

of tire shreds for aggregate replacement during landfill construction, a range of tire shred sizes may 

be used, depending on the construction details of the liner and drainage system. Examples of landfill 

applications include use of tire shreds for daily cover, leachate collection layers, surface water drainage 

layers, and gas collection channels. Large chips with minimal processing requirements minimize 

abatement costs if they are technically acceptable.

Proper retrieval of tires from uncontaminated stockpiles can yield clean tires that can be processed 

into TDF or drain field products. In some cases, contractors choose to accept higher equipment 

maintenance costs and downtime to process dirty tires under abatement contracts. However, most 

crumb rubber producers generally do not accept abatement tires because of their impact on equipment 

and product quality.

Coordinating Scrap Tire Abatement with Landfill Remediation in Illinois 

Illinois EPA recently directed an abatement of its largest scrap tire site that was coordinated 

with a nearby state-funded landfill remediation project. The Coultas Recycling site in Danville, 

Illinois, contained about 1 million scrap tires. The inactive H&L landfill about 3 miles away posed 

environmental problems for the City of Danville and was being properly closed and capped by 

the Illinois EPA. A gas transmission system was required below the impermeable cap to maintain 

its integrity. The stockpiled tires were shredded on the Coultas Recycling site, transported to the 

landfill site, and spread over the top of the landfill (within geotextile encapsulation) to serve as a 

gas transmission medium under the impermeable cap. The shred layer was tapped to allow gas 

removal. One million tires were processed and removed from the stockpile site in 9 months with 

no impact on existing markets and at a lower cost than that of alternatives. 
Section 3: Planning 19

Some legislative or regulatory measures 

require that all abatement tires be 

constructively used. Such a requirement can 

have the following impacts:

• Damage of processing equipment: 

Processing heavily contaminated 

or partially burned tires can cause 

equipment problems that delay 

stockpile abatement.

• Market distortion: Driving abatement 

tires to existing markets can displace 

products made from currentgeneration tires. This displacement 

can create market instability, cause 

processor attrition, and force currentgeneration tires into landfills or stockpiles.

Creating new markets for abatement tires or rewarding contractors for creation of such markets is a 

critical component of an effective scrap tire program. Examples might include working with the state 

Department of Transportation (DOT), landfill owners and operators, and state agencies conducting 

landfill closures to identify scrap tire projects. Creating and specifying a new market can decrease 

abatement costs. At a minimum, the maximum percentage of existing markets displaced by abatement 

activities should be controlled even if it means extending cleanup schedules or allowing product 

storage under monitored conditions.

PROPERTY ISSUES

Scrap tire stockpiles are generally located 

on property that is owned and controlled 

by one or more individuals. Before a scrap 

tire remediation project begins, it is essential 

to obtain either a written property access 

agreement from the landowner or a court 

order granting property access for the purpose 

of tire removal. At many sites, a property 

boundary survey is also necessary to ensure 

that remediation work does not inadvertently 

extend over onto adjacent properties. If 

additional properties are involved, additional 

property access agreements or court orders 

will be needed.

The following issues should be considered in dealing with properties :

• Utilization: A property can contain buildings, other structures, and utilities that would be 

useful to a contractor during on-site activities. If any of these items are to be used, a written 

agreement establishing the usage conditions, obligations, and compensation can prevent 

subsequent misunderstandings.

• Damage: States have been sued for damage done by contractors acting as their agents. In 

some cases, the damage has been done by others prior to initiation of cleanup activities. As 

a preventive measure, complete and dated sets of photographs before, during, and after site 

abatement is useful for documenting site conditions.

Photo courtesy of Todd Thalhamer, California IWMB

Photo courtesy of Gavin Adams, Alabama DEM
Section 3: Planning 20

• Restoration: Water in tires and rain create muddy conditions in unstable soil under a stockpile. 

Heavy equipment can create deep ruts, and water runoff can erode surface soil. After tire 

retrieval, contractors are generally required to level heavily rutted land. In most cases, reestablishing vegetation will control erosion.

Recognizing a property’s value while obtaining and maintaining the landowner’s cooperation facilitates 

abatement operations. If the property owner will not cooperate, a court order must be obtained to 

enter the property and remove the scrap tires. State legislation can aid this process if laws are passed to 

create an administrative process for ordering scrap tire cleanups. One example is Ohio Revised Code 

3734.85, which can be found at http://www.ohio.gov/government.htm.

COMMUNICATIONS

Stockpile abatement involves many groups, including contractors, local governments, politicians, and 

the press. Informing and coordinating these groups are critical components of successful scrap tire 

programs and abatement projects.

Contractors. Any special abatement project requirements should be clearly defined in detailed plans 

and specifications provided to prospective contractors prior to the bidding process. Examples of items 

that should be addressed in such plans include the following:

• Site description

• Tire quantity estimate

• Tire pile length, width, and height

• Operating procedures

• Fencing

• Lighting

• Security

• Fire lanes

Many contractors have developed their own abatement methods to optimize the efficiency of cleanup 

operations based on years of experience. Experienced contractors should be invited to suggest 

alternative approaches. An initial description of the project should be developed to provide a sound 

foundation for project communications and to minimize the need for discussion of pre-planned 

activities. Example pre-bid documents 

prepared by the States of Iowa and Illinois 

are available at http://www.epa.gov/reg5rcra/

wptdiv/solidwaste/tires/guidance/index.htm. 

Elected Officials. Local and state elected 

officials are instrumental in creating and 

maintaining abatement programs. Providing 

updates on program implementation 

and abatement projects is important. 

Digital photographs, videotapes, or aerial 

photographs of sites before, during, and after 

abatement can be sent to state legislators 

in the district to maintain communications 

• Pile removal sequence

• Stabilized access and perimeter roadways

• Control of vegetation, mosquitoes, and 

run-off

• Water source and distribution

• Fire plan

• Utilities

• Progress reporting

Photo courtesy of Bob Large, Ohio EPA
Section 3: Planning 21

and build support. Inviting elected officials to see stockpile sites before and after cleanup also creates a 

good public relations opportunity.

Local Governments. Local administrators and police and fire departments can provide critical support 

services at little or no cost if they are included in project communications. Informing these groups 

about project plans and associated benefits to the community enhances cooperation. Discussing 

security and fire control measures with local departments before the project starts increases the 

probability of a successful response if needed. A contact list that includes emergency response contacts 

and procedures should be provided to all project participants.

Press. Publicity allows citizens to understand an abatement program and the value received for 

public fees. In addition, publicity allows politicians and program participants to be recognized for 

accomplishing removal objectives. However, drawing attention to stockpile abatement projects can 

have undesired effects. Many fires are actually started by site operators or local residents in the wake 

of publicity over cleanup activities. One of the largest tire fires in Canada, which involved an estimated 

10 million tires, was started by teenagers attracted to the site by local publicity. One approach is to 

issue a press release highlighting the last scrap tire being thrown onto a truck by a local community 

leader; the release can include site photographs taken before and during abatement. 
Section 4: Contractors 22

SECTION 4 Contractors

The success of a scrap tire abatement program hinges 

on selecting contractors that are capable of performing 

required tasks cost-effectively in accordance with 

procedures and schedules. In many early abatement 

efforts, processors were developing field operating 

experience, equipment was evolving, maintenance 

requirements were being defined, limited capital 

prevented use of efficient tire retrieval equipment, 

and few product markets existed. These factors 

contributed to project delays and failures. Although 

abatement activities still pose substantial challenges, 

the cumulative benefit of past experience, equipment 

improvements, appropriate retrieval equipment, and 

substantial market development has greatly enhanced the probability of success. One key to success is 

selection of contractors with good performance records and the ability to perform at a reasonable cost. 

This section defines critical factors and alternatives for successful evaluation and selection of stockpile 

abatement contractors.

EVALUATING CONTRACTOR QUALIFICATIONS 

The amount of information requested from contractors during the evaluation process varies widely. 

Some agencies request comprehensive data, while others simply request contact and pricing 

information. The optimum amount of required information depends on specific site characteristics 

such as stockpile size and project complexity as well as the agency’s experience with contractors. The 

primary factors that have been used to evaluate contractors are discussed below.

Company History. Some contractors and processors have changed their names frequently, especially 

after failed projects. Requiring a contractor to identify all of its previous names and affiliated 

companies and to provide organizational charts can help the agency understand the contractor’s 

history. Also, identification of subcontractors, their roles, and the anticipated revenue apportionment 

allows the agency to evaluate the contractor’s ability to execute assigned responsibilities.

Company Financial Capabilities. Financial strength increases the probability that a contractor will 

have appropriate equipment and will be able to overcome unexpected problems. To identify the 

financial strength of contractors, some states request 2 or 3 years of financial data. Some privately held 

companies are reluctant to provide this data unless confidentiality can be maintained. An alternative 

is to require a contractor to document its ability to provide a bond or other financial assurance for an 

amount equal to the maximum required for the proposed abatement activities. This approach protects 

the agency’s financial interests and avoids confidentiality concerns.

Experience. Positive project completion experience increases the probability of future success, so it 

is critical for a contractor to document its experience on comparable projects. Experience on small 

projects does not necessarily relate to larger projects, but it can provide a foundation if the small 

project’s equipment and removal rates were comparable to the requirements for a larger site. A 

contractor should describe its previous work in detail and should submit customer contact information 

to allow verification of performance claims.

Equipment. Stockpile abatement involves tire retrieval, transport, and processing. Requiring a 

contractor to list and describe the major equipment to be used facilitates the evaluation. Retrieval 

Photo courtesy of Mel Pins, Iowa DNR
Section 4: Contractors 23

equipment generally includes an excavator for larger sites, a front-end loader with a specially equipped 

bucket system for medium-sized sites, and a tracked bobcat with an appropriate bucket for smaller 

sites. Additional specialized equipment may be required for sites with unusual topography. 

Transport equipment typically consists of standard 18-wheel tractors and trailers. High-volume 

trailers enhance efficiency if long-distance transport of whole tires is required. Some contractors use 

subcontractors to haul tires; information on the subcontractors, such as their licensing or relevant 

qualifications, should be required during the bidding process.

Tire processing can be performed on site or at a centralized processing facility. On-site processing 

is generally less efficient because of unstable ground conditions, material handling considerations, 

volume inconsistency, and equipment maintenance challenges. On-site processing is most suitable for 

large sites that are distant from centralized processing facilities and product markets. 

Processing equipment requirements depend on product 

and market specifications. A smaller product size 

specification normally requires multiple size reduction 

units in series or extensive recycling within a single 

unit (with a proportional decrease in effective capacity). 

The impact of dirt, rocks, and other contamination is 

generally proportional to the processing requirements. 

Large tire chips for highway embankment applications 

require less processing, but soil contamination must 

be removed. Nominal 1-inch-diameter TDF has been 

produced at stockpile sites, but dirt contamination 

significantly increases equipment maintenance 

requirements and associated downtime. It is generally 

not practical to produce crumb rubber from stockpiled tires unless they are unusually clean and are 

carefully retrieved.

Products and Markets. A contractor should be required to identify specific markets and the percentage 

of displacement expected to be incurred from stockpiled tires. In general, this percentage should not 

exceed 15 to 25 percent of the current-generation tires. In addition, the contractor should identify 

product specifications and an existing contractual basis with a product customer. Lack of a contractual 

basis increases market vulnerability and the probability of displacing products made from currentgeneration tires. The proposed processing equipment must be capable of generating products that 

meet the specifications. 

Wastes. In some cases, contractors have received premium payments associated with product 

recycling while actually recovering a very small percentage of tires as usable product. Substantial 

volumes of tires have been discarded or landfilled without the prior knowledge of the contracting 

agency. For this reason, a contractor should identify projected waste volumes and disposal methods 

so that the contracting agency can consider recovery percentages in its evaluation. On the other hand, 

the contracting agency should not preclude landfill disposal of heavily contaminated tires or shreds. 

Attempts to recover tire material can be counterproductive by unnecessarily increasing (1) handling 

requirements and (2) equipment maintenance and downtime. Such attempts can thus be detrimental to 

completing rapid, efficient, and cost-effective site abatement.

Personnel. A contractor should identify specific management personnel and their prior experience, 

including the on-site personnel who will be responsible for daily operations and equipment 

maintenance. On-site operations require personnel who are capable of making sound decisions when 

faced with unexpected events at remote locations. In addition, the contractor should identify qualified 

support personnel who are available to assist if needed.

Availability. Many contractors have limited equipment and may be involved with multiple sites prior 

to a new contract award. For this reason, a contractor should identify its anticipated mobilization 

time requirement and proposed start date; alternatively, an early start date can be established to reveal 

Photo courtesy of Mel Pins, Iowa DNR
Section 4: Contractors 24

whether a contractor can perform according to the schedule. It is also critical to identify the net 

removal rate that the contractor can sustain for the duration of the project so that the total amount of 

time needed to clean up the site can be estimated.

Past Performance. A contractor should identify all comparable projects completed within the last 2 to 3 

years. In addition, the contractor should provide a detailed description of its previous project activities, 

identify any failures to comply with contract conditions, and provide customer contact information for 

each project so that the contracting agency can verify the contractor’s performance.

Cost. The contracting agency can require a 

contractor to submit a bid based on a fixed price 

to perform the total site abatement. In general, 

contractors build a substantial safety factor into 

fixed-price bids, increasing the cost per ton of 

material to be removed. Most current abatement 

activities are performed on a cost-per-ton basis to 

enhance cost-effectiveness. The risk associated 

with this approach involves additional costs 

associated with contamination such as soil or 

automotive parts. To control abuse, retrieval and 

loading operations should be closely monitored, 

and the contracting agency should reserve the 

right to adjust weights in order to control excess 

contamination. In a cost-per-ton contract, the total 

contract price is based on the estimated quantity 

of tires. To avoid change orders, associated work 

stoppages, and additional costs, it is important to 

obtain an accurate estimate up front. However, in 

the event that an accurate estimate is not possible, 

the contract can include costs based on a range of 

tonnages to reduce the need for change orders.

BIDDING AND AWARD PROCESS

States have used a wide range of approaches in the contractor bidding and award process. One major 

variable has been the amount of information requested in request for proposal (RFP) documents. 

In some cases, only a fixed price was requested, and the project was awarded solely on this basis. 

One state used this approach during initial site abatement activities, and the contractors selected 

were inexperienced, were underfinanced, and offered low bids based on a misunderstanding of the 

abatement requirements. The result was a consistent pattern of failures to maintain schedules and 

complete projects.

An alternative RFP approach for major stockpile sites is to require contractors to provide detailed 

responses to the criteria cited in the previous subsection in order to increase the factual basis for 

evaluation. Less information may be requested for smaller sites or when the contracting agency 

already has a thorough understanding of a contractor’s capabilities based on previous experience. 

When detailed responses are requested, a weighted evaluation should be completed to reflect the 

importance of each criterion. These weights should be included in the RFP. A minimum of three 

experienced individuals should evaluate and score proposals, with the total scores controlling 

contractor selection. When the scores for a given proposal differ significantly, the scores should 

be reviewed for errors or misunderstandings, and obvious errors should be corrected prior to final 

contractor selection.

Conducting a detailed RFP process for each site can be cumbersome and time-consuming for all parties, 

especially if multiple sites are to be abated. An alternative is to pre-qualify potential contractors 

through a modified RFP or a request for qualifications (RFQ) process. In such a process, contractors 

Photo courtesy of Brian Wright, Georgia DNR
Section 4: Contractors 25

submit detailed qualifications once, and the top three to six contractors are selected and pre-qualified 

for a 3- to 4-year period. As projects arise, the pre-qualified contractors are invited to submit cost 

proposals identifying only costs, schedules, and any significant changes in capabilities and procedures 

since the original RFQ response. The contractor selection is then made based primarily on cost. 

Under this approach, the bidding process for a site is simple and quick, and qualified contractors are 

consistently used. 

The Florida Department of Environmental Protection has used a pre-qualification process successfully 

since 1989. The process is repeated every 3 to 4 years in order to allow for changes in industry 

participants. Illinois conducts a similar pre-qualification process in which contractor responses 

include binding cost data presented on a price per ton basis. When a site is identified for abatement, 

a contractor is selected based on the site’s proximity to the contractor’s processing facility. The lack of 

individual site bidding does not result in significantly higher abatement costs. Illinois has used its prequalification process for over 10 years to handle a high volume of cleanup projects.

CONTRACTS

The form of an abatement contract depends on the bidding and award procedures used as well as state 

contracting requirements. Such contracts generally fall into two main categories:

• Individual site contracts created solely to cover specified abatement activities associated with an 

individual or conjoined stockpile. These contracts typically cover awards made based on singlesite RFP responses.

• Task assignment contracts created to cover general conditions associated with stockpile 

abatement activities. Such contracts are supplemented by task assignment documents covering 

specific site conditions as awards are made. This type of contract is generally used in cases 

where contractor pre-qualification is conducted. A general task assignment contract is executed 

with each pre-qualified contractor, and then task assignments are issued for individual sites as 

appropriate. This process requires broader initial contracting work but expedites individual site 

assignments and the resulting abatement.

Each state has its own contracting procedures and language requirements, so it is not possible to 

provide a ‘model’ contract. However, example basic contract documents are available at http://www.

epa.gov/reg5rcra/wptdiv/solidwaste/tires/guidance/index.htm.

BONDING AND INSURANCE

The primary purpose of bonding and insurance requirements is to protect the contracting agency from 

financial loss as a result of contractor error or failure to perform. A secondary purpose is to ensure that 

a contractor has adequate resources and is committed to successful project completion.

Historically, contracting agencies have required bonding or other financial assurance equivalent to 

50 to 100 percent of a project’s estimated cost. In addition, a bond typically remains in force until 

the contracting agency confirms final project completion and releases the bond. When bonds were 

relatively easy and inexpensive to obtain, the bonding requirement was not normally a hardship except 

for companies with poor operating statements or balance sheets.

Recently, however, it has become more difficult and expensive for smaller companies (including many 

successful contractors) to obtain bonds. Some companies have resorted to alternative methods such 

as letters of credit or cash deposits. In some cases, large financial assurance requirements can be 

burdensome for contractors, as they tie up working capital resources needed to execute contracts. In 

other cases, such requirements may exclude successful contractors from competing. Iowa and Virginia 

have no financial assurance requirements and have not experienced any contractor failures, but these 

states have a long history of successful contractor performance. Florida recently decreased its bonding 

requirements from 100 percent to 50 percent of contract awards. The cost of bonds is ultimately paid 

by the contracting agency, as the cost is factored into bid prices. 
Section 4: Contractors 26

It is a challenge to balance actual financial assurance needs against the burden placed on prospective 

contractors. The actual contracting agency loss incurred because of contractor failure is normally the 

expense of repeating the bidding and award process plus the difference between old and new costs. A 

financial assurance requirement of 10 to 25 percent provides adequate loss protection without placing 

an undue burden on a contractor. The lower requirement is appropriate for mature programs with 

proven contractors, and the higher requirement is appropriate for new programs with no contractor 

performance history.

Insurance requirements typically consist of 

comprehensive general liability insurance to protect 

the contracting agency in the event of contractor error, 

worker injury, or site damage. Most states require a 

minimum of $1 million of coverage, which does not 

normally present a hardship for contractors.

CAPACITY ASSESSMENT

The tire processing industry and product markets have 

a finite capacity to process and use current-generation 

tires and tires from stockpile abatement. Abatement 

objectives should be determined in the context of local 

and regional capacity to avoid disrupting the market.

If economic imbalances are identified, corrective measures can be initiated. For instance, if the capacity 

of local or regional processors is limited, they can be made aware of anticipated tire volumes and may 

choose to increase their capacity. If not, mobile processors that may not be operating at capacity can 

be solicited from a broader geographic area. If markets are limited, others can be created through 

agency cooperation or incentives. For example, the New York State DOT considers use of tire chips 

from stockpile abatement for embankment projects if the chips have a lower delivered cost than other 

aggregate alternatives. If economic imbalances are not correctable, program objectives should be 

adjusted to reflect realistic tire volumes or to allow tire disposal in order to avoid market disruption.

On a smaller scale, assessing a contractor’s processing and marketing capability to absorb stockpiled 

tires without disrupting use of current-generation tires can be a reality check on contractor projections. 

Identification of processing capacity should be based on the historically demonstrated performance of 

similar equipment, not on equipment supplier claims.

Photo courtesy of Jana White, South Carolina DHEC
Section 5: Project Management 27

SECTION 5 Project Management

The preceding sections provide the foundation and considerations for establishing a successful 

scrap tire abatement program. However, once abatement projects are underway, a whole new set of 

issues must be considered. This section discusses factors that will enhance project management and 

implementation.

SITE SURVEY

Prior to site mobilization, a review or survey of the property boundaries should be completed to verify 

that all tires and planned access routes are located on that property. Often tire piles extend across 

property lines. In such cases, written property access agreements with neighboring property owners 

will be needed. 

EQUIPMENT

Proper equipment selection depends on site conditions, and unique site conditions may require 

specialized equipment or safety procedures. For instance, a tracked excavator is an efficient, highvolume tire retrieval tool if the following conditions exist:

• Open-top trailers can be moved adjacent to the stockpile for direct loading, minimizing 

excavator movement. If the ground is too unstable for truck access, a loader can cover longer 

tire transport distances more efficiently.

• Boom movement is not impaired by large trees or other obstacles such as power lines. Where 

obstacles prevent free boom movement from pile to trailer, a loader may be safer.

• The stockpile is deep, but the top is reachable. An excavator minimizes the risk of pile collapse 

onto equipment and operators, making it the safest alternative for deep piles.

• Contaminating metal objects are large enough to be seen and separated prior to loading. Cars 

and other large objects can be separated, but rims and smaller objects may be inadvertently 

loaded.

• The bucket is closed above ground level to minimize soil entrapment. If the bucket is dropped 

to ground level before it closes, it will trap soil and debris.

Photo courtesy of Jim Waldron, Tri-Rinse, Inc.
Section 5: Project Management 28

In some cases, smaller equipment such as a loader or tracked bobcat can be more efficient and 

inexpensive than an excavator. For instance, an excavator loses many of its advantages if tires are 

simply being staged for loading into enclosed trailers. A bobcat can easily place tires in the end of a 

trailer. Most experienced contractors understand efficient use of equipment and manpower. 

Changing site conditions can alter equipment needs during a project, and contractors need latitude 

to make adjustments provided that the schedule and safety are not compromised and no increased 

contamination or site damage results. If any of these problems occur, the contracting agency should 

increase its monitoring and guidance efforts until the problems are resolved.

In addition to normal retrieval and hauling equipment, on-site utilities such as portable sanitary 

facilities may be required. Electricity, telephone, and water service and an enclosed work area may also 

be desirable at sites during extended operations or inclement weather conditions.

TRANSPORTATION

Registration and Permitting. Many states require processor and hauler registration. All necessary 

registrations and permits should be obtained ahead of time to avoid unnecessary delays. Contractors 

have been cited for transportation violations by the same agency that contracted with them for removal 

activities.

Weighing. Load weight can change during transport. Trapped water can drain during tire movement, 

or rain can add weight if water is trapped in exposed tire casings. In other cases, tires may be added 

to trailers in transit. If possible, trailers should be weighed at a pre-approved scale near the abatement 

site and again at the receiving site. The lesser of the two weights should be used for invoicing. Florida 

has used this approach for all sites with little inconvenience to contractors. Ohio requires submittal of 

computerized weight scale receipts providing the loaded truck weight and the empty truck weight for 

each load taken to an approved facility.

Rims. Rims can double the transport weight 

of passenger tires. Removing rims prior to 

transport will reduce transport and processing 

charges based on weight. If rim removal is 

not feasible, a tracking and weight adjustment 

method should be established, especially for 

sites such as salvage yards that have high 

percentages of rimmed tires. When tires are 

de-rimmed, both the scrap metal rims and the 

tire-balancing lead weights removed provide a 

source of revenue. The contract terms should 

clearly state whether the contractor retains this 

revenue, shares the revenue with the agency, 

or submits all the revenue to the agency. The 

Scrap Tire Removal Under Unique Site Conditions in Ohio

During 2004, over 1 million tires were removed from a strip mine site in Ohio. The tires covered 

the high wall and were submerged and compacted in the 19-foot-deep strip pit. Also in Ohio, 

buried tires and tire fire residuals were removed from a site where a major fire involving 400,000 

scrap tires had occurred. EPA emergency response contractors had extinguished the fire at this 

site by bulldozing approximately 3 feet of clay over the burning tires to form a temporary cap. The 

removal contractor had to implement procedures to minimize further soil contamination as the fire 

residuals were removed.

Photo courtesy of Ethan Mayeu, Mississippi DEQ
Section 5: Project Management 29

contractor incurs additional expenses in removing and processing the rims from tires, so the contractor 

should be reimbursed in some manner.

Rail Transport. Transportation of shredded tires in bottom-dump railcars can be problematic because 

of chip compaction and rainwater freezing. The chips become difficult to dump at the receiving site. 

Side-dump and arm-dump railcars generally do not have this problem. However, rain- and snowfrozen TDF sent by rail from a southern abatement site to a northern utility prevented dumping and 

forced loaded railcars to be staged until the spring thaw.

Monitoring Logs. Good records of tare and loaded weights must be kept for all vehicles and unit 

numbers must be noted on weigh slips to avoid discrepancies that can delay invoice payments.

ENVIRONMENTAL FACTORS

Water. Water can create serious problems at a stockpile site. Storm water can accumulate in low spots, 

impeding equipment movement and operating efficiency. In addition, stockpiled tires spill trapped 

water during retrieval and handling, creating unstable soil at the site. These problems can be resolved 

by creating drainage channels or constructing elevated paths for equipment. Another alternative is to 

rotate work areas in order to allow wet, unstable areas to dry. As unstable ground is exposed under 

piles, silty runoff can drain from the property to adjacent streams, ponds, and properties. Where such 

runoff occurs, silt fences commonly used at construction sites must be constructed. As a mosquito 

control practice, Ohio requires that ruts and holes be filled with soil or drained so that standing water 

does not remain for longer than 7 days after a rainfall; otherwise, the contractor must sample the area 

and treat it with a mosquito larvicide.

Roadways. Heavy truck movement can destroy dirt roadways at sites during wet or thaw periods. If 

such roadways are used by area residents, the road surface must be kept passable for normal vehicles.

Dust. During dry conditions, equipment movement on unstable soil and roadways can generate dust 

plumes. If airborne dust impacts abatement operations, on-site personnel, or adjacent properties, water 

spraying can be used for dust control. 

Noise. Tractor-trailers, heavy retrieval equipment, and on-site shredders are noisy. In populated areas, 

abatement operations can be limited to daylight hours in order to control noise impacts on nearby 

residents. Local residents are normally grateful for stockpile removal and tolerant of temporary noise 

and inconvenience.

SECURITY

The primary objectives of site security are to prevent addition of tires to a site, prevent fires, and 

protect equipment. The security measures discussed below have been effective in accomplishing these 

objectives.

Vehicle Access Control. The most common 

approach for vehicle access control is a locked chain 

extending between secure posts. The chain can be 

removed for inspection or abatement activities, and 

most emergency response vehicles carry lock cutters 

in the event that they require access to a secured 

location. A cut lock or broken chain would indicate 

the need for other measures. Ditches and earthen 

berms have also been used to control vehicle access, 

especially if they enhance drainage or runoff control.

Fencing. Preventing all vehicle and pedestrian 

access to a site is difficult, but casual access can be 

controlled by fencing. Chain-link fencing and gates Photo courtesy of Jana White, South Carolina DHEC
Section 5: Project Management 30

may already be present at industrial sites. In some cases, a fence along a visible front boundary is 

enough to discourage intruders. However, a rural site often has multiple entrance points, so the entire 

perimeter should be checked for signs of unauthorized activity. A fence is most cost-effective in urban 

areas where nighttime equipment protection is critical. Fences can be rented or purchased depending 

on the duration of site operations.

Lighting. Lighting increases the probability of observing intruders but is only effective when 

combined with security guards. Otherwise, lighting just attracts attention and facilitates vehicle access 

to the site.

Security Guards. Security guards can control site access and provide an early warning in the event 

that a fire occurs. To be effective, guards must have adequate lighting and must patrol the site in spite 

of mosquitoes and adverse weather conditions. Punch clocks are commonly used to ensure adequate 

guard coverage. An electric cart can be used to increase the patrol range on larger sites while allowing 

quiet movement. Guards have a broad range of training and capabilities. Guards with little training 

can be acceptable in low-risk cases provided that they are well prepared for actual emergencies 

by being given detailed instructions and communications equipment. In other cases, trained law 

enforcement officers are appropriate. In one high-risk case in Florida involving a landowner with 

multiple felony convictions, sheriff deputies served as security guards and arrested three people with 

outstanding felony warrants who were visiting the landowner during the first two weeks of operation. 

Additional Measures. Guard dogs can deter intruders at fenced sites, but dogs raise liability issues 

and can be injured by loose wire at processing sites. Motion detectors have been considered for 

sites, but animal movement in rural areas triggers false alarms. Cameras have been used at sites 

but generally fail to provide adequate picture quality to support the capture or arrest of an intruder. 

Smoke detectors and heat sensors have been considered for fire detection, but the associated expenses 

and logistics are problematic for abatement sites.

Even the best security measures serve only as deterrents and will not necessarily stop a determined 

arsonist, saboteur, or thief. Security guards were patrolling a Hagersville, Ontario, site when its 10 

million tires were ignited by teenagers. Equipment was sabotaged at an inner-city site in Florida in 

spite of fencing, lighting, and security guards. A security guard started a fire at a Texas processing site 

to ensure continued employment. Fires have been started by objects thrown over fences. However, 

there is no way to know how many mishaps have been prevented by appropriate security and site 

management.

SAFETY

The use of heavy equipment and shredders at an abatement site poses risks for on-site personnel. 

These risks are similar to those encountered at processing facilities but are increased by the less 

structured equipment paths, outdoor conditions, and uneven or unstable terrain at a site. Ohio requires 

abatement contractors to prepare and implement site-specific health and safety, emergency response, 

and fire prevention and response plans for 

state-funded abatement projects. One specific 

requirement is to have at least one contractor 

employee with a current American Red Cross 

or equivalent certificate of CPR and first 

aid training at the site during all operating 

hours. Additional safety considerations are 

discussed below.

Mosquitoes. Container-breeding mosquitoes 

thrive in the warm, protected, stagnant water 

contained in tires. In addition to being a 

nuisance, these insects serve as vectors for 

potentially fatal diseases in humans, such as Photo courtesy of James Gathany, CDC
Section 5: Project Management 31

West Nile virus, eastern equine encephalitis, and dengue fever. Measures should be taken to control 

on-site worker exposure to mosquitoes, especially during active breeding seasons in areas prone 

to these diseases. Exposure control measures include (1) wearing long-sleeved shirts and pants to 

minimize exposed skin, (2) using insect repellent, and (3) spraying sites to control adult and larvae 

populations. At most scrap tire remediation sites during warm weather months, Ohio often takes 

an additional step to prevent the spread of West Nile virus and other mosquito-borne diseases. The 

state requires contractors or licensed application firms to conduct thermofogging and apply granular 

insecticides in order to prevent mosquito larvae in the tires from being transported to other sites. Tires 

removed from cleanup sites should be processed immediately and not stored whole at another site to 

minimize spreading of mosquitoes because of the presence of mosquito eggs or larvae in the tires.

Snakes and Other Wildlife. Tire stockpiles host snakes 

and small mammals such as rats, opossum, skunks, and 

raccoons. Although they generally flee when heavy 

equipment disturbs a pile, they continue to pose a risk 

to site workers and nearby residents. Some measures 

that have been used to address this risk include 

(1) installing screened cages on retrieval equipment 

to protect operators from snakes dropping from tires 

during retrieval; (2) requiring workers to wear heavy 

gloves, long sleeves, pants, and boots to protect against 

animal bites and scratches; (3) identifying the nearest 

emergency medical facilities capable of treating bites 

and other injuries; and (4) installing silt fences to divert escaping snakes from adjacent populated areas, 

especially those containing children. The risk posed by snakes does not stop at the site. One contractor 

claims that over 50 snakes escaped from tires in trailers that were mechanically loaded at a Florida site 

and transported to a processing facility.

FIRE PLANNING AND PREVENTION

The greatest risk associated with scrap tire stockpiles is their possible ignition. Once ignited, stockpile 

fires tend to spread rapidly, generating massive quantities of smoke, oil, and contaminated water that 

cause environmental damage. Factors associated with stockpile fire planning and prevention are 

discussed below.

Owner or Operator Role. Many stockpile fires involving arson start during enforcement proceedings 

or initial abatement activities, indicating that the landowner may be seeking revenge or attempting to 

avoid cost recovery associated with abatement. Unfortunately, the remediation costs and repercussions 

after a fire far outweigh the abatement costs. As a general rule, it is five to ten times more expensive 

to remediate a fire site than to simply remove the tires. In addition, large tire fires typically involve 

federal emergency response agencies, thereby adding investigation and legal expenditures to cost 

recovery efforts. Enforcement officials should clearly communicate the personal benefits of fire 

prevention to the site owner or operator.

Emergency Response Plan. An emergency response plan should be developed for a large stockpile 

site to support coordinated notification and response in the event of a tire fire. Each responding agency 

should have a clear understanding of the resources available and the plan for their optimum use. 

Each local fire department typically has an outline of specific subjects that should be addressed in an 

emergency response plan.

Initial Site Stabilization. Large stockpile sites should be stabilized to decrease the possibility of a 

tire fire and to increase the odds of controlling a fire. Stabilization can be initiated by a site owner as 

part of a compliance agreement or by a contractor during initial abatement activities. Important site 

stabilization activities include the following:

Photo courtesy of U.S. Fish and Wildlife Service
Section 5: Project Management 32

• Removal of trees, brush, and grass around stockpiles to avoid fire transmission to and from 

surrounding areas, especially if the site is inactive

• Identification of available fire control resources and installation of supplemental fire control 

tools

• Creation of at least two connected access points for emergency vehicles 

• Creation of fire lanes that are at least 50 feet wide to divide a large stockpile into isolated 

segments. The initial lane should roughly bisect the pile, and subsequent lanes should result in 

pile segments that are no larger than 50 by 200 feet in size. Pile sides should be tapered to avoid 

collapse during fire turbulence.

• Stabilization of central fire lanes to facilitate emergency response vehicle access and to 

maximize contractor efficiency during subsequent abatement activities

Site Abatement. During site abatement, alternate pile segments should be sequentially removed to 

increase the separation between remaining segments. In some cases, piles near roadways or fences are 

removed early in the abatement to prevent tire ignition by thrown objects as well as to show abatement 

progress.

Shred Auto-Ignition. Deep stockpiles of compacted 

tire shreds can undergo a progressive series of 

exothermic reactions that increase pile temperatures 

and pyrolytically generate combustible gases. Surface 

symptoms of this phenomenon can be subtle, such as a 

slight sulfur odor, vapor steaming from isolated sections 

of the pile surface, or a slight oil sheen on adjacent 

standing water after rainfall. Auto-ignition normally 

occurs in stockpiles that are more than 10 feet deep 

and that have been compacted by movement of heavy 

equipment during their formation. The phenomenon 

has occurred in shreds of all sizes but is more common in 

smaller shred sizes. 

The potential consequence of auto-ignition is that surface fires can ignite on a shred stockpile, 

especially as the pile is abated. As shreds are removed from the area near the hot zone, gases and 

shreds are exposed to air and ignite. The fire then spreads across the pile as though it was started on 

the surface. This has happened in more than 20 stockpiles and monofills. A sign of this phenomenon 

is an area of melted rubber shaped like a mushroom cap within the pile. Care should be taken during 

abatement of deep, compacted shred piles, and steps should be taken to immediately control autoignited shred fires before they can spread.

The Rubber Manufacturers Association offers “Guidelines for the Prevention and Management of Scrap 

Tire Fires” (available at http://www.rma.org), which provides a foundation for fire prevention and 

management at stockpile sites. The California Integrated Waste Management Board has also prepared 

a document titled “Tire Pile Fires: Prevention, Response, Remediation” that is available at http://osfm.

fire.ca.gov/pdf/regulations/TPFReportFinal.pdf. Some of the document is specific to California 

conditions and does not necessarily have universal applicability.

COMMUNICATION

Successful abatement of a stockpile site depends on good communication between the contractor 

and contracting agency. Both efficiency and mutual respect are acquired from experience, which is 

critical to successful tire abatement projects and programs. On-site monitoring and invoicing are also 

important elements of communication, as discussed below.

Photo courtesy of Todd Thalhamer, California IWMB
Section 5: Project Management 33

Contractor and Agency Communication. Abatement plans and schedules are working documents that 

are subject to change based on factors such as weather, equipment breakdowns, and market conditions. 

Good communication between the contractor and contracting agency provides a foundation for 

appropriate adjustments. The contractor can provide a weekly, biweekly, or monthly written progress 

report describing tire quantities removed, adherence to the schedule, obstacles, adjustments, and 

anticipated future activities; progress reports may also be made verbally at the agency’s discretion. 

The contractor should also report all unexpected site conditions to the agency as they are discovered, 

particularly conditions such as the presence of (1) items other than tires in the piles and (2) pits and 

ravines under piles that will increase the total PTE at the site. These previously unknown conditions 

need to be documented with photographs that can serve as a basis for possible contract changes and 

cost recovery actions. In addition, contractor and agency personnel should be readily accessible for 

quick resolution of on-site issues as they arise. 

On-Site Monitoring. Performance monitoring is a balance of economics, need, availability, and 

experience. States have used full-time monitors, facilitated daily visits by local officials, reviewed logs 

kept by security or contractor personnel, and conducted unannounced site visits and record audits. 

Minimum monitoring generally involves daily telephone discussions, two to five site visits per week by 

local agency or law enforcement personnel, and periodic unannounced site visits.

Invoices. The contractor should submit monthly invoices with all supporting documentation. This 

procedure allows problems to be identified early and limits the magnitude of invoice preparation and 

review time. Delayed invoicing can increase review time and delay invoice payment.

SITE RESTORATION

Abatement Completion. The issue of abatement completion is subject to interpretation when tires are 

buried on a site. In general, large pockets of tires are removed but individual tires are left in place if 

less than 25 percent of the tire extends above the surface. In cases involving tire shreds, some states 

require the contractor to use a 2-inch rake harrow to gather and remove surface shreds.

Other Wastes. Other waste materials present in tire stockpiles are normally separated and placed in 

piles. In some cases, wastes are segregated to facilitate subsequent recovery (for example, of metals) 

or disposal efforts. A contractor’s responsibility for other wastes should be clearly defined in the 

initial scope description. The contractor should receive supplemental compensation for waste-related 

activities outside the scope.

Site Restoration Case Study: Fort Wayne, Indiana

In Fort Wayne, Indiana, a former oil pump manufacturing and warehouse site was used to store 

600,000 scrap tires by a company that went bankrupt. While the city was working with the state 

to remove the tires, a tire fire began that burned for 3 days over Labor Day weekend of 1997 (see 

http://www.abanet.org/statelocal/lawnews/223helmke.html). After the fire, approximately 3,200 

cubic yards of soil required removal from the site because of contamination from previous site 

activities and the tire fire; charred structures and underground tanks from years of manufacturing 

also required removal. After cleanup, 20 new homes were constructed on the site and it became a 

thriving community. This case illustrates how scrap tire piles can suddenly catch fire and how the 

fire can increase the amount of work and associated costs required to restore a site. Nonetheless, it 

is possible to revitalize sites after tire fires as productive land.
Section 5: Project Management 34

Grading. A site can be deeply rutted by heavy 

equipment during abatement activities. The contractor 

is generally required to restore a relatively smooth 

surface corresponding to the original site contour.

Roadways. Public dirt roadways rutted by heavily 

laden trucks during abatement activities are generally 

graded at the completion of on-site activities. County 

road crews are often assigned to do this grading at little 

or no cost as a show of cooperation. Access roadways 

constructed to facilitate the abatement are sometimes 

removed.

Erosion Control. Seeding and drainage channels can 

control erosion of unstabilized surface soil. Silt screens or similar methods are used to control site 

runoff to adjacent surface waters until vegetation is re-established.

Documentation. Post-abatement site conditions should be thoroughly documented by means of 

photographs or video recordings of ground conditions, residual piles, buildings, and fences. The 

documentation should be retained to aid in resolution any subsequent problems or issues.

Photo courtesy of Mel Pins, Iowa DNR
Section 6: Summary 35

SECTION 6 Summary

Many states have successfully cleaned up scrap tire stockpiles and established programs to prevent 

future stockpile formation. Much can be learned from the successes and failures of the wide array of 

strategies used to address this serious problem. This guidebook represents the first nationwide effort 

to capture and share the collective knowledge of state and industry representatives with decades of 

experience in stockpile abatement (see Acknowledgements).

Many states have proven that the threats to human health and the environment posed by uncontrolled 

and illegal scrap tire stockpiles can be mitigated through thoughtful application of regulatory policy 

and available resources along with careful planning and execution of cleanup projects. The past 

experience of state and federal authorities has also clearly demonstrated that the costs of stockpile 

prevention and abatement are small fractions of the costs associated with emergency response and 

remediation activities necessitated by tire fires.

This guidebook outlines all the essential elements that need to be considered when planning and 

implementing abatement programs and individual cleanup projects. After decades of catastrophic tire 

fires and other health-related impacts of illegal scrap tire piles, it is clear that the practices described in 

this guidebook need to be followed in order to adequately protect human health and the environment.

In addition to this guidebook, many resources are available to those who are working to deal with the 

scrap tire problem, including state regulator forums, workshops, seminars, international conferences, 

trade associations, and journals. See http://www.epa.gov/epaoswer/non-hw/muncpl/tires/rel_links.htm

for links to these resources.

Photo courtesy of Todd Thalhamer, California IWMB
Section 7: Resources 36

SECTION 7 Resources

Scrap Tires – General Information

U.S. EPA. “Management of Scrap Tires.” On-Line Address: http://www.epa.gov/epaoswer/non-hw/

muncpl/tires/index.htm

Scrap Tire Fires – Analysis of Ambient Air Data

U.S. Environmental Protection Agency (EPA) Office of Air Quality. 1993. “Analysis of Ambient Air 

Data in the Vicinity of Open Tire Fires.” On-Line Address: http://www.epa.gov/ttn/atw/burn/

tireburning1993.pdf

Scrap Tire Fires - Characterization of Emissions

DeMarini, D.M., and P.M. Lemieux. 1992. “Mutagenicity of Emissions from the Simulated Open 

Burning of Scrap Rubber Tires.” U.S. EPA Document No. EPA-600/SR-92-127. July.

Lemieux, P.M., and J.V. Ryan. “Characterization of Air Pollutants Emitted from a Simulated Scrap Tire 

Fire.” U.S. EPA Document No. EPA/600/s2-89-054. On-Line Address: http://nepis.epa.gov

U.S. EPA. “Field Study to Characterize Dioxin Emissions from Uncontrolled Combustion and NonCombustion Area Sources. On-Line Address: http://cfpub1.epa.gov/ncea/cfm/recordisplay.

cfm?deid=55184

U.S. EPA National Risk Management Research Laboratory. 1997. “Air Emissions from Scrap Tire 

Combustion.” U.S. EPA Document No. EPA/600/SR-97/115. By Joel I. Reisman. Cincinnati, 

OH. On-Line Address: http://permanent.access.gpo.gov/websites/epagov/www.epa.gov/ORD/

WebPubs/projsum/600sr97115.pdf

U.S. EPA Office of Research and Development. 1997.“ Air Emissions from Scrap Tire Combustion.” 

U.S. EPA Document No. EPA-600/R-97-115. Washington DC. On-Line Address: http://www.epa.

gov/ttn/catc/dir1/tire_eng.pdf

Scrap Tire Fires - Prevention and Management

Rubber Manufactures Association. 2000. “The Prevention & Management of Scrap Tire Fires.” 

Washington DC. On-Line Address: http://rma.org/scrap_tires/scrap_tires_and_the_environment/

fire_prevention.pdf

West Nile Virus

U.S. Department of Health and Human Services. 2003. “Epidemic/Epizootic West Nile Virus in the 

United States: Guidelines for Surveillance, Prevention, and Control.” On-Line Address: http://

www.cdc.gov/ncidod/dvbid/westnile/resources/wnv-guidelines-aug-2003.pdf
Appendix: Stockpile Characterization Form

APPENDIX

Stockpile

Characterization

Form