Materials Characterization Paper 

In Support of the 

Final Rulemaking: 

Identification of Nonhazardous Secondary Materials That Are Solid Waste 

Scrap Tires

February 3, 2011

=============================================================== 

1. Definition of Scrap Tires 

Scrap tires are used tires that can no longer be utilized as tires, or that contain 

defects that make them unusable on vehicles. 

2. Annual Quantities of Scrap Tires Generated and Used 

(1) Sectors that generate scrap tires: Scrap tires are generated from the 

replacement of tires on passenger and commercial vehicles. 

• The majority of scrap tires, 85 percent, come from passenger vehicles and 

light duty trucks. The remaining 15 percent comes from larger vehicles 

such as heavy duty trucks and buses (RMA 2009). 

• Many scrap tires are sent to processors where they are shredded and then 

sent to end users such as: plants using tire-derived fuel; civil engineering 

projects (e.g., construction sites for landfills, septic tank leach fields, or 

roads); and crumb rubber plants where they may be recycled into other 

products (Virginia Department of Environmental Quality 2008). Other 

tires are used whole, either in civil engineering or similar projects, or as a 

fuel. 

(2) Quantities of Scrap Tires Generated: Consumers and industry in the 

United States generated 4.6 million tons of tires in 2007, or an estimated 

303.2 million scrap tires (RMA 2009). Of these tires, roughly 13 percent 

were landfilled. These landfilled tires are “wasted,” with their resource value 

being lost to society. Exhibit 1 provides a brief overview of the generation 

and use of scrap tires in 2005 and 2007 (except for the total annual quantity 

generated, 2007 figures are available only in terms of weight). Exhibit 2 

provides more detailed information on the uses of scrap tires from 1990 

through 2007. 

Public comments received from the Institute of Scrap Recycling Industries 

state that in 2009 the U.S. generated roughly 300 million scrap tires (Scrap 

Tire & Rubber 2010 Users Directory, as cited in Wagger (2010)). 
Scrap Tires 

2

Exhibit 1: Overview of Generation and Use for 2005 and 2007 

Commodity 

Annual Quantity 

Generated 

Annual Quantity 

Used as Fuel 

Annual Quantity 

Land Disposed 

Annual Quantity 

Diverted to Other 

Uses1

Total Quantity 

Stockpiled as 

 of 2005/2007 

Scrap Tires 

(2005)2

299.6 million tires 

4.4 million tons 

155.1 million tires 

2.1 million tons 

177 facilities 

42.42 million tires 

0.6 million tons 

104.1 million tires 

1.5 million tons 

188.0 million tires 

2.9 million tons 

Scrap Tires 

(2007)3

4.6 million tons 

303.2 million tires 2.5 million tons 0.6 million tons 1.5 million tons 128.4 million tires 

Sources:

Data for 2005 are from RMA 2006, and data for 2007 are from RMA 2009. 

Notes:

1. The quantity diverted to other uses includes roughly 0.1 million tons of exported tires in both 2005 and 2007.. 

2. Of the 4.4 million tons of tires generated in 2005, the Rubber Manufacturers Association (RMA) has accounted for 

how 4.2 million tons were managed. RMA was unable to determine how the remaining 0.2 million tons were 

managed. 

3. In its 2009 report, RMA states that, henceforth, it will include only weight-based figures in its published market 

data. This reflects the evolution of data reporting within the industry. Historically, RMA presented scrap tire data 

in units, consistent with the first major report on scrap tire management completed by EPA. However, some 

governments and tire industry organizations present data in terms of weight, and the EPA Resource Conservation 

Challenge Tire Workgroup has recommended use of weight-based data. RMA states that this full conversion is 

necessary for consistency and precision of data, though it will make comparisons to previous years challenging. 

However, RMA still reports the quantity stockpiled in numbers of tires, because stockpile estimates continue to be 

given in units. 

Exhibit 2: Summary of Scrap Tire Uses from 1990 to 2007 

Millions of Tires Used 

Scrap Tire Use 1990 1992 1994 1996 1998 2001 2003 2005 20071

Tires Used as fuel (whole 

and shredded) 24.5 57.0 101.0 115.0 114.0 115.0 129.7 155.1 179.6

Cement Kilns 6.0 7.0 37.0 34.0 38.0 53.0 53.0 58.0 48.4

Pulp/paper Mills 13.0 14.0 27.0 26.0 20.0 19.0 26.0 39.0 77.1

Industrial Boilers 0.0 6.0 10.0 16.0 15.0 11.0 17.0 21.0 14.5

Utility Boilers 1.0 15.0 12.0 23.0 25.0 18.0 23.7 27.0 24.9

Non-Fuel Uses 0.0 11.0 37.5 49.5 63.5 103.0 103.6 104.0 94.9

Civil Engineering N/A 5.0 9.0 10.0 20.0 40.0 56.4 49.2 43.1

Ground Rubber 0.0 5.0 1.5 7.5 7.0 21.0 18.2 30.1 43.0

Export 0.0 0.0 12.5 15.0 15.0 15.0 9 6.9 6.3

Cut/Punched/Stamped N/A N/A 8.0 8.0 8.0 8.0 6.5 6.1 0.1

Miscellaneous/Agriculture N/A 1.0 3.5 4.0 5.5 7.0 3.0 3.0 0.5

Electric Arc Furnaces N/A N/A N/A N/A N/A N/A 0.5 1.3 1.9

Rubber Modified Asphalt2 N/A N/A 3.0 5.0 8.0 12.0 10.0 7.4 -

Scrap Tires in Stockpiles 1000.0 1,000.0 800.0 500.0 400.0 300.0 275.0 188.0 128.4

Sources:

Data for 1990 through 2005 are from RMA 2006, and data for 2007 are from RMA 2009. 

Notes:

1. RMA 2009 includes figures only in weight for 2005 and 2007, as well as percent change between 2005 and 2007. 

To approximate 2007 figures in terms of the quantity of tires, in order to demonstrate how various uses have 

changed over time, we applied the percent change in weight between 2005 and 2007 to the 2005 quantity figures. 

However, the 2007 stockpile figure was given in quantity of tires. 

2. Rubber modified asphalt was not separated out as a category in RMA 2009. 

3. The tire derived fuel (TDF) total includes dedicated tires to energy. 
Scrap Tires 

3

(3) Trends in Generation: 

• Scrap tire generation increased by 36 percent from 1990 to 2007, while 

the amount reused or recycled increased from 11 percent in 1990 to 89 

percent in 2007 (RMA 2009). This reflects a major accomplishment in 

effective materials management. 

• During this same period, the number of tires in stockpiles declined by 

more than 87 percent, from 1 billion to 128 million (RMA 2009). 

• The use of tires for fuel has increased from 24.5 million tires in 1990 to 

roughly 179.6 million tires in 2007 (RMA 2009).1

 The Rubber 

Manufacturers Association (RMA) suggests that the use of tires as a fuel 

source will likely continue and may increase as the cost of conventional 

fossil fuels increases (RMA 2006).

• The U.S. economy affects both the demand for and supply of scrap tires. 

During the recent economic recession, the U.S. saw a 15 to 20 percent 

decline in replacement tire sales, which, in turn, reduced the number of 

scrap tires generated. The TDF markets contracted by 17 percent 

nationwide from 2007 to 2009, however, because supply had shrunk so 

drastically, demand for scrap tires was higher than available supply in 

some areas of the country (RMA 2010). 

• The combustor survey database developed by EPA for the 2009 proposal 

of the Commercial and Industrial Solid Waste Incinerator (CISWI) 

standards and the Industrial Boilers Maximum Achievable Control 

Technology (MACT) standards indicates that the sources surveyed for 

these rules annually combust 599,000 tons of scrap tires2

 (EPA 2009). 

• States have contributed to the increased use of scrap tires as a fuel and for 

other purposes by regulating scrap tires and by working with the public 

and private sectors to improve the management of scrap tires to minimize 

landfilling, stockpiling, and illegal dumping (EPA 2007). Exhibit 3 

demonstrates that stockpiles have been depleted despite increased 

generation, while Exhibit 4 illustrates the increasing rate of 

reuse/recycling of scrap tires.

 1 We approximated this 2007 figure of numbers of tires used as fuel by applying the percent 

change in weight of tires used for fuel between 2005 and 2007 (RMA 2009) to the 2005 quantity figure. 

2

 Although we report scrap tire data from the combustion database as a tonnage, the database 

includes material quantities expressed in terms of heating values (Btu). To express this information as a 

tonnage, we assumed that scrap tires have a heating value of 14,000 Btu per pound, which is the midpoint 

of the 12,000 to 16,000 Btu/lb range referenced below from the North Carolina Division of Pollution 

Prevention and Environmental Assistance. 
Scrap Tires 

4

Exhibit 3: Changes in Scrap Tire Generation and Stockpile Depletion

Scrap Tire Generation Compared to the Number of Scrap 

Tires in Stockpiles

0

100

200

300

400

500

600

700

800

900

1000

1100

1990 1992 1994 1996 1998 2001 2003 2005 2007

Year

# of Tires (Millions)

Scrap Tire

Generation

Scrap Tires in

Stockpiles

Data from RMA 2009

Exhibit 4: Changes in Scrap Tire Generation and Reuse/Recycling

Scrap Tire Generation Compared to the Number of Scrap 

Tires Recycled or Recovered

0

50

100

150

200

250

300

350

1990 1992 1994 1996 1998 2001 2003 2005 2007

Year

# of Tires (Millions)

Scrap Tire

Generation

Scrap Tires

Recycled or

Recovered

Data from RMA 2009. We approximated the number of scrap tires recycled or 

recovered in 2007 by applying the reported percentage recycled or recovered in 2007 to 

the reported generation of scrap tires for 2007. 

3. Uses of Scrap Tires 

(1) Combustion Uses of Scrap Tires: 

A major use of scrap tires is as fuel, either in whole form or as tire-derived 

fuel (TDF). The southeast is currently the strongest market for use of scrap 

tires as fuel (Blumenthal 2009a). Whole tires are frequently used as fuel in 

cement kilns, and the reinforcing steel within tires provides an additional 

benefit (Gray 2009). Otherwise, use of whole tires is limited by whether they 
Scrap Tires 

5

are compatible with the combustion and handling characteristics of 

individual combustion units (EPA 2008c, Gray 2009). TDF is defined by 

ASTM as scrap tires that have been shredded and processed into rubber chips 

according to product standards. The use of TDF in combustion units is 

typically limited to blends of less than 30 percent of total energy input due to 

the high rates of heat release and the low moisture content of TDF. Thus, 

TDF is often used as a supplementary fuel in combustors to complement 

other fuel sources such as coal and biomass (ASTM 2006). 

• Pulp and paper manufacturers accounted for 43 percent of the fuel use of 

TDF, by weight, in the United States in 2007. Other users include 

cement manufacturers (27 percent of fuel use), electric utilities (14 

percent of fuel use), industrial boilers (8 percent of fuel use), and 

dedicated tire-to-energy facilities (8 percent of fuel use). These figures 

represent a shift since 2005, when cement manufacturers accounted for 

37 percent of use and pulp and paper manufacturers accounted for 25 

percent. From 2005 to 2007, use of TDF by pulp and paper 

manufacturers increased by 98 percent (RMA 2009). The reduction in 

market demand for TDF in cement kilns can be attributed to the 

following factors: (1) increased market demand for processed TDF chips 

by the pulp and paper industry, which garner a higher return on 

investment for the scrap tire processor and (2) significantly lower 

nationwide demand for cement due to the economic downturn and 

resulting decrease in building and construction (RMA 2009). 

• Currently, a total of 66 cement kilns (at 43 cement production facilities) 

burn tires as fuel in the United States. Only ten of these kilns burn 

shredded tires; the remaining 56 kilns burn whole tires (Blumenthal 

2009a). 

• Data on the precise breakdown between shredded tires and whole scrap 

tires in the scrap tire fuel market are not readily available. However, 

based on data from RMA (2009) and Blumenthal (2009a), EPA estimates 

that shredded tires make up 69 percent of the market and whole tires 

make up 31 percent. 

As indicated in Exhibit 2, RMA (2009) divides the scrap tire fuel market 

across different user industries. The RMA (2009) document also 

suggests that cement kilns and dedicated tire-to-energy plants are the 

main consumers of whole tires. To estimate the segmentation of the 

market, EPA therefore assumed that all other facilities burn shredded 

tires. In addition, based on RMA (2009), EPA assumed that dedicated 

tire-to-energy facilities burn whole tires exclusively and that cement kilns 

burn both whole tires and shredded tires. To distribute cement kiln tire 

use between whole tires and shredded tires, EPA relied upon data 

provided by Blumenthal (2009a) on the number of cement kilns that burn 
Scrap Tires 

6

whole tires and the number that burn shredded tires. EPA assumed that 

the breakdown between whole tires and shredded tires among cement 

kilns is proportional to the percentage of kilns that burn whole tires and 

the percentage that burn shredded tires. 

• As of the end of 2007, there were 123 facilities permitted to use tirederived fuel in the U.S. (RMA 2009). Exhibit 5 presents the 3-digit 

NAICS codes for these facilities. Appendix 1 includes basic identifying 

information for each facility in the U.S. known to be utilizing TDF. 

• The use of scrap tires as fuel accounts for roughly 53 percent of the 

beneficial use of scrap tires, as indicated in Exhibit 6. 

• As shown in Exhibit 7, the use of tires as fuel has increased significantly 

since 1990. RMA indicates that the increased use of tires as fuel is likely 

due to increased energy prices for conventional fossil fuels and 

improvements in tire processing (RMA 2006). 

Exhibit 5: NAICS Codes for Facilities Using Tire-Derived Fuel 

NAICS NAICS Title Count1

327 Nonmetallic Mineral Product Manufacturing2 44 

221 Utilities 22 

322 Paper Manufacturing 32 

562 Waste Management and Remediation Services 8 

Various Other Industrial Boilers 17 

Source:

RMA 2009 

U.S. Census Bureau 2007 

Notes:

1. The values presented here are based on information in Chapter 3 of RMA 

2009. Appendix C of RMA 2009, however, includes slightly different values. 

2. This sector includes cement kilns, a major user of TDF discussed throughout 

this paper. 

(2) Non-Combustion Scrap Tire Uses: Although energy recovery is the most 

common use of scrap tires, there are many non-fuel uses for scrap tires 

including the following:

• Agriculture/Miscellaneous (i.e., erosion control) 

• Civil Engineering (i.e., construction of landfills and roads)

• Cut/Punched/Stamped into other products (e.g., floor mats) 

• Electric Arc Furnaces (i.e., these units combust tires to utilize energy 

value and to incorporate carbon and steel into new steel products) 

• Ground Rubber (e.g., synthetic sports field turf)

• Rubber Modified Asphalt (RMA 2006)
Scrap Tires 

7

Exhibit 6: Use of Scrap Tires in 2007

 Source: RMA 2009. 

• Similar to the increased use of scrap tires as a fuel source, the beneficial 

use of scrap tires in non-combustion applications has increased 

significantly between 1990 and 2001, and currently, a high percentage of 

truck tires are diverted into ground rubber applications (Blumenthal 

2009a). Since 2001, however, the amount of scrap tires used for noncombustion applications has been fairly constant, whereas the amount 

used as fuel has continued to increase. This trend reflects the high fuel 

value of tires. The increased acceptance of tires as a legitimate fuel led to 

success in reduction of tire piles. With the increase in fuel prices since 

2001, beneficial use of tires as fuel has become a more attractive 

management option than other beneficial use applications.

• Cooperation from state agencies is crucial to the growth and development 

of non-combustion applications of scrap tires. For example, despite 

Rubber Modified Asphalt’s potential to absorb large amounts of scrap 

tires (one highway lane absorbs approximately 1,000 scrap tires), 

reluctance on the part of state transportation agencies due to cost and 

performance concerns has hindered its growth as a market (Frye 2009; 

RMA 2009; Gray 2009). 
Scrap Tires 

8

Exhibit 7: Trends in the use of Scrap Tires from 1990 – 2007 

0

50

100

150

200

250

300

1990 1992 1994 1996 1998 2001 2003 2005 2007

Year

# of Tires (Millions)

Rubber Modified Asphalt

Electric Arc Furnaces

Miscellaneous/Agriculture

Cut/Punched/Stamped

Export

Ground Rubber

Civil Engineering

Tires Used for Tire Derived

Fuel

Data from RMA 2009. We approximated 2007 figures in terms of the quantity of tires, 

in order to demonstrate how various uses have changed over time, by applying the percent 

change in weight between 2005 and 2007 to the 2005 quantity figures 

(3) Quantities of Scrap Tires Landfilled: The number of tires landfilled has 

slowly declined as the use of TDF and other applications for tires has 

increased. This trend reflects an important environmental accomplishment. 

Despite efforts to minimize the number of tires sent to landfills, tires are still 

landfilled because of the high cost of hauling tires to a processing facility in 

some areas (i.e., landfilling is often the least costly management option), or if 

they are in too poor of condition to be suitable for beneficial use applications. 

This reflects a significant waste of resources. In general, the placement of 

whole tires in above-ground landfills is discouraged due to their large size, 

flammability, and potential to harbor mosquitoes. As an alternative, scrap 

tires may be placed in an underground monofill (RMA 2006). While EPA 

considers monofill disposal preferable to traditional above-ground tire piles, 

these are also a clear waste of valuable resources (EPA 2007).

(4) Quantities of Scrap Tires Stockpiled/Stored: Stockpiles of tires have been 

steadily decreasing as a result of state efforts to eliminate “tire piles.” States 

are typically responsible for regulating scrap tires, and each state, with the 

exceptions of Alaska and Delaware, has developed laws and requirements to 

address scrap tire concerns. While some states focus mostly on the 

management of scrap tires as they are generated, others have also developed 

programs to address existing tire stockpiles (EPA 2007). The majority of 

current stockpiles are located in seven states: Alabama, Arizona, Colorado, 

Massachusetts, Michigan, New York, and Texas (RMA 2009). As indicated 

in Exhibit 2, the number of tires in stockpiles has fallen by over 87 percent 

since 1990. Most states, like EPA, encourage the use of tires as fuel. Some 
Scrap Tires 

9

states have formally determined, under state law, that combustion of tires is 

not related to waste management, but is actually a beneficial use of resources.

4. Management and Combustion Processes for Tire-Derived Fuel 

(1) Types of Units Combusting Tires as Fuel: Tires are combusted as fuel in a 

variety of applications, including in boilers and kilns (RMA 2006). They can 

be used to supplement and/or replace a wide range of fuels including coal, 

coke, and wood, but coal is the fuel for comparison under the rule and can 

replace only a unit designed to burn coal under this rule. Although many 

combustion units were not designed to burn tires, many are able to use tires 

as a supplement to conventional fuels (ASTM 2006). According to 

comments submitted to EPA by the Cement Kiln Recycling Coalition, TDF 

is most commonly paired with coal (CKRC 2010). 

(2) Supply/Processing Chain for Tires Used as Fuel: While scrap tires are 

generated from many different sources, they are generally consolidated at 

key collection points (e.g., tire retailers, automotive repair shops, and fleets) 

through well-established channels before being shipped to processing 

facilities and end users. Exhibit 8 summarizes the processing chain for scrap 

tires used as TDF. An additional source for scrap tires is historical tire piles. 

Furthermore, some tire processors send TDF to end-users indirectly, through 

brokerage firms (Sorcher 2009).

Exhibit 8: Typical Process for Recovering Tires for Tire-Derived Fuel

Source: Texas Commission on Environmental Quality 2008 

Notes: 1

 In some cases, combustion devices accept whole tires, which can 

provide environmental advantages over chipped tires (e.g., energy 

savings from avoided chipping). 

Scrap tires are removed from passenger vehicles and trucks. 

Tires that are no longer usable on vehicles are collected at 

retailers, fleets, etc. until they are ready for transport. 

Tires are transported to processing facilities. 

Tires are chipped/shredded and made into TDF.1

 TDF is sent to a combustion facility. 
Scrap Tires 

10

(3) Processing Scrap Tires for Fuel Applications: 

 Scrap tires are often processed through two physical processing steps: 

chipping/ shredding and metal removal. Shredded tires used as fuel consist 

of chipped tires ranging in size from 1 to 4 inches; the amount of metal in 

this material varies depending on how much the tires have been processed. 

This processing step is beneficial for many combustion units because it 

minimizes the metals content of the tires and improves heating efficiency. 

However, shredding tires to the smaller particle size required to remove 

metals increases processing costs (Gray 2009). The price of TDF therefore 

increases with smaller particle sizes conducive to metal removal (ASTM 

2006, Gray 2009).3 Tire processors can sort their material by metal content 

and charge higher prices for material with 90 percent of the metal wire 

removed (Gray 2004). 

Some units such as cement kilns do not require the removal of wire because 

their processes are hot enough to oxidize the wire. Also, the metals provide a 

positive value in the process as a substitute for raw materials, and 

considerable energy is saved by not chipping tires. Furthermore, some argue 

that the combustion characteristics of tires (and the emissions produced) are 

improved when combusted whole in certain combustion devices (e.g., cement 

kilns). Currently, there are at least five states whose scrap tire programs 

divert whole tires for use as fuel in cement kilns: Alabama, California, 

Oklahoma, Pennsylvania, and Texas (Blumenthal 2009a). 

 In addition to chipping/shredding and metal removal, some TDF producers 

are experimenting with pyrolysis, but it has not become commercially 

successful due to high capital costs associated with processing equipment and 

the relatively low value of the outputs produced, especially the solid char 

product (CIWMB 1992, Gray 2009).4

 

Because the specifications for TDF are somewhat user specific, the ASTM 

has not issued recommended specifications for TDF or the processing of 

scrap tires for use as TDF. 

While newly generated scrap tires can typically be processed for TDF 

applications, many tires in tire piles are in such poor condition that they 

cannot be processed and used as TDF. When tires from large stockpiles are 

processed, it is usually onsite at the stockpile itself; to avoid the degradation 

of processors’ primary equipment, stockpile tires are not shipped to 

processors’ main facilities (Blumenthal 2009b). Besides landfill or monofill 

 3

 The extraction of metals from tires can also cause deterioration of shredding equipment, which 

adds further to processing costs (Grantham 2009). 

4

 To a lesser extent, there has been some experimentation with the use of cryogenics to shatter 

scrap tires into TDF chips, but an established industry for the use of cryogenics in the production of TDF 

has not yet developed (CIWMB 1992; Sorcher 2009). 
Scrap Tires 

11

disposal, the only other notable potential uses of these tires are in cement 

kilns and civil engineering applications (Gray 2009, RMA 2006). 

(4) Amount of Processed TDF Chips or Whole Tires Expected to Qualify as 

Non-Waste under the Final Rule: 

Far less than 10% of the tires that are used every year for fuel are expected to 

be classified as waste under the final rule. 

(a) The majority of unit types that use a tires as a replacement 

fuel for coal, use the processed TDF chips that are expected to 

qualify as non-waste under the final rule per §241.3(b)(2)(i). (See 

the final rule for details on the criteria for processed scrap tires.) 

(b) Over 90% of the tires used as fuel are handled in tire 

collection programs. In addition, the vast majority of tires are 

“annually generated” from tire and auto shops. (RMA comments, 

2010). EPA anticipates that those will qualify as non-waste per 

§241.3(b)(4) in the final rule. “Annually generated tires” that are 

no longer useable as vehicle tires and are distributed from tire and 

auto shops are assumed to be from non-discarded sources. 

(5) Recognition of Value in Using this Alternate Fuel – by Regional, State, 

and Academic Parties:

The Resource Conservation Challenge (RCC) Scrap Tire Workgroup5

 has 

two goals related to scrap tires: 

(a) To manage 85 percent of scrap tires through reuse, recycling, 

and energy recovery by 2008; that goal was met and was followed 

with “increase by 5% the amount of newly generated scrap tire 

tonnages diverted to beneficial re-use, including ground/crumb 

rubber recycling, tire-derived fuel and civil engineering uses, 

compared to the 2009 amount, based on RMA data” (by 2012). 

(b) By 2012, reduce the number of stockpiled tires by 65% using 

the 2003 amount as the base year. 

To help meet these goals, the RCC workgroup has developed subcommittees 

to target different applications in order to make progress, one of which is the 

Tire-Derived Fuel Subcommittee, which is striving to support the expanded 

 5

 The Scrap Tire Workgroup contributes to the overall goals of Resource Conservation Challenge 

(RCC), a multi faceted initiative implemented by USEPA with three overarching goals: 1. to prevent 

pollution and promote recycling and reuse of materials; 2. to reduce the use of toxic chemicals; and 3. to 

conserve energy and materials. The Scrap Tire Workgroup of the RCC works on various issues related to 

scrap tire management and markets. The workgroup consists of over 50 representatives from various state 

environmental agencies, industry, trade groups, EPA and academia with expertise in scrap tire 

management, market development, and application technologies. 
Scrap Tires 

12

and appropriate use of scrap tires as a supplemental energy resource in 

properly permitted industrial facilities (RMA 2006). 

 

(6) State Status of Scrap Tire Used as Fuel: 

According to state responses to a 2006 survey by the Association of State and 

Territorial Solid Waste Management Officials (ASTSWMO), the following 

states have approved the use of scrap tires as fuel on at least one occasion: 

Maryland, Pennsylvania, Kentucky, Maine, and North Dakota. This use does 

not appear to have pre-approved status, however, suggesting that a case-bycase approval process for designation of beneficial use is in place in these 

states (ASTSWMO 2007). According to ASTSWMO, the following states 

have given pre-approved beneficial use determinations to the use of scrap 

tires as fuel: Indiana, Iowa, North Carolina, and Virginia. In addition, RMA 

data indicate that TDF has been approved for use in facilities in 34 states 

(RMA 2009). 

5. Scrap Tire and TDF Composition and Impacts 

(1) Composition of Tires Used as Fuel:

Tires have a high energy content ranging from 12,000 – 16,000 Btus per 

pound. This is higher than coal, the replacement fuel. 

The Btu Values of tires and a number of other fuels are as follows: 

• Tires: 12,000 – 16,000 Btu/pound (North Carolina Division of Pollution 

Prevention and Environmental Assistance (NCDPPEA)) 

• Coal: 11,000 - 13,000 Btu/pound (NCDPPEA and EIA 2005) 
Scrap Tires 

13

Exhibit 9 summarizes the constituents in tire-derived fuel. In order to 

compare the constituents to the traditional fuel, refer to the values for coal, 

the comparable traditional fuel that it displaces.6

Exhibit 9: Constituents in TDF and Coal 

CONSTITUENTS CONCENTRATIONS (Parts Per Million by Weight)

Range of TDF Values

ASTM 

(2006)1 TDF - PCA Data2

Cadmium 6 <5 

Calcium 3,780 3,780 

Chlorine 1,490 Non-detect - 1,490 

Mercury3 - - 

Nitrogen 2,700 - 

Sulfur 19,200 - 

ELEMENTS IN METAL STEEL FROM TIRE BELTS; NOT EXPECTED TO BE RELEASED TO EMISSIONS IN A 

CONVENTIONAL BOILER4

Chromium 97 <5 

Lead 65 51 

Manganese <100 - 

ELEMENTS NOT ON LISTS FOR 

CAA 112(b) HAP OR CAA 129 (a) (4) POLLUTANTS 

Fluoride 10 - 

Iron5 3,210 295 

Zinc6 15,200 21,400 

Sources:

1. ASTM (2006), note, Gray (2004) agreed with these ASTM data and provided the additional data for 

manganese. 

2. Data cited in Portland Cement Association (2010). 

3. Other commenters noted that mercury can be present at levels similar to values in low mercury coals. 

4. The concentration of metals in the wire (98.5 percent of the wire is iron) from processed TDF chips is 

comparable to those in coal. The iron and other components of the wire are not expected to be released to 

emissions in a typical boiler. Rather, the wire ends up in the bottom ash. According to one commenter, 

the metal can be recovered. 

5. Iron is the main component of the steel wire and is also not expected to be liberated in emissions as the 

others described in footnote 4. 

6. Data cited in Portland Cement Association (2010) mentioned that data available from the USGS 

database showed that some coal samples can have much higher concentrations of zinc. The commenter 

said the coal sample was 51,000 ppm zinc. 

 

6

 TDF replaces coal, but it usually replaces a percentage of it since TDF is typically mixed with coal when 

used as fuel. Refer to the coal estimates for the range of values listed in the Material Characterization 

Paper for traditional fuels. Coal has many more constituents in that are not in TDF. 
Scrap Tires 

14

(2) Impact Information

• Cost Savings of Beneficial Use Applications: The net cost savings 

associated with the beneficial use of scrap tires (i.e., the cost savings 

realized less the costs associated with beneficial use) are a function of (1) 

avoided disposal costs, (2) fuel (or other input) savings associated with 

the beneficial use of this material, and (3) processing (e.g., shredding) 

and other costs associated with beneficial use.7

 Exhibit 10 summarizes 

readily available information on these variables. Based on this 

information, it is not possible to generate a single estimate of the net cost 

savings or benefits associated with the beneficial use of scrap tires. As 

suggested by the exhibit, avoided disposal costs depend on the location of 

disposal. In addition, cost savings can vary depending on the whether 

tires are shredded or whole. For example, although tires have high fuel 

value, a limited number of state programs pay cement kilns to receive 

whole tires at their facilities; one source estimates that kilns are paid 

between five and fifteen cents per tire (Blumenthal 2009), while another 

source estimates that kilns are paid up to twenty-five cents per tire (Gray 

2009). However, some kilns take whole tires for free, and all boilers and 

kilns pay for shredded tires (Blumenthal 2009a). Information is not 

readily available on the costs of processing tires for beneficial use 

applications. 

Exhibit 10: Summary Economic Savings and Costs of Scrap Tire Beneficial Use 

Savings 

Avoided Disposal Costs 

Whole tires are banned from being disposed in landfills in the vast majority of states, and some states 

allow tires that are not whole (example quartered tires) to be landfilled. 

Tip fees associated with landfill disposal vary by location and depend on the size of the tire. Example tip 

fees reported by local waste management authorities in California, Pennsylvania, and Virginia are as 

follows: 

California: $68 per ton (California Integrated Waste Management Board) 

Centre County, Pennsylvania: $66 per ton (Centre County Solid Waste Authority, 2003) 

Page County, Virginia: $155 per ton (Page County, 2008) 

Fuel or Material Cost Savings 

The fuel and material costs savings associated with beneficial use depend on the value of the fuel or input 

for which scrap tires serve as a substitute. The average cost of various fuels for which scrap tires are a 

substitute are as follows (2007 prices unless otherwise noted):1

• Coal – Average Delivered Price in 2006: $2.23 / MMBtu (EIA 2007, Table ES1) 

 7 With respect to the costs associated with beneficial use, cement kiln operators are generally 

required to enact performance testing and air permit modifications prior to using scrap tires and other 

alternative fuels. In addition, kilns may be required to install continuous emissions monitoring systems if 

they chose to burn scrap tires (EPA 2008a).
Scrap Tires 

15

Costs 

Processing and Other Costs of Beneficial Use

Information on the costs of scrap tire beneficial use applications is not readily available. One source 

estimates the price of shredded tires to be approximately 150% of that of whole tires due to additional 

processing (U.S. EPA 1991).

Notes:

1. To express these values as dollars per MMBtu, the following thermal conversion factors were used: 

22,473,000 Btu per short ton of coal (EIA 2005, Tables A1, A4, and A5). 

End-users running different combustion units will be willing to pay 

different prices based on the kind of fuel that is being replaced by TDF. 

For example, cement kilns often substitute TDF for low-grade coals, 

which are a relatively low-cost fuel. This translates into a lower 

willingness to pay. End-users substituting TDF for high-grade coal are 

more likely to pay higher prices for TDF. However, the relationship 

between the level of processing needed, operational efficiency, and 

willingness to pay of an end-user also depends on the specific 

combustion unit and cannot be generalized across an industry (Sorcher 

2009). 

• Greenhouse Gas Emissions: Data compiled by the Greenhouse Gas 

Protocol, suggests that the greenhouse gas emissions rate associated with 

the combustion of scrap tires is approximately 0.09 metric tons of carbon 

dioxide equivalents (MTCO2E) per million Btu (MMBtu) of scrap tires 

combusted (GHG Protocol, 2005).8

 By comparison, based on emissions 

and energy data compiled by EPA, the GHG emissions rates for coal, 

natural gas, distillate oil, and residual oil are approximately 0.094 

MTCO2E per MMBtu, 0.053 MTCO2E per MMBtu, 0.073 MTCO2E per 

MMBtu, and 0.079, MTCO2E per MMBtu, respectively (EPA 2008b). 

These estimates do not include upstream emissions impacts (e.g., from 

the extraction and transport of virgin materials), which are presented 

below in Exhibit 14. 

• Criteria Pollutants and Hazardous Air Pollutants: Although numerous 

studies have been conducted on the criteria pollutant and hazardous air 

pollutant (HAP) emissions associated with tire-derived fuel, most of these 

studies examine fuels that are a combination of scrap tires and 

conventional fuels. Therefore, these studies do not isolate the criteria 

pollutant or HAP emissions associated with scrap tires alone. 

Although existing studies do not include sufficient data to isolate the 

emissions associated with scrap tires alone, it is possible to reach a few 

 8

 This figure is derived from data presented in units of kilograms per gigajoule (kg/GJ). To 

convert the data into units of metric tonnes (MT) per million Btu (MMBtu), we divide 0.947817 MMBtu 

per GJ and divide again by 1,000 kg per metric tonne. The result is about 0.09 metric tonnes per MMBtu: 

(85 kg⁄GJ) / (0.947817 MMBtu⁄GJ) / (1000kg⁄MT) = 0.08968 MTCO2E/MMBtu.
Scrap Tires 

16

general conclusions based on the results of these studies. For example, 

emissions test data compiled by EPA in 1997 suggest that substituting 

scrap tires for coal in electric utility boilers may lead to reductions in 

NOx and particulate matter emissions but show no clear pattern for SOx

emissions (EPA 1997). The same study also examined the emissions 

impacts associated with tire combustion at several other types of facilities 

(e.g., pulp and paper mills, cement kilns, and industrial boilers) that use a 

variety of different fuels. In addition, a 2004 paper by Gray includes 

information on the emissions impact of TDF at six sample facilities. 

Based on this paper and the 1997 EPA study, Exhibit 11 indicates 

whether the use of tires as a fuel at each facility type may lead to a 

reduction or an increase in emissions. The available studies on emissions 

related to tires as fuel examine only a limited number of emissions 

sources, and it is unclear whether these sources are representative of the 

combustion units that may use tires. Note that at well-controlled facilities 

that use coal, the comparable fuel, emissions will not change significantly 

when tires are used.9

 

Relative to criteria pollutants, historical EPA and test program data 

demonstrate that, while emission rates vary over different TDF levels at 

different facilities, criteria pollutant emissions from combusting TDF 

have been found a majority of the time to be reduced or not very much 

different than those from other conventional fossil fuels, provided 

combustion occurs in a well-designed, well-operated and well-maintained 

combustion device. In fact, results from a dedicated tires-to-energy 

(100% TDF) facility indicate that it is possible to have emissions much 

lower than those produced by existing solid-fuel-fired boilers (especially 

when comparing on a heat input basis) with a specially designed 

combustor and add-on controls.10 That said, little data exists for coal 

burning devices that could supplement their fuel for TDF where the 

devices are not well-designed (e.g., small kilns, small incinerators). 

Thus, owners/operators should consider the composition of tires relative 

to design of the combustion device to be used, the adequacy of its 

existing air pollution control devices (APCDs) and the operating 

conditions to be used in recovering energy from TDF and consider 

making whatever processing steps, feed rate and system improvements. 

 9

 EPA notes that its 1997 study was a laboratory test program (not full-scale) that assessed 

controlled burning of TDF in a Rotary Kiln Incinerator Simulator (RKIS). While the study concluded 

that, with the exception of zinc emissions, potential emissions from TDF are not expected to be very much 

different than from other conventional fossil fuels, it noted “as long as combustion occurs in a welldesigned, well-operated, and well-maintained combustion device." 

10 See, for example, Reisman JI (1997) Air Emissions from Scrap Tire Combustion, Appendix: Emissions 

Data from Controlled Tire Burning. Technical Report prepared for USEPA. Office of Research and Development, 

Washington, DC EPA 1997 at http://www.epa.gov/ttn/catc/dir1/tire_eng.pdf
Scrap Tires 

17

We further note that variation in emissions could be attributable to factors 

other than the use of tires itself (such as variations in air pollution control 

device efficiency and the coal it is mixed with).

In comments submitted to EPA in response to the proposed rule, CKRC 

(2010) provided data suggesting that annual NOx and SO2 emissions at 

one cement facility would increase by 24.2 tons and 1.4 tons, 

respectively, if it stopped burning TDF and substituted it with coal. 

These figures assume that no additional controls would be installed to 

control NOx and SO2 emissions. 

Exhibit 11: Emissions Impact of Using Tires as a Substitute for Conventional Fuels, 

by Pollutant and Combustor Type 

NOx PM SO2 Zinc 

Utility boilers Reduction Reduction Data inconclusive Data inconclusive 

Industrial boilers Reduction Reduction Data inconclusive Increase 

Pulp & paper mills Reduction or similar Increase Increase Increase 

Cement kilns Data inconclusive Reduction Reduction Data inconclusive 

Sources: 

The information presented in this exhibit is based on emissions data in EPA 1997 and Gray 2004.

Notes: 

1. “Reduction” indicates that emissions test data suggest that the use of TDF as a fuel will reduce 

emissions. “Increase” indicates that emissions may increase, and “similar” indicates that emissions 

are unlikely to change. “Data inconclusive” indicates that the available emissions data show no 

clear pattern with respect to the emission impact of using TDF as a substitute for conventional fuel. 

• Upstream Emissions Impacts: Use of tires as a replacement for fossil 

fuels may eliminate the environmental impacts associated with extraction 

and processing of the traditional fuels.11 Exhibit 12 lists the quantities of 

cradle-to-gate emissions for these fuels based on typical processes in the 

United States in the late 1990s. The generation of scrap tires generally 

creates minimal emissions. Of course, there are impacts associated with 

the shredding of scrap tires into TDF, and these are not accounted for in 

Exhibit 12. 

• Other Impacts: In addition to the impacts outlined above, the beneficial 

use of scrap tires limits, and in some cases prevents, the growth of scrap 

tire stockpiles. This could result in improvements to human health and 

the environment because such stockpiles provide habitat for disease 

 11 Cement kilns report that the environmental and cost savings are greater overall 

when energy is not expended to shred tires. Also, the steel in tires is an important raw 

material in cement manufacturing needed to make clinker. 
Scrap Tires 

18

vectors (such as mosquitoes and rodents), and because they can catch 

fire, uncontrolled, this can contaminate air, water and soils.

Exhibit 12: Emissions from Extraction and Processing of Traditional Fuels 

(TDF is the replacement fuel for coal, not the other traditional fuels listed) 

Pollutant Coal 

Distillate 

Fuel Oil 

Residual 

Fuel Oil Wood 

Natural 

Gas 

---------------------------- Lb./MMBtu ----------------------

Criteria Pollutants 

PM2.5 - - - - - 

PM10 - - - - - 

PM, unspecified 0.246 0.012 0.012 6.67x10-4 0.004 

NOx 0.022 0.061 0.062 0.08 0.117 

VOCs 0.008 0.361 0.365 - 0.515 

SOx 0.022 0.186 0.187 0.003 1.913 

CO 0.017 0.046 0.046 0.022 0.223 

Pb 2.60x10-7 1.01x10-6 1.00x10-6 - 2.72x10-7

Hg 8.17x10-8 1.87x10-7 1.87x10-7 - 7.18x10-8

Greenhouse Gases 

CO2 3.9 19 19.1 - 15.3 

CH4 0.451 0.029 0.029 - 0.369 

N2O 1.63x10-5 2.01x10-5 2.07x10-5 - 1.17x10-5

MTCO2E/MMBtu 0.006 0.009 0.009 - 0.01 

Source:

Franklin Associates 1998. 

Notes:

“-” signifies data not available; may equal zero. 

The emission information presented in this table is derived from Life Cycle Inventory (LCI) data, 

as compiled by Franklin Associates. LCI data identifies and quantifies resource inputs, energy 

requirements, and releases to the air, water, and land for each step in the manufacture of a product 

or process, from the extraction of the raw materials to ultimate disposal. The LCI can be used to 

identify those system components or life cycle steps that are the main contributors to 

environmental burdens such as energy use, solid waste, and atmospheric and waterborne 

emissions. Uncertainty in an LCI is due to the cumulative effects of input uncertainties and data 

variability. 

There are several life cycle inventory databases available in the U.S. and Europe. For this paper, 

we applied the most readily available LCI database that was most consistent with the materials and 

uses examined. These LCI data rely on system boundaries as defined by Franklin Associates, as 

described in the documentation for this database, available at: 

http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf. 
Scrap Tires 

19

References 

ASTM International. 2006, “Standard Practice for Use of Scrap Tire-Derived Fuel”. 

Blumenthal, Michael. 2009a, Personal Communication with Lyn Luben, U.S. EPA, July 9, 2009. 

Blumenthal, Michael. 2009b, Personal Communication with Jason Price, Industrial Economics, July 21, 

2009. 

Association of State and Territorial Solid Waste Management Officials (ASTSWMO), 2006 Beneficial 

Use Study Report, November 2007. 

California Integrated Waste Management Board, “Solid Waste Facility Tipping Fees: 1998 to 2000 

Summaries of 

Special Waste Tipping Fee Surveys”, accessed August 28, 2008 at: 

http://www.ciwmb.ca.gov/landfills/TipFees/SumSW.htm

California Integrated Waste Management Board, “Tires as a Fuel Supplement: Feasibility Study”, January 

1992, accessed June 18, 2009 at: http://www.ciwmb.ca.gov/Publications/default.asp?pubid=90

Cement Kiln Recycling Coalition. 2010. Comment to EPA on the Proposed Rule for the Identification of 

Non-hazardous Secondary Materials that are Solid Waste, Docket/document number EPA-HQRCRA-2008-0329-1034, August 3, 2010. 

Centre County Solid Waste Authority. 2003, “Tipping Fees”, accessed August 27, 2008 at: 

http://www.centrecountyrecycles.com/Recycle/RefuseTippingFees/RefuseTippingFees.html. 

Franklin Associates. 1998, “Franklin US LCI 98 Library”. 

Frye, Neal. 2009, Entech, Incorporated. Personal Communication. July 3, 2009. 

GHG Protocol (the Greenhouse Gas Protocol Initiative). 2005, “CO2 Emissions from the Production of 

Cement (CSI)”, accessed on August 21, 2008 at: http://www.ghgprotocol.org/calculationtools/cement-sector. 

Gray, Terry. 2004, “Tire Derived Fuel: Environmental Characteristics and Performance”. 

Gray, Terry. 2009, TAG Resource Recovery. Personal Communication. August 24, 2009. 

Grantham, Dewey. 2009, Liberty Tire Recycling, Inc. Personal Communication. May 26, 2009. 

North Carolina Division of Pollution Prevention and Environmental Assistance, “Tire Derived Fuel”, 

accessed August 20, 2008 at: http://www.p2pays.org/ref/11/10504/html/usa/tdf.htm. 

Page County, “Landfill, Compactor, & Recycling Sites”, accessed August 27, 2008 at 

http://pagecounty.virginia.gov/index.php?option=content&task=view&id=163. 

Portland Cement Association. 2010. Comment to EPA on the Proposed Rule for the Identification of Nonhazardous Secondary Materials that are Solid Waste, Docket/document number EPA-HQ-RCRA2008-0329-1138-1143, August 3, 2010. 

Rubber Manufacturers Association (RMA), “Scrap Tire Characteristics”, accessed August 21, 2008 at: 

http://www.rma.org/scrap_tires/scrap_tire_markets/scrap_tire_characteristics/ 
Scrap Tires 

20

Rubber Manufacturers Association (RMA). 2006, “Scrap Tire Markets in the United States”. 2005 

Edition. 

Rubber Manufacturers Association (RMA). 2009, “Scrap Tire Markets in the United States”. 9th Biennial 

Report. 

Rubber Manufacturers Association (RMA). 2010. Comment to EPA on the Proposed Rule for the 

Identification of Non-hazardous Secondary Materials that are Solid Waste, Docket/document 

number EPA-HQ-RCRA-2008-0329-1166, August 3, 2010. 

Sorcher, Michael. 2009, M.A. Associates, Inc. Personal Communication. May 27, 2009. 

Texas Commission on Environmental Quality. 2008, “Scrap Tires”, accessed August 21, 2008 at: 

http://www.tceq.state.tx.us/compliance/tires/index.html#gen. 

United States Census Bureau, “2007 NAICS Codes and Titles”, accessed August 21, 2008 at: 

http://www.census.gov/naics/2007/NAICOD07.HTM U.S. 

United States Energy Information Administration (EIA). 2007, Annual Coal Report 2006. 

United States Energy Information Administration (EIA). 2005, Annual Energy Review 2004.

United States Energy Information Administration (EIA). July 2008a, “Natural Gas Monthly”. 

United States Energy Information Administration (EIA). June 2008b, Preliminary Petroleum Marketing 

Annual 2007. 

United States Environmental Protection Agency (EPA). 1991, “Markets for Scrap Tires” 

United States Environmental Protection Agency (EPA). 1997, “Air Emissions from Scrap Tire 

Combustion”. 

United States Environmental Protection Agency (EPA). 1998, “Development of Comparable Fuels 

Specifications”. 

United States Environmental Protection Agency (EPA). 2007, “Basic Information”, accessed August 20, 

2008 at: http://www.epa.gov/epaoswer/non-hw/muncpl/tires/basic.htm. 

United States Environmental Protection Agency (EPA). 2008a, Cement Sector Trends in Beneficial Use 

of Alternative Fuels and Raw Materials, October 2008. 

United States Environmental Protection Agency (EPA). 2008b, Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990-2006: Annex 2 Methodology and Data for Estimating CO2 Emissions 

from Fossil Fuel Combustion. 

United States Environmental Protection Agency (EPA). 2008c, “Tire Derived Fuel”, accessed August 20, 

2008 at: http://www.epa.gov/epaoswer/non-hw/muncpl/tires/tdf.htm. 

United States Environmental Protection Agency (EPA). 2008d, “Updated 2006 Kiln List Received 

8_25_2008”, internal EPA document provided by EPA on August 25, 2008. 

United States Environmental Protection Agency (EPA). 2009, Combustor survey database in support of 

the 2009 proposal of the Commercial and Industrial Solid Waste Incinerator (CISWI) standards and 

the Industrial Boilers Maximum Achievable Control Technology (MACT) standards, April 2009. 
Scrap Tires 

21

United States Environmental Protection Agency (EPA). 2010, Preliminary Characterization Study: 

Traditional Fuels and Key Derivatives, Prepared in Support of the Final Rulemaking – 

Identification of Nonhazardous Secondary Materials That Are Solid Waste. Docket Number 

EPA-HQ-RCRA-2008-0329. December 2010. 

Virginia Department of Environmental Quality. 2008, “Regional Collection and Processing Projects”, 

accessed August 21, 2008 at: http://www.deq.virginia.gov/wastetires/progsummary2.html. 

Wagger, David L. 2010. Comment to EPA on the Proposed Rule for the Identification of Non-hazardous 

Secondary Materials that are Solid Waste, submitted on behalf of the Institute of Scrap Recycling 

Industries (ISRI), Docket/document number EPA-HQ-RCRA-2008-0329-1186, August 3, 2010. 
Scrap Tires 

22

Appendix 1: Summary of Facilities Using Tires as Fuel

State Location Company Type of Facility 

Alabama Calera Lafarge North America Cement kiln 

Alabama Courtland International Paper Corp. Pulp & paper mill 

Alabama Theodore Holcim Inc. Cement kiln 

Alabama Leeds Lehigh Cement Company Cement Kiln 

Alabama Ragland National Cement Cement kiln 

Alabama Stevenson Smurfit-Stone Pulp & paper mill 

Alabama Demopolis CEMEX Cement kiln 

Arkansas Foreman Ash Grove Cement Company Cement kiln 

Arkansas Crossett Georgia Pacific Pulp & paper mill 

Arkansas Ashdown Domtar, Inc. Pulp & paper mill 

Arkansas Pine Bluff International Paper Pulp & paper mill 

California Colton California Portland Cement Cement kiln 

California Victorville CEMEX Cement kiln 

California Redding Lehigh Southwest Cement kiln 

California Stockton Stockton Co-generation Industrial boiler 

California Lucerne Valley Mitsubishi Cement Cement kiln 

California Lebec National Cement Co. of CA Cement kiln 

California Kern County Mt. Posco Cogeneration Industrial boiler 

Colorado Florence Holcim, Inc. Cement kiln 

Connecticut Sterling Exeter Energy Dedicated tire-toenergy 

Florida Auburndale Wheelabrator Ridge Generating Station Utility boiler 

Florida Brooksville CEMEX Cement kiln 

Florida Brooksville Rinker Materials Cement kiln 

Florida Gainesville Florida Rock Cement kiln 

Florida Across the state Names not supplied Waste-to-energy (8) 

Florida Confidential Pulp & paper mill 

Georgia Clinchfield CEMEX Cement kiln 

Georgia Brunswick Georgia Pacific Pulp & paper mill 

Georgia Rome Temple Inland-Rome Pulp & paper mill 

Georgia Riceborough Interstate Paper Pulp & paper mill 

Georgia Dublin SP Newsprint Pulp & paper mill 

Georgia Cedar Springs Georgia Pacific Pulp & paper mill 

Hawaii Oahu AES Hawaii, Inc. Industrial boiler 

Idaho Inkom Ash Grove Cement Company Cement kiln 

Idaho Boise Boise P&N LLC (Boise Cascade) Pulp & paper mill 

Illinois Decatur Archer Daniels Midland (ADM) Industrial boiler 

Illinois Oglesby Buzzi Unichem USA Cement kiln 

Illinois Grand 

Chain/Joppa 

Lafarge North America Cement kiln 

Kansas Humboldt Monarch Cement Cement kiln 

Kansas Chanute Ash Grove Cement Company Cement kiln 

Kentucky Owensboro Owensboro Municipal Utilities Utility boiler 

Kentucky Wickliffe NewPage Corporation Pulp & paper mill 
Scrap Tires 

23

State Location Company Type of Facility 

Louisiana Mansfield International Paper Pulp & paper mill 

Louisiana Bastrop International Paper Pulp & paper mill 

Louisiana Monroe International Paper Pulp & paper mill 

Louisiana Deridder Boise Pulp & paper mill 

Maryland Fredrick Fort Detrick Industrial boiler 

Maryland Baltimore Wheelabrator Baltimore LP Utility boiler 

Maryland Joppa Harford Waste-to-Energy Utility boiler 

Maine Rumford NewPage Corporation Pulp & paper mill 

Maine Bucksport International Paper Pulp & paper mill 

Maine Skowhegan SD Warren Pulp & paper mill 

Michigan Hillman Hillman Power Utility boiler 

Michigan McBain Viking Energy Utility boiler 

Michigan Lincoln Viking Energy Utility boiler 

Michigan Dundee Holcim, Inc. Cement kiln 

Michigan Wyandotte Wyandotte Power Utility boiler 

Michigan Filer City Tondu Energy Utility boiler 

Michigan Grayling Grayling Generating Station Industrial boiler 

Michigan Escanaba New Page Pulp & paper mill 

Michigan Quinasec Mananany Paper Pulp & paper mill 

Minnesota Satell Versa Paper Pulp & paper mill 

Mississippi Montecello Georgia Pacific Pulp & paper mill 

Mississippi Jackson Nucor Steel Electric arc furnace 

Mississippi Vicksburg (International Paper) Pulp & paper mill 

Missouri Columbia University of Missouri-Columbia Industrial boiler 

Missouri Kansas City Aquila/ Sibley Generating Station Utility boiler 

Missouri Cape Girardeau Buzzi Unichem USA Cement kiln 

Missouri Joplin Empire District Electric Co. Asbury 

Power Plant 

Utility boiler 

Missouri St. Joseph Aquila, Inc. - Utility boiler 

Nebraska Lincoln Ashgrove Cement kiln 

New York Auburn Nucor Steel Auburn Electric arc furnace 

New York Fort Drum Black River Electric Utility boiler 

New York Niagara Falls Niagara Generation Industrial boiler 

North 

Carolina 

Roxboro Primary Energy Industrial boiler 

North 

Carolina 

Southport Primary Energy Industrial boiler 

North 

Carolina 

Lumberton Cogentrix Industrial boiler 

North Dakota Mandan MDU Heskett Station Utility boiler 

Ohio Akron Akron Thermal, LLP Utility boiler 

Ohio Chillicothe PH Glatfelter Pulp & paper mill 

Oklahoma Ada Holcim, Inc. Cement kiln 

Oklahoma Tulsa Lafarge North America Cement kiln 

Oklahoma Pryor Lone Star Industries Inc. dba Buzzi 

Unicem 

Cement kiln 
Scrap Tires 

24

State Location Company Type of Facility 

Oregon Durkee Ash Grove Cement Company Cement kiln 

Pennsylvania Wampum Cemex Cement kiln 

Pennsylvania Whitehall Lafarge North America Cement kiln 

Pennsylvania Allentown Lehigh Cement Cement kiln 

Pennsylvania Meadville ESSROC Materials Cement kiln 

Pennsylvania Northampton Northampton Generation (2008 start up) Industrial boiler 

South 

Carolina 

Hodges Trigen Biopower Industrial boiler 

South 

Carolina 

Harleyville Lafarge North America Cement kiln 

South 

Carolina 

Catawba Bowater Pulp & paper mill 

South 

Carolina 

Hartsville Sonoco Products Company Pulp & paper mill 

South 

Carolina 

Eastover International Paper Pulp & paper mill 

South 

Carolina 

Georgetown International Paper Pulp & paper mill 

South Dakota Ottertail Power Company Utility Boiler 

Tennessee Calhoun Bowater Incorporated Pulp & paper mill 

Tennessee Memphis TVA Allen Steam Plant Utility boiler 

Tennessee Knoxville CEMEX Cement Kiln 

Tennessee Jackson Gerdau Ameristeel Electric arc furnace 

Texas Midlothian Ash Grove Cement, Texas L.P. (f/k/a 

North Texas Cement) 

Cement kiln 

Texas New Braunfels Cemex of Texas, L.P. Cement kiln 

Texas Midlothian Holcim Texas L.P. Cement kiln 

Texas Mary Neal Lone Star Cement Cement kiln 

Texas Hunter Texas Industries Cement kiln 

Texas Midlothian Texas Industries Cement Cement kiln 

Utah Leamington Ashgrove Cement kiln 

Utah Morgan Holcim Inc. Cement kiln 

Utah Grantsville Chemical Lime Company Lime kiln 

Virginia Richmond Cogentrix Industrial boiler 

Virginia Portsmouth Southeastern Public Service Authority Industrial boiler 

Virginia Martinsville Tire Energy Corp (TEC) Industrial boiler 

Washington Seattle Ashgrove Cement Cement kiln 

West Virginia Parkersburg Allegeny Power Utility boiler 

Wisconsin Cassville Alliant Energy Utility boiler 

Wisconsin Sheboygan Alliant Energy Edgewater Generating 

Station 

Utility boiler 

Wisconsin Ashland Xcel Energy Bayfront Plant Utility boiler 

Wisconsin Madison University of Wisconsin Charter Street 

Plant 

Industrial boiler 

Wisconsin Kaukauna Thilmany Paper Pulp & paper mill 

Source: RMA 2009