From: "Michael Blumenthal" <mblumenthal@rma.org>

To: JPrice@indecon.com

Date: 7/21/2009 10:08 AM Subject: RE: Scrap tire analysis for EPA

Once upon a time cement kilns took a significant percentage of their from tire pile abatement projects; probably 10-20 percent of the total TDF they consumed (yes whole tires). Over time the number of stockpiled tires diminished and so the percentage of the TDF they got from stockpiled tires went down as well. Quite honestly a little dirt on a whole tire going into a cement kiln is no big deal (just as long as there was no mud/water in the tires). In today's scrap tire marketplace most of the major stockpiles have been cleaned up; there are three exceptions however: Michigan, Alabama and Colorado are still abating stockpiles and still sending those tires to cement kilns or industrial

boilers. Some of these tires are be ing used as whole tires (in Alabama for kilns) but in Michigan the stockpiled tires are being processed into two inch pieces of TDF before being sent to the industrial boilers.

There have also been examples when/where stockpiled tires were processed into two inch chips (Texas). I know that there are two cement kilns in Colorado that are planning to take tires out of a monofill and use them for TDF. One of the kilns plans on rough shredding the tires before they feed them into their kiln.

So there has been some processing of stockpiled tires to make TDF; I will also say that if/when stockpile d tires are processed the processing takes place at the stockpile location before being shipped off as fuel. What I told the young lady (I forgot her name) was that stockpiled tires are not brought back to a processors main processing facility (not to wear out their mainline processing equipment and dirty up the yard). Furthermore, scrap tire haulers do not get their tires out of stockpiles and bring them to processors. That is not how the market works.

To directly answer one of your questions: RMA has never publicly stated the number of stockpiled tires going for TDF. The reason for that was

that the information from the states just was not available. We have always aggregated the overall TDF numbers (as well as the TDA numbers)

for that reason.

Finally, several states are also ro ugh shredding stockpiled tires and using them for tire-derived aggregate, such as New York and Ohio.

I sure hope this is helpful. Should you have any further questions please do not hesitate contacting me.

-----Original Message----- From: Jason Price [mailto:jprice@indecon.com] Sent: Monday, July 20, 2009 1:58 PM

To: Michael Blumenthal Subject: Scrap tire analysis for EPA

Mr. Blumenthal,

Thank you again for taking the time to speak with Mark Ewen and myselflast week. We appreciate your concerns and will work diligently to ensure that our analysis for EPA on the proposed rule to identify secondary materials that are or are not solid waste reflects actual industry practice. To that end, we have one question for you regarding cement kilns' use of scrap tires. Based on information from various RMA documents, we know that, with a few exceptions, cement kilns largely

burn whole tires rather than shredded tires. The documents that we've identified, however, don't indicate the extent to which cement kilns' supply of whole tires comes from waste tire piles versus "newly" generated scrap tires. Does RMA have data on this that you would be willing to share with us for the purposes of our analysis?

Our motivation for asking this question is that our analysis will treat whole tires differently depending on whether they're from tire piles or are newly generated. Assuming that tires from stockpiles are dirty, our understanding is that tire processors are unwilling to produce shredded

TDF from these tires because the dirt on these tires could cause serious damage to processors' equipment. In contrast, this isn't necessarily a problem for newly generated scrap tires.

We would appreciate any information that you're able to provide on this issue. Thank you for your time.

Kind regards,

Jason

************************** Jason C. Price, Senior Associate Industrial Economics, Inc.

2067 Massachusetts Avenue Cambridge, MA 02140

Phone: (617) 354-0074 Fax: (617) 354-0463