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 being 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 stockpiled 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 rough 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 myself 
last 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