### Materials Characterization Paper In Support of the Final Rulemaking: Identification of Nonhazardous Seconda ry Materials That Are Solid Waste Scrap Tires

February 3, 2011



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1. Definition of Scrap Tires

Scrap tires are used tires th at 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 passenge r and commercial vehicles.

• The majority of scrap tires, 85 percen t, come from passenger vehicles and light duty trucks. The remaining 15 pe rcent 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 us ing tire-derived fue l; civil engineering projects ( e.g ., construction sites for landfills, septic tank leach fields, or roads); and crumb rubber plants wher e they may be recycled into other products (Virginia Department of E nvironmental Quality 2008). Other tires are used whole, either in civil e ngineering 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 provi des 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 In stitute 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

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### 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 Uses 1 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 Asso ciation (RMA) ha s 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 scra p 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 st ockpiled in numb ers of tires, because stockpile estimates continue to be given in units.



### Exhibit 2: Summary of Scr ap Tire Uses from 1990 to 2007
Millions of Tires Used Scrap Tire Use 1990 1992 1994 1996 1998 2001 2003 2005 2007 1 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 Asphalt 2 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 sepa rated out as a category in RMA 2009. 3. The tire derived fuel (TDF) total in cludes dedicated tires to energy.Scrap Tires

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### (3) Trends in Generation:

• Scrap tire generation increased by 36 percent from 1990 to 2007, while the amount reused or recycled incr eased 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 stockp iles declined by more than 87 percent, from 1 billion to 128 million (RMA 2009).

• The use of tires for fuel has increa sed 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 in crease as the cost of conventional fossil fuels increases (RMA 2006).

• The U.S. economy affects both the de mand 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 ma rkets contracted by 17 percent nationwide from 2007 to 2009, however, because supply had shrunk so drastically, demand for scrap tires wa s 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 Boile rs Maximum Achievable Control Technology (MACT) standards indicates that the sources surveyed for these rules annually combust 599,000 tons of scrap tires 2 

### (EPA 2009).

• States have contributed to the increased use of scrap tires as a fuel and for other purposes by regulating scrap ti res and by working with the public and private sectors to improve the ma nagement 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 illu strates 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 co mbustion database as a tonnage, the database includes material quantities expressed in terms of heatin g 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

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### 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 Ti re 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 th e 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, ei ther 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 ti res are frequently used as fuel in cement kilns, and the reinforcing steel within tires provides an additional benefit (Gray 2009). Otherw ise, use of whole tires is limited by whether theyScrap Tires

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### are compatible with the combustio n 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 accounte d for 43 percent of the fuel use of TDF, by weight, in the United Stat es in 2007. Other users include cement manufacturers (27 percent of fuel use), electric utilities (14 percent of fuel use), industrial boile rs (8 percent of fuel use), and dedicated tire-to-energy f acilities (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 percen t (RMA 2009). The reduction in market demand for TDF in cement kilns can be attributed to the following factors: (1) increased mark et 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 buildi ng and construction (RMA 2009).

• Currently, a total of 66 cement kiln s (at 43 cement pr oduction facilities) burn tires as fuel in the United States. Only ten of these kilns burn shredded tires; the remaining 56 k ilns 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 dedicat ed 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, ba sed on RMA (2009), EPA assumed that dedicated tire-to-energy facilities burn whole ti res exclusively and that cement kilns burn both whole tires and shredded tires. To distribute cement kiln tire use between whole tires and shre dded tires, EPA relied upon data provided by Blumenthal (2009a) on the num ber of cement kilns that burnScrap Tires

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### whole tires and the number that burn sh redded tires. EPA assumed that the breakdown between whole tire s 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 tire s as fuel has increased significantly since 1990. RMA indicates that the increas ed 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 Faci lities Using Tire-Derived Fuel

NAICS NAICS Title Count 1

327 Nonmetallic Mineral Product Manufacturing 2 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 reco very 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

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### 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-combus tion applications has increased significantly between 1990 and 2001, and currently, a high percentage of truck tires are diverted into groun d rubber applications (Blumenthal2009a). Since 2001, however, the amount of scrap tires used for noncombustion applications has been fa irly constant, whereas the amount used as fuel has continued to increa se. This trend reflects the high fuel value of tires. The increased acceptan ce 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 fu el has become a more attractive management option than other beneficial use applications.

• Cooperation from state agencies is cr ucial to the growth and development of non-combustion applications of sc rap 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

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### 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 im portant environmental accomplishment. Despite efforts to minimize the number of tires sent to landfills, tires are still landfilled because of the high cost of ha uling 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 cond ition to be suitable for bene ficial use applications. This reflects a significant waste of res ources. 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 undergro und 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 Ti res Stockpiled/Stored: Stockpiles of tires have been steadily decreasing as a result of state efforts to eliminate “tire piles.” States are typically responsible fo r regulating scrap tires, and each state, with the exceptions of Alaska and Delaware, ha s 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 ha ve also developed programs to address existing tire stoc kpiles (EPA 2007). The majority of current stockpiles are located in seve n 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, encour age the use of tires as fuel. SomeScrap Tires

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### 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 Pro cesses for Tire-Derived Fuel

(1) Types of Units Combusting Tires as Fuel: Tires are combusted as fuel in a variety of applications, including in bo ilers 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 Ceme nt 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, th ey are generally consolidated at key collection points ( e.g ., tire retailers, automotive repair shops, and fleets) through well-established channels befo re being shipped to processing facilities and end users. Exhibit 8 summarizes the processing chain for scrap tires used as TDF. An additional source fo r scrap tires is historical tire piles. Furthermore, some tire processors send TDF to end-users in directly, 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 devi ces accept whole tires, which can provide environmental advantages over chipped tires ( e.g ., energy savings from avoided chipping). 

### Scrap tires are removed from pa ssenger vehicles and trucks.

Tires that are no longer usable on vehicles are collected at retailers, fleets, etc. until th ey 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

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### (3) Processing Scrap Tires for Fuel Applications: Scrap tires are often processed th rough two physical processing steps: chipping/ shredding and meta l 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 mu ch 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 smalle r particle size required to remove metals increases processing costs (Gra y 2009). The price of TDF therefore increases with smaller particle si zes 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 th e wire. Also, the metals provide a positive value in the process as a substitute for raw materials, and considerable energy is saved by not chi pping 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 fi ve 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 a nd metal removal, some TDF producers are experimenting with pyrolysis, but it has not become commercially successful due to high capital costs associ ated 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 specificati ons 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 st ockpile 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 ti res 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 indust ry for the use of cryogenic s in the production of TDF has not yet developed (CIWMB 1992; Sorcher 2009).Scrap Tires

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### disposal, the only other notable potential uses of these tires are in cement kilns and civil engineering applic ations (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 th at use a tires as a replacement fuel for coal, use the processed TDF chips that are expected to qualify as non-waste unde r 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 a nd auto shops. (RMA comments, 2010). EPA anticipates that thos e 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 Challe nge (RCC) Scrap Tire Workgroup 5 

### 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 benefici al re-use, including ground/crumb rubber recycling, tire-d erived 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 orde r to make progress, one of which is the Tire-Derived Fuel Subcommittee, whic h 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 impl emented by USEPA with three overa rching 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 Work group 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

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### 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 su rvey by the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), the following states have approved the use of scrap tir es as fuel on at least one occasion: Maryland, Pennsylvania, Kentucky, Maine, and North Dakota. This use does not appear to have pre-approved stat us, 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 be neficial use determinati ons to the use of scrap tires as fuel: Indiana, Iowa, North Ca rolina, and Virginia. In addition, RMA data indicate that TDF has been approve d for use in facilities in 34 states (RMA 2009).

5. Scrap Tire and TDF Co mposition 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 co al, the replacement fuel.

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

• Tires: 12,000 – 16,000 Btu/pound (North Ca rolina Division of Pollution Prevention and Environmenta l Assistance (NCDPPEA))

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

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### Exhibit 9 summarizes the constituents in tire-derived fuel. In order to compare the constituents to the traditiona l 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 Data 2

Cadmium 6 <5
Calcium 3,780 3,780
Chlorine 1,490 Non-detect - 1,490
Mercury 3

- - Nitrogen 2,700 -
Sulfur 19,200 -

ELEMENTS IN METAL STEEL FROM TIRE BELTS; NOT EXPECTED TO BE RELEASED TO EMISSIONS IN A CONVENTIONAL BOILER 4

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 -

Iron 5 3,210 295

Zinc 6 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 ir on and other components of the wire are not expected to be released to emissions in a typical boiler. Rath er, 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 ra nge of values listed in the Material Characterization Paper for traditional fuels. Coal has many more constituents in that are not in TDF.Scrap Tires

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### (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 ma terial, 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 genera te a single estimate of the net cost savings or benefits associated with th e 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 pr ograms 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 (Blume nthal 2009a). Information is not readily available on the costs of processing tires for beneficial use applications.

Exhibit 10: Summary Economic Savings an d 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 lo cation 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 as sociated with beneficial use depend on the value of the fuel or input for which scrap tires serve as a substitute. The averag e 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 sc rap 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 combusti on units will be willing to pay different prices based on the kind of fu el 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 fo r TDF. However, the relationship between the level of pr ocessing needed, operational efficiency, and willingness to pay of an end-user also depends on the specific combustion unit and cannot be generali zed across an indu stry (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 appr oximately 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 virg in 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 w ith 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 associ ated with scrap tires alone.

Although existing studies do not include sufficient data to isolate the emissions associated with scrap tire s 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 NO x 

### and particulate matter emissions but show no clear pattern for SO x 

### emissions (EPA 1997). The same study also examined the emissions impacts associated with tire combusti on 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 thes e sources are representative of the combustion units that may use tires. No te that at well-controlled facilities that use coal, the comparable fuel, em issions 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 polluta nt 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-designe d, 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 bo ilers (especially when comparing on a heat input ba sis) with a specially designed combustor and add-on controls. 10 

### That said, little data exists for coal burning devices that could suppleme nt their fuel for TDF where the devices are not well-designed (e.g., sm all 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 de vices (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 Incinera tor Simulator (RKIS). While the study concluded that, with the exception of zinc emissions, potential emi ssions from TDF are not expected to be very muchdifferent 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. T echnical Report prepared for USEPA. Office of Research and Development, Washington, DC EPA 1997 at http://www.epa.gov/ttn/catc/dir1/tire_eng.pdfScrap Tires

17 

### We further note that variation in emi ssions 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 su ggesting that annual NO x 

### and SO 2 

### emissions at one cement facility would increase by 24.2 tons and 1.4 tons, respectively, if it stopped burning TD F and substituted it with coal. These figures assume that no additiona l controls would be installed to control NO x 

### and SO 2 

### emissions.

Exhibit 11: Emissions Impact of Using Tires as a Substitute for Conventional Fuels, by Pollutant and Combustor Type

NO x PM SO 2 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” i ndicates that emissions are unlikely to change. “Data in conclusive” indicates that the av ailable 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 fuel s 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 ti res into TDF, and these are not accounted for in Exhibit 12.

• Other Impacts: In addition to the impacts out lined 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 environmen tal 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 manufacturi ng needed to make clinker.Scrap Tires

18 

### vectors (such as mosquitoes and rodents), and because they can catch fire, uncontrolled, this can cont aminate 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

CO 2 3.9 19 19.1 - 15.3

CH 4 0.451 0.029 0.029 - 0.369

N 2 O 1.63x10 -5 2.01x10 -5 2.07x10 -5 - 1.17x10 -5

MTCO 2 E/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 st ep in the manufacture of a product or process, from the extraction of the raw material s to ultimate disposal. The LCI can be used to identify those system components or life cycl e steps that are the ma in 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 ava ilable 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 Prac tice 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/la ndfills/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/Publi cations/default.asp?pubid=90

Cement Kiln Recycling Coalition. 2010. Comment to EPA on the Proposed Rule for the Identification of Non-hazardous Secondary Materi als that are Solid Waste, Do cket/document number EPA-HQRCRA-2008-0329-1034, A ugust 3, 2010.

Centre County Solid Waste Auth ority. 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 De rived Fuel: Environmental Char acteristics 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.

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.
Page County, “Landfill, Compactor, & Recycli ng 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/documen t number EPA-HQ-RCRA2008-0329-1138-1143, August 3, 2010.

Rubber Manufacturers Association (RMA), “Scrap Tire Characteristic s”, accessed August 21, 2008 at: http://www.rma.org/scrap_ tires/scrap_tire_markets/scrap_tire_characteristics/Scrap Tires

20 Rubber Manufacturers Association (R MA). 2006, “Scrap Tire Market s in the United States”. 2005 Edition.

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

Rubber Manufacturers Association (RMA). 2010. Comment to EPA on the Proposed Rule for the Identification of Non-hazardous Secondary Mate rials that are Solid Wa ste, Docket/document number EPA-HQ-RCRA-2008-0329-1166, August 3, 2010.

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

Texas Commission on Environmenta l 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 Co des and Titles”, accessed August 21, 2008 at: http://www.census.gov/naics/2007/NAICOD07.HTM U.S

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United States Energy Information Administration (EIA). June 2008b, Preliminary Petroleum Marketing Annual 2007

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.

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.

United States Environmental Prot ection Agency (EPA). 2008b, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006: Annex 2 Methodology and Data for Estimating CO 2 Emissions from Fossil Fuel Combustion

.

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.
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21 United States Environmental Protection Agency (E PA). 2010, Preliminary Characterization Study: Traditional Fuels and Key Derivatives, Prepared in Support of the Final Rulemaking – Identification of Nonhazardous Se condary Materials That Are So lid Waste. Docket Number EPA-HQ-RCRA-2008-0 329. December 2010.

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22 

### Appendix 1: Summary of Faci lities 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 millScrap 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 Mi ssouri-Columbia Industrial boiler Missouri Kansas City Aquila/ Sibley Generating Station Utility boiler Missouri Cape Girardeau Buzzi Unichem USA Cement kiln Missouri Joplin Empire Di strict 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 Niagar a 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 In dustries Inc. dba Buzzi Unicem Cement kilnScrap 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 Amer isteel 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