Re: tire burning

["Alex J. Sagady & Associates" <ajs@sagady.com>]

At 01:48 PM 11/25/1998 -0500, you wrote:
>A  friend needs help finding data on tire burning.
>If you have any info, please send it to me and I will forward it.
>
> Tom says:
> Co-Chair Delegate Laird said that he would like to hear from a more
>authoritative
>source about the down-side of burning. It was made pretty clear that I
>have until one or two weeks before the next interims (Dec. 13-15) to get
>that information to the committee. I have not had much luck finding hard
>data, like independent emissions tests, refuting the EPA, Ohio, Texas, the
>OAQ, and Dick Cooke on this topic. I feel that the information must be out

[snip]

Tire burning environmental effects are not as clear-cut as many would like
to see these issues.....

Uncontrolled burning of tires in tire piles is, of course, awful with 
very high particulate emission, toxic emissions and potential for 
groundwater contamination from oils generated.

The relative environmental effects of burning tires in industrial boilers
and cement 
kilns depends on the type of fuel being replaced and the amount of BTU heat
input provided by the tires.   If they go above 30% BTU replacement, they may
have to comply with the municipal incinerator emission rules  (it is more
complex
than this...its been a while since I've read the requirements), which will 
impose dioxin and metal emission limitations on facilities that probably
wouldn't
presently have them.    

One regulatory hook...as I recall a facility must have a legally enforceable 
provision in its permit to limit tire burning to less than 30% if they aren't
going to be bound the the MSW rules.  This means that you may be able 
to go to court to block tire burning if there has been no amendment to a 
permit and this is a new fuel.

It makes a difference whether tire chips vs. whole tires are burnt.   In
general, some 
of the toxic metals (zinc and chrome) will be reduced by burning tire chips
instead of whole tires.   In addition, burning whole tires in northern climates
in an industrial boiler may cause problems when large amounts of ice is
charged to the boilers.  This will generally lead to increased emissions of 
carbon monoxide and products of incomplete combustion.  Most proposals 
for burning in industrial boilers have used tire chips.

Depending on the sulfur content of fuels being replaced, sulfur dioxide
emissions
can either go up or go down.   One dodge out there is that facilities will get
permitted on other fuels and avoid sulfur dioxide control technology
requirements
and then request permit amendments later for tires/chips and then
potentially escape
SO2 controls.  (i.e. dry scrubbers/fabric filter combinations).

Special problems may occur in cement kilns which charge whole tires to the 
cooler portions of the kilns along with the potential for products of
incomplete 
combustion.   

In a lime kiln I've dealt with in Ohio, burning of tire chips caused a
significant 
increase in objectionable visible particle  emissions...probably from poor
combustion 
of oily materials generated during thermal deterioration of rubber inside
the kiln.

I've seen stack tests showing both increases and decreases in TCDD/F emissions
upon burning tires.  You'll clearly want to examine emissions and
limitations for 
zinc and chromium under all circumstances.  Other stack tests I've seen show 
reductions in nitrogen dioxide emissions from tire burning over conventional
fuels.

Although some toxic emissions may increase, it is not clear that these will
necessarily 
cause ambient screening levels used in many states to be exceeded.   As a 
result, you may have a hard time and uphill battle using existing
regulations to 
successfully challenge tire burning proposals.


There are other means for dealing with disposal of tires out there....there are
pyrolizing units with produce oil and carbon black.   I've also heard of 
cryogenic units that produce crumb rubber.   There was a recent item on 
environmental news service about the benefits to asphalt longevity of 
using crumb rubber addition to asphalt paving.....  however, to date, 
all of these alternatives have taken a back seat to burning in industrial 
boilers and cement kilns.

EPA's Paul Lemieux in NC is going to be updating 
EPA's review of tire burn stack testing information sometime 
soon.    Also, you may find some information from the 
EPA Industrial Combustion Coordinated Rulemaking on 
tire burning issues.




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Alex J. Sagady & Associates        Email:  ajs@sagady.com
Environmental Consulting and Database Systems
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