WASHINGTON (Aug. 20, 2010) — The American Trucking Associations (ATA) has added its voice to those protesting the U.S. Environmental Protection Agency (EPA) proposal to treat facilities burning scrap tires and used oil as fuel as solid waste incinerators.
Along with the Rubber Manufacturers Association, the Tire Industry Association, the cement industry and other groups, the ATA said it was indefensible to redefine tire-derived fuel (TDF) and used oil as solid wastes.
Currently, fuel-burning facilities that burn TDF and used oil are regulated under Section 112 of the Clean Air Act, which regulates industrial boilers. The EPA proposal would redefine such units as solid waste incinerators under Section 129 of the Clean Air Act, meaning that they would be subject to much more stringent environmental controls. This, opponents of the action argue, would price TDF and used oil out of the energy market.
“Most motor carriers and truck dealers treat scrap tires as a useful commodity,” the ATA wrote in its comments dated Aug. 3.
“Retreading of worn tires is common in our industry,” the trade group said. “Retreading saves a company money, conserves petroleum necessary to manufacture new tires, and reduces emissions associated with new tire production.
“However, the life of retreads and other tires do eventually come to an end,” it said. “Avenues for scrap tires to be sold or given to recyclers for beneficial end-use markets must be broadened rather than constricted.”
Similarly, classifying used or off-specification oil as a solid waste would only undercut oil recycling and invite illegal dumping of oil, the ATA said.
“Off-specification oil being used as a traditional fuel dates back to the days of the first automobiles,” it said. “It was only in 1985 that a distinction was made between on- and off-specification used oil.”
The EPA is expected to issue a final rule on scrap tires, used oil and other alternative fuels by the year-end.