United Slates
Environmental Protection
Agency
                         Office Of
                         The Administrator
                         (A-101F6)
EPA 1017F-91/048
February 1991
EPA
Scrap Tire Consumption
In New England And
New Jersey
#90-6502
                              Printed on Recycled Paper

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                                  DISCLAIMER

      This report was furnished  to  the  U.S. Environmental Protection
      Agency by  the student identified  on the cover page, under  a National
      Network  for  Environmental  Management Studies fellowship.

      The contents  are  essentially as received  from the author.   The
      opinions,  findings, and conclusions  expressed are those of the author
      and  not necessarily those of the U.S. Environmental Protection
      Agency.   Mention, if  any,  of company, process,  or product names  is
      not to be considered  as an endorsement  by the U.S. Environmental
      Protection Agency.
(A
 ^
X
V)
                              U.S. Environmentai Protection Agency
                              Region 5, Library (PL-12J)
                              77 West Jackson Boulevacd. 12th F/oar.
                              Chicago, IL  60604-3590

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SCRAP TIRE CONSUMPTION IN NEW ENGLAND AND NEW JERSEY
                      Amy  Barad
        U.S.  Environmental  Protection Agency,
            1990 NNEMS Fellowship Program

            School of Natural Resources,
               University of Michigan

                   November, 1990

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                          Abstract

The disposal of scrap tires is one facet of the current
solid waste dilemma that is currently receiving an
increasing amount of attention in the northeast.  Above-
ground disposal in tire stockpiles has become a common
phenomenon.  One way to avoid continued stockpiling of scrap
tires, and to reduce the number and size of existing piles,
is to find ways to consume the tires.  The economics of
scrap tire consumption in the region has not yet been
examined in great detail.  The main goal of this paper is to
describe the current pattern of scrap tire use and disposal
in New England and New Jersey, and the changes expected in
the near future.  In the course of this description, various
economic, regulatory and other factors emerge as significant
forces shaping the consumption and disposal pattern.  The
concluding sections of the paper highlight some of these
factors and identify policy options available to increase
scrap tire consumption in the region.

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                      Acknowledgements

The author would like to thank the following people for
their assistance with this project:  Ronald Jennings and
Paul Bedrosian, EPA Region I; Carole Ansheles, NEWMOA;
Steven Yaffee and Joseph Swierzbinski, University of
Michigan, School of Natural Resources; and the many state
officials and representatives of private industry who
provided invaluable information and insights.

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                        TABLE OF CONTENTS

                                                             Page

I.   INTRODUCTION AND OVERVIEW                                  1

II.  SCRAP TIRE CONSUMPTION AND DISPOSAL IN THE NEWMOA STATES   3

     A.   Background                                            3

     B.   Size of the Problem Today                             4

     C.   The Current Pattern of Scrap Tire Consumption and
          Disposal                                              6

          1.   Retreading                                       7
          2.   Export                                           7
          3.   Manufactured Products                            8
          4.   Experimental Uses                                8
          5.   Disposal                                         9

     D.   Expected and Potential Near Future Changes in Scrap
          Tire Consumption                                     10

          1.   Exeter Energy                                   10
          2.   Champion International                          11
          3.   Additional Users of Tire-Derived Fuel           11
          4.   Dragon Cement                                   12
          5.   TireCycle of New England                        12
          6.   Road Construction                               12

III. CHARACTERISTICS OF THE INDUSTRY TODAY                     14

     A.   Options Facing Tire Consumers                        15

     B.   Options Facing Tire Dealers                          15

     C.   Options Facing Tire Haulers                          16

     D.   Options Facing Landfill and Stockpile Operators      17

     E.   Whole-Tire Incineration for Energy                   20

     F.   Retreading and Remolding                             23

          1.   Individual Consumers of Replacement Tires       24
          2.   Large-scale Purchasers of Replacement Tires     25
          3.   Tire-Consuming Potential                        26

     G.   Manufacturers Using Whole Tires                      27
          1.   Stamped Products                                27
          2.   Artificial Reefs                                28
          3.   Mats and Liners                                 28
          4.   Tire Tubing                                     29

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     H.    Intermediate Material Manufacturers                  30
          1.   Tire Shredding                                  30
          2.   Crumb Rubber                                    32
          3.   Rubber-Plastic Polymers                         33
          4.   Pyrolysis                                       35

     I.    Consumers of Intermediate Products:
          Tire-Derived Fuel                                    35

          1.   Pulp and Paper Mills                            37
          2.   Cement Kilns                                    38

     J.    Consumers of Intermediate Products: Roadway
          Construction and Maintenance                         39

          1.   Crumb Rubber Additives to Asphalt Cement        40
          2.   Tire Chips in Construction Projects             45

     K.    Consumers of Intermediate Products: Play Surfaces    48

          1.   Soil Conditioning                               48
          2.   Playground Surfaces                             50

IV.  FACTORS AFFECTING SCRAP TIRE CONSUMPTION                  52

     A.    Availability of Low-Cost Scrap Tire Disposal         52
     B.    Competition with Existing Products                   53
     C.    Attitudes Toward New Products and Methods            53
     D.    Minimum Efficient Scale                              54
     E.    Capital Outlays                                      55
     F.    Transportation Costs                                 55
     G.    Lack of Product Standards and Specifications         56
     H.    Lack of Coordination in Research                     57
     I.    Environmental Concerns                               57
     J.    Limited Size of Some Markets                         58

V.   POLICY OPTIONS FOR DECREASING SCRAP TIRE DISPOSAL         60

     A.    No Further Action                                    60
     B.    Regulating Tire Disposal and Hauling                 62
     C.    Promoting Coordinated Research                       64
     D.    Developing Standards and Specifications              64
     E.    Public Sector Consumption (Procurement)              65
     F.    Demonstration Projects                               66
     G.    Subsidizing Tire Consumption                         66
     H.    Capital Cost Assistance                              68
     I.    Raising Revenue                                      69
     J.    National Legislation                                 70

VI.  CONCLUSIONS                                               72

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                       LIST OF TABLES
                                                        Page
Table 1: Current Generation and Stock                      5
Table 2: Current Consumption and Disposal                  6
Table 3: Additional Future Annual Tire Consumption       10A
Table 4: Heat Content of Common Fuels                    35A
Table 5: Scrap Tire Generation Rates with
         Exponential Growth                               61

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I. INTRODUCTION AND OVERVIEW


     The disposal of scrap tires is one facet of the current
solid waste dilemma that is currently receiving an increasing
amount of attention in the northeast and nationwide.  While tires
represent only a small percentage of the municipal solid waste
stream, some states have classified them as a "hard to dispose
of" waste.  Problems with the landfilling of whole tires have led
to a reduction in the number of disposal sites, and increases in
disposal costs at facilities that continue to accept tires.

     Above-ground disposal in tire stockpiles has become a common
phenomenon.  Some stockpiles contain tens of millions of tires
and carry the risk of serious health, safety and environmental
hazards.  Fires at tire stockpiles produce toxic runoff that can
pollute soil and water, in addition to generating acrid smoke and
reducing visibility.  Tire fires are difficult to extinguish
because the tires tend to trap pockets of oxygen that help to
maintain combustion, and some fires have been known to smolder
for months.  In addition, piles of whole tires collect rainwater
and thus provide breeding grounds for mosquitoes that can serve
as vectors for infectious diseases.  Among the diseases that have
been linked to mosquitoes breeding in tire piles are dengue fever
and La Crosse or St. Louis encephalitis.

     One way to avoid continued stockpiling of scrap tires, and
to reduce the number and size of existing piles, is to find ways
to consume the tires.  Promoters of recycling believe that the
materials that go into the manufacture of tires retain at least
some of their value even after the tire itself is no longer
usable.  Whether it is economically feasible to employ various
tire recycling technologies is a subject of great interest to
those trying to address the solid waste problem posed by the vast
numbers of scrap tires generated every year.  The fact that some
tire recycling is already taking place provides evidence that
private markets can sustain some level of some forms of this
activity.

     Government entities, from the Environmental Protection
Agency at the federal and regional levels, to interstate
cooperative groups, to state, county, and local agencies,
recognize that the private sector can play an important role in
solving the scrap tire problem.  Many have expressed an interest
in learning how market mechanisms are affecting the recycling of
tires and tire-derived products, and if there is a role for the
public sector to facilitate greater activity in this area.  The
present study was motivated by the interests of EPA's Region I
and the seven states that comprise the New England Waste
Management Officials Association (NEWMOA): Connecticut, Maine,
Massachusetts, New Hampshire, Rhode Island, Vermont and New
Jersey.

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     Before the role of the public sector can be discussed,
however, a better understanding of the current status of tire
recycling in the region is necessary; only after some initial
investigation of the existing and newly developing markets for
scrap tire products can informed policy questions be addressed.
The main goal of this paper is thus to describe the current
pattern of scrap tire use and disposal in New England and New
Jersey, and the changes expected in the near future.  In the
course of this description, various economic, regulatory and
other factors emerge as significant forces shaping the
consumption and disposal pattern.  The concluding sections of the
paper highlight some of these factors and identify policy options
available to increase scrap tire consumption in the region.  A
fuller policy analysis would also have to address the more
general market for waste disposal services, to which scrap tire
disposal and consumption is closely related.

     Two caveats are worth noting at this stage.  First, due to
the numerous ways in which tires can be consumed, some of which
are technologically complex, additional research is needed to
describe the economics of many of the potential uses.  Second,
the markets for scrap tires in the northeast are in a state of
flux, and the picture that emerges from this paper should be
regarded as a snapshot of an evolving situation.  Monitoring
changes in the region's uses of scrap tires will be necessary to
maintain a reasonably accurate picture of these markets.

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II. SCRAP TIRE CONSUMPTION AND DISPOSAL IN THE NEWMOA STATES


     It is useful to think of the scrap tire issue in terms of a
stock of material to which new additions are being made every
year, and from which consumable tires are flowing.  The stock can
be represented by the number of scrap tires currently stored in
above-ground stockpiles or other storage facilities, and at many
small dump sites.  The annual scrap tire generation rate may be
thought of as the flow into the stock, while the flow out of the
stock is accounted for by landfilling, recycling, or export.
When the rate of land disposal, recycling, and export exceeds the
annual generation rate, the stock shrinks.  Conversely, if the
generation rate exceeds these outflows, the size of the stock
grows.  Earlier this century, scrap tire generation was roughly
matched by the rate of tire recycling, and significant stockpiles
did not exist.  Several factors have served to change this
picture, however.
Background

     Scrap tires are generated in two ways.  First, for every
replacement tire purchased, an old tire is discarded.  Second,
for every car that is junked, four or five scrap tires are
generated.  Approximately 80% of the generation is due to
replacement and 20% to vehicle disposal.1

     Until World War II, and for some time thereafter, most scrap
tires were recycled.  Tire jockeys, people in the business of
removing scrap tires from the premises of tire dealers and scrap
yards, would typically pay for the privilege of collecting the
tires.  They would then resell the tires for reuse, retreading,
or reclamation.  These outlets accounted for approximately 10%,
20%, and 70% of the scrap tires, respectively.   Rubber
reclamation plants sold most of their output to tire
manufacturers, who could use the product in making new tires.
     Over the past several decades, tire jockeys have seen
dramatic changes in the outlets for their haul.  After World War
II, tire manufacturers began to use increasing amounts of
synthetic rubber in their product.  The result of reclaiming
synthetic rubber is not as suitable for the manufacture of new
tires as is the product derived from natural rubber.  Presumably,
the price for reclaimed rubber fell, and reclaimers competed for
customers by lowering the price of their product.  As some
reclaimers went out of business, the remainder could lower the
price they paid jockeys for scrap tires, and could eventually
begin to charge the jockeys to take the tires off their hands.
Eventually, the reduced demand for reclaimed rubber forced most
of the reclaiming plants out of business, including ones in
Naugatuck, CT, Butler, NJ and Buffalo, NY.  The Naugatuck
facility, which closed in 1975, was probably the largest in the

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region, processing 3 to 4 million tires per year.3  Only two
reclaimers are left in the country today.

     In addition, the advent of the radial tire made retreading a
more difficult operation.  While retreading bias-ply tires was
often a viable small business opportunity, the more expensive
equipment required to retread radial tires significantly
decreased the number of retreaders.  Furthermore, the
availability of relatively low-cost new tires has made it
difficult for retreaded tires to compete in the replacement tire
market.  These factors have greatly reduced the numbers of
passenger car tires being retreaded. and thus, the outlets for
the tires collected by the jockeys.

     Consequently, tire jockeys began to realize less profit from
the sale of the tires they collected.  As their markets for scrap
tires diminished, the jockeys reduced the amount they were
willing to pay to collect tires, eventually charging for this
service instead.  Tires were increasingly disposed of in
landfills or low-visibility dumps, which initially may have been
available at little or no cost.  Eventually, the jockeys'
expenses and sources of revenues switched places:  tire
collection became the principal revenue-producing side of the
business, and tire disposal a major cost.

     Returning to the picture of a stock with tires flowing in
and out, we see why New England and New Jersey did not always
have a scrap tire problem: the rate of reuse and recycling kept
pace with the scrap tire generation rate.  As these activities
declined, disposal increased.  The cheapest and least visible
disposal opportunities were exploited first.  As these
opportunities were exhausted, we have turned to the more visible
disposal options remaining, i.e., larger tire piles, piles in
less remote locations, and costly landfills.
The Size of the Problem

     Given the undesirability of tire stockpiles, and the public
interest in reducing the piles, it would be helpful to know the
rate at which the stock of scrap tires is shrinking or growing.
Knowledge about the magnitude of the problem will aid discussion
on the means of reducing it.

     Unfortunately, good estimates of the size of the stock and
the rates of flow into and out of this stock are not readily
available.  Estimates of the size of the existing stock depend on
inventories of tire piles in the region.  While the locations and
approximate sizes of the larger piles are usually known to state
environmental agencies, smaller piles may go uncounted.  Accurate
estimation of the size of the total stock, including the many
smaller piles in the region, may require much additional
investigation.

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     Better estimates are available for the rate of flow of scrap
tires into the stock, that is, the scrap tire generation rate.
Each state in the study area was able to provide an estimate of
the number of scrap tires generated per year.  These estimates
tend to be proportional to the states' populations.

     The following figures on generation rates and stockpile
sizes were supplied by each of the states in the region:5


                           Table 1

               CURRENT GENERATION AND STOCK
                         Annual
                         Generation     Stockpiles

     Connecticut         3,500,000      15,000,000
     Maine6              1,200,000      50,000,000
     Massachusetts7      6,000,000      30,000,000
     New Hampshire       1,000,000       1,500,000
     Rhode Island8       1,000,000      40,000,000
     Vermont9              500,000      10,000,000
     New Jersey10        9,700,000       8,000,000

     Total              22,900,000    -155,000,000


     A comparison of these estimates yields the observation that
the size of a state's stockpiles does not seem to be proportional
to its generation rate.  One explanation for this is that tires
cross state lines very easily, and disposal does not always take
place in the state where a scrap tire is generated.

     Finally, the flow of tires out of the stock depends on the
degree of recycling, export, and alternate forms of disposal
taking place.  (The shifting of stockpiled tires to other forms
of disposal occurs when, for example, tire pile cleanups result
in the shredding of tires for subsequent landfilling.  While this
practice reduces the number of tires in above-ground stockpiles,
it is not a consumptive use.)  Information on tire consumption
and disposal is the most difficult to obtain.  While some
national estimates of the level of recycling and export are
available11,  no clearinghouse on tire information keeps
statistics that are sufficiently detailed to enable a quick
regional analysis of these activities.  While the number of
companies in this region currently involved in tire recycling or
export may still be relatively small, these firms engage in
significant trade among themselves and across state and regional
boundaries, complicating attempts to obtain accurate figures for
the region.

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     In the following section, an attempt is made to estimate the
numbers of the NEWMOA states' tires that are going to each of the
recycling, export, and other disposal alternatives currently
available.  The information for this section was gathered
primarily through interviews with people involved in these
activities.  Following the description of the current pattern of
scrap tire consumption and disposal, is a discussion of some of
the major changes that appear likely to take place over the next
few years.


The Current Pattern of Scrap Tire Consumption and Disposal

     The majority of scrap tires in the region currently are
going to landfills or stockpiles, where their numbers are almost
impossible to document.  Retreading and export account for the
greatest number of tires going to non-disposal options.  The
total number of tires going to other recycling activities is
relatively small.  It should also be noted that many recycling
options for scrap tires only use a portion of the tire, and that
the byproducts from the recycling process may still account for a
substantial volume of solid waste.

     A summary of scrap tire consumption and disposal is
presented as Table 2.  (The following sections will briefly
describe what is included in each of categories and how the
figures on Table 2 were derived.)  All non-disposal figures
should be regarded as upper bounds on the numbers of tires
consumed in those categories.   The non-disposal estimates total
7.5 million tires per year.  Annual disposal is then the number
of scrap tires generated per year less the number consumed, or
15.4 million tires.  The disposal figure is thus a lower bound
estimate.  Based on these figures, we conclude that at least two-
thirds of the scrap tires generated in the NEWMOA states are
being stockpiled, landfilled, or otherwise disposed of, and up to
one-third are being put to other uses.


                           Table 2

               CURRENT CONSUMPTION AND DISPOSAL

     Destination                Tires per Year    Percent

     Retread                       3,000,000       13.1%
     Export Abroad                 2,400,000       10.5
     Manufactured Products         1,800,000        7.9
     Experimental Uses               300.000        1.3

       Subtotal                    7,500,000       32.8

     Disposal                     15.400.000       67.2

     Annual Generation            22,900,000

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Readers should note that much of the information used to compile
these figures was obtained by informal means and was usually
impossible to verify independently.


     Retreading

     Deriving an accurate estimate of the number of tires
retreaded in the NEWMOA states was surprisingly difficult.
National sources of tire data12  do not make state or regional
breakdowns, and a detailed survey of all the retreaders in the
region was beyond the scope of this study.  Therefore,
extrapolating from national rates was necessary.

     One way to estimate the number of tires retreaded is to
start with the region's annual generation rate, and reduce it by
20 percent to account for tires derived from vehicle disposal.
The remaining 80 percent can then be multiplied by the national
rate of retread sales as a percentage of total replacement tire
sales, which is 8.5 percent.13  If we assume that all of the
tires being replaced are passenger car tires, we get a regional
retread estimate of about 1.6 million tires per year.  If we
assume that the scrap tire generation rates reported by the
states include medium and light truck tires, and use a weighted
average percentage of replacement tire sales including these
categories, or 16.3 percent, our estimate of the number of tires
retreaded rises to about 3.0 million per year.14  This is the
figure listed on Table 2.15

     A serious problem with this estimate is that it is not clear
whether the scrap tire generation rates reported for each of the
states include or exclude tires to be retreaded.  If these rates
exclude tires that are retreaded, the actual number of tires
being retreaded is higher than that estimated above.15  Since
this number would not be part of the consumption of scrap tires,
the disposal estimate would have to increase by 3 million tires
per year; the number of tires recycled by other means or exported
would then equal only 20 percent of the total annual generation
of scrap tires.


     Export

     The next destinations accounting for relatively large
numbers of tires are various export markets.  Metropolitan Tire
Converters of Newark, NJ, and their affiliate, Integrated Tire,
ship tire chips to be used as fuel in foreign industrial
facilities.17  In the past year,  the companies have made two
shipments from the port of Newark of 25,000 metric tons each.
This is the equivalent of about 5.7 million tires.  However,
Metropolitan Tire Converters suggested that 2 to 3 million tires
is a better annual estimate.  About 80 percent of the tires
delivered to the Newark company are believed to originate in New

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                                                               8


Jersey, and the rest to come from New York City.  Given the
collection ranges of some tire haulers, however, it is difficult
to determine the origin of the tires.  It is likely that some are
coming from New England.  The figure listed on Table 2 represents
80 percent of 3 million tires.

     The reliability of this rate of export in future years is
unknown.  Recent shipments have gone to Greece and Mexico, but
additional customers are being sought in Canada and England.18
This suggests room for expansion in the export market for tire
chips as fuel.

     Whole tires are also shipped abroad for reuse in countries
where tread standards are not as high as in the United States.
Shipments to several Caribbean may be made from ports in
Massachusetts, Connecticut, New York, and New Jersey.19   Little
detailed information was available on how such shipments are
arranged or the numbers of tires involved.


     Manufactured Products

     A New Bedford, MA company that makes equipment for the
fishing and scalloping industries and other specialized products
is the largest manufacturing consumer of scrap tires in the
region.  Their products consume about 1.4 million tires per
year.20  Two New Jersey counties are making artificial reefs from
whole scrap tires.  This accounts for about 95,000 tires per
year.

     The NEWMOA states are also sending about 425,000 tires worth
of material per year to a crumb rubber manufacturer in
Pennsylvania.22  At least some of this quantity (anywhere from
one-fifth to three-quarters) represents leftover portions of the
tires consumed by the New Bedford manufacturer,23 which must be
subtracted to avoid double-counting.  About 100,000 of these
tires come back to the region in the form of intermediate or
finished products.  Most of this volume is accounted for by an
asphalt rubber contractor in Rhode Island.  Other consumers of
the crumb in this region include a brake manufacturer in
Massachusetts, and a New Jersey manufacturer of molded rubber
products.

     Additional products made from recycled rubber are being used
in the region, but most of the scrap tires consumed probably
originated elsewhere.  Examples of such products are woven rubber
mats, custom-fitted rubber railroad grade crossings, and poured
rubber flooring and roofing materials.


     Experimental Uses

     Some tires are being consumed as part of research projects
or in experimental applications.  For example, the state of

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Vermont is to use about 130,000 tires worth of chips this year in
an experimental road shoulder expansion project.  Research on the
use of rubber chips as backfill material for retaining walls is
also underway at the University of Maine.  Additional pavements
using crumb rubber additives not accounted for by the Rhode
Island firm may consume some tires.  A Connecticut company
developing rubber-plastic polymers may consume about 30,000
tires' worth of material per year.  While it is difficult to
identify all the experimental uses that may be occurring in the
region, a rough estimate of the number tires consumed in these
applications is 300,000 per year.


     Disposal

     The principal disposal options in the region include
landfills (accepting either whole or shredded tires) and sites
where shredded tires are stored above ground.  Some tires may be
burned in incinerators, but most incinerators try to exclude
tires because they do not burn well in facilities designed for
municipal solid waste.  Ideally, the disposal figure on Table 2
would have been calculated from actual data on the numbers of
tires accepted by the various disposal facilities in the region.
Had this been possible, an estimate of the number of tires going
to unregulated tire piles could have been made.  The
unavailability of detailed tire disposal data meant that all
disposal  permitted or unpermitted  had to estimated together
by subtracting estimated known consumption from estimated scrap
tire generation.

     A particularly noteworthy disposal facility in the region is
known as the "Tire Pond".  Owned by Tire Salvage, Inc., in
Hamden, CT, this facility is a former clay quarry that has filled
with water.  Tires are have been dumped in the 42-acre pit since
1976.  Since they are under water, they do not present the fire
hazard that tires stockpiled above ground do.  Because the Pond
apparently has no natural outlets to other surface or
groundwaters, water quality concerns are reduced.  The State of
Connecticut currently requires a discharge permit for the
facility, but no solid waste permit.24

     Total storage capacity of the Pond is estimated by Tire
Salvage to be 35 million tires, of which there may be room left
for 18 million.   The operator is currently accepting tires at a
rate of about 3 to 5 million tires annually.  About 60% are
brought by large tire hauling companies, and the remainder come
from Tire Salvage's own collection service.  Based on the
company's estimate that it culls 20 percent of its intake for
reuse, retread, or recycling,25 an  estimated 2.4  to  4 million
tires will be added to the Pond this year.

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                                                               10


Expected and Potential Near-Future Changes in
Scrap Tire Consumption

     Several developments likely to take place in the next few
years may have important effects on scrap tire disposal and
consumption in the NEWMOA states in the near future.  This
section describes these potentially major developments.  The most
probable events are discussed first.  A summary of these uses is
presented as Table 3.  Further detail is provided in Chapter 3.
                           *

     Exeter Energy, Sterling CT

     The most significant change about to take place in the
consumption of scrap tires in the Northeast will be the operation
of a tires-to-energy plant in Sterling, CT.  Exeter Energy, a
subsidiary of the Oxford Energy Company of Santa Rosa, CA, has
already begun construction of the plant and expects to begin
burning tires in 1991.  The plant will have a maximum capacity of
about 25 megawatts of electricity, and is expected to operate at
approximately 85 percent of capacity.  Exeter's financial pro
forma indicates expected tire usage to be about 80,000 tons (8
million whole tires) per year.  The electricity will be sold to
the Connecticut Light and Power Company under a 25 year
contract.26

     Once on line, the incinerator will consume tires collected
by Oxford Tire Supply, another subsidiary of the same parent
company, as well as those collected by other tire haulers.
Oxford Tire Supply is currently collecting tires at the rate of
3.5 million per year.  Of these, approximately 10% are culled for
reuse or retreading.  The company's strategy is to steadily
increase the number of tires it collects so that by the time the
incinerator is operational, an adequate supply network will be in
place.27  Oxford expects to be collecting tires within a 250 mile
radius of Sterling, thus including parts of New York State  (New
York City, Long Island, and towns east of the Hudson up to
Saratoga) and northern New Jersey, in addition to most of New
England, except Vermont and the parts of Maine north of Portland.
The proportion of tires that will come from New York was not
available at this time.

     Until recently, tires that were not usable for resale or
retreading were shredded and stored at two facilities owned by
Oxford Tire Supply, and affiliate of Exeter Energy.  Over one
million tires' worth of chips are in storage at a facility in
Bloomfield, CT, and an undetermined amount are in Walpole, MA.28
Now that these facilities are closed, Oxford is sending most of
its haul to the Tire Pond.

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                                                             10A
                           Table 3
          ADDTIONAL FUTURE ANNUAL TIRE CONSUMPTION



MOST PROMISING LARGE CONSUMERS                 STARTING DATE


Exeter Energy               8,000,000              1991


Champion                    3,000,000          Fall 1990


Another Paper Mill          3,000,000      .        1992
         SUBTOTAL          14,000,000



POTENTIAL LARGE CONSUMERS


TireCycle                   3,000,000     "         ?


Dragon Cement               3,750,000          1994 (?)


State Road Projects

   based on the replacement of 10% of
   the clean fill or common borrow currently used

         Vermont            1,000,000
         Maine              1,000,000
         Rhode Island       1,200,000
         New Hampshire      1,200,000
         Connecticut        1,000,000
         Massachuestts     not available
         New Jersey           800,000

         Road Projects
          Subtotal          5,400,000              ?


         SUBTOTAL          12,150,000
TOTAL                      26,150,000

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                                                               11


     Champion Paper Mill, Bucksport ME

     Champion International began investigating the feasibility
of burning tire-derived fuel (TDF)  at the Bucksport facility
about three years ago, in cooperation with the Maine Department
of Environmental Protection (DEP).   The idea was to replace a
portion of the coal used in the multi-fuel boiler with tire
chips.  The first experiments used chips supplied by Sawyer
Environmental Recovery of nearby Hampden, ME.  These chips proved
unsuitable because they contained too much wire.  Champion then
obtained chips manufactured in Georgia by Waste Recovery, Inc.
that had a greater percentage of the wire removed.  Test burns
with form of TOP were eventually successful.

     In the fall of 1989, the Maine DEP monitored emissions from
the plant using different amounts of TDF, with environmentally
acceptable results.29  The DEP  is currently in the process of
amending Champion's air licenses to allow the use of TDF on a
regular basis.  Champion hopes to begin using the fuel during the
fall of 1990.  The plant will be capable of consuming 3 million
tires' worth of chips per year.30  The choice of a fuel supplier
or suppliers has not yet been made public, but it is likely that
TDF meeting Champion's specifications can be supplied from within
the region.31


     Additional Users of Tire-Derived Fuel

     Negotiations between Sprague Energy, a New Hampshire-based
energy marketer, and potential suppliers of tire-derived fuel may
soon change the channels by which TDF would be supplied in
northern New England.  Sprague, which handles Champion
International's energy needs at both the plant and corporate
level, recently developed a relationship with Sawyer
Environmental Recovery, a TDF manufacturer.  Conversations with
representatives of both Sprague and Champion suggest that
centralized marketing of TDF by a company such as Sprague may
facilitate greater consumption of TDF in the region.

     Currently, potential large consumers of TDF, such as pulp
and paper mills, would each demand far greater quantities than an
individual TDF supplier is likely to produce.  The industrial
consumer would thus have to deal with several small suppliers in
order to obtain a sufficient volume of material.  This introduces
potential complications for the consumer in terms of managing
several supply contracts, assuring steady supply, and assuring
uniform product quality.

     The services of an intermediary who could offer a single
contract to the consumer and assure that the fuel will meet
quality specifications may help relatively small TDF producers
overcome barriers to entry into the vast, established market for
fossil fuels.  Given the newcomer status of tire chips as a fuel,
the participation of a major energy marketer in the supply of TDF

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                                                               12
lends a legitimacy to the material that may help encourage
potential consumers to experiment with it.  The energy marketer
thus reduces some of the risk and uncertainty associated with
TDF.

     Those in the industry agree that there is a strong
possibility that at least one more pulp or paper mill in Maine
may begin to use TDF in the near future.  Both favorable
experiences on the part of Champion and more reliability in the
supply of TDF may provide the evidence for which these firms are
waiting.  Of the four or five mills that employ the type of grate
that can accommodate TDF, two or three may seriously consider
using it to replace some of the coal they now consume.32  Some of
these other boilers have the potential to consume larger
quantities of TDF than Champion.33  Table 3  lists just one
additional paper mill, of a size comparable to Champion.


     Dragon Cement

     The only cement kiln in New England is operated by Dragon
Products in Thomaston, ME.  The plant is not now capable of
consuming either TDF or whole tires.  However, the company may
undertake capital modifications that would allow the burning of
whole tires.  If the plant is modified, it will be capable of
consuming 3.75 million tires per year, which would represent 25
percent of its fuel requirements.  The modification would cost
about $4 million and would not occur before 1993.34


     TireCycle of New England

     The TireCycle chemical process takes tires as a raw material
and produces an intermediate feedstock for plastic injection
molding and other uses.  The first company to use the process on
a large scale was Rubber Research Elastomerics at a plant in
Babbitt, MN.  The venture was partially financed by the state of
Minnesota, and its failure in 1989 was well publicized.  However,
TireCycle of New England believes that economic conditions in
Rhode Island, where they would like to locate a plant, are
substantially different.  The company is currently seeking a site
and financial backing.  If their plans succeed, they will have
the capacity to consume 3 million tires per year.35


     Road Construction Projects

     Table 3 also lists the tire-consuming potential of one
aspect of state road construction projects that might become a
significant consumer of scrap tires in the future.  The use of
tire chips as a substitute for ten percent of the clean fill
currently used in these projects could total more than 5 million
tires7 worth of material per year.  The use of crumb rubber

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                                                               13
additives to asphalt concrete is not included in this estimate,
but is another potentially large consumer of scrap tires.

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                                                               14


III. CHARACTERISTICS OF THE INDUSTRY TODAY


     To better understand the current pattern of tire disposal
and recycling in the NEWMOA states, we need to look at the
factors that face each of the actors who make decisions about
what to do with a used tire or its derivatives.  Many types of
actors are involved, representing all stages of the waste
disposal path or recycling loop.  These actors include individual
car and truck owners, the managers of private or government
vehicle fleets, tire dealers, tire retreaders, and those in the
business of hauling scrap tires.  They also include landfill and
incinerator operators, manufacturers of recycled products,
manufacturers of intermediate tire-derived products,
manufacturers of goods that consume intermediate tire-derived
products, and the ultimate consumers of these products.
Engineers who design highway reconstruction projects and
businesspeople who buy fuel for industrial boilers make decisions
that can affect the fate of large numbers of scrap tires.

     Economic factors play a significant role in influencing the
decisions made by these people.  In addition to more obviously
quantitative factors, government regulations, the availability of
information, professional reputations, and business ethics also
affect the way people regard options for handling used tires and
their derivatives.  An attempt has been made to bring all these
factors into the discussion, where appropriate.

     The current scrap tire recycling industry is small but
diverse.  One dimension of this diversity is the degree of
vertical integration exhibited by different firms.  That is, some
firms are involved only in one stage of the recycling loop, such
as tire collection, production of crumb rubber, or consumption of
tire-derived fuel.  Other firms participate in two or more
stages, using the output of one step as an input to the next.
For example, a company may collect tires from dealers, sort out
reusable casings, and make consumer-ready stamped products from
the remaining casings.  Alternatively, a company may collect
tires and shred them for sale to another processor who will make
rubber crumb.  The crumb manufacturer may itself consume the
crumb as a feedstock, or sell it to other manufacturers.
Vertical integration is neither a "good" nor "bad" feature
of an industry.  However, when it is displayed by some firms and
not by others, it makes the industry somewhat more difficult to
describe.

     The following sections will discuss the actors involved in
the tire disposal path or recycling loop.   Due to the overlapping
functions of some of these actors,  the lines between various
steps are somewhat difficult to draw.   In general, the first few
sections will trace the route of a scrap tire toward disposal,
indicating where the tire may branch off to one of the recycling
options.  The later sections will deal more explicitly with these
options.

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                                                               15


Options Facing Tire Consumers

     The individual car owner who needs new tires typically goes
to a tire dealer from whom she purchases the new tires and leaves
the old ones for disposal.  In the states of Maine and Rhode
Island, the customer pays a tax of $1 and $.50, respectively, for
each new tire purchased.  Given the small amount of the tax
relative to the price of a new tire, the customer is unlikely to
bother going out-of-state for the purchase.  As of this writing,
however, a bill before the Rhode Island legislature proposes to
establish a $10 deposit on new tires at the point of sale; a
deposit this large might encourage consumers to cross state lines
to buy their tires.

     Customers usually have the gas station or dealer from whom
they bought the new tires replace the tires on the vehicle.  Gas
stations and dealers sometimes take the old tires for free, but
may charge the customer a nominal fee for this service.

     If the tire dealer or gas station will not take the used
tires back, or if the tire consumer is getting rid of tires
without making a new purchase, the consumer must investigate
other disposal options.  Some communities that have curbside
garbage pick-up will take one or two tires per household at a
time, but others will not.  Residents who take their garbage to
the town landfill may have to pay a special fee to dispose of
tires there.  Landfills in New England typically charge $.50 to
$2 per tire.  Some may charge as much as $5 per tire.  The fee on
truck tires may be higher than that for passenger car tires.

     If all the legal disposal options facing the consumer charge
a fee or are otherwise inconvenient, the consumer may consider
storing the tire or dumping it illegally.
Options Facing Tire Dealers

     Tire dealers sometimes inspect returned tires and sell those
in good condition as used tires.  They may also sell them to used
car dealers who need to replace tires on the cars they sell.  The
average retail price for a reusable passenger car tire is about
$15'3   Tire  dealers  do  not  typically get  involved in culling  for
retreadable casings,  unless they do some retreading on their own
premises.  Dealers store the remaining majority of the tires
until disposal.  Smaller gas stations that change tires for their
customers often pay a tire dealership to handle the disposal of
their scrap.

     Regulations in some states limit the onsite storage of scrap
tires.  For example,  Rhode Island prohibits the storage of more
than 400 tires except by persons engaged in the tire recycling or
recovery business and licensed by the Department of Environmental

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                                                               16


Management.37  Maine limits the area of tire storage to 2,500
square feet.  To comply with these regulations, tire dealers must
thus have regular pick-up of the returned tires they accumulate.

     Tire collection services are provided by a few large
companies that serve large parts of New England, as well as by
many independent "tire jockeys".  Tire collection companies will
sometimes spot a trailer on the dealer's property and collect it
when it is full.  Alternatively, the dealer may be on a regular
route established by the tire hauler, and receive periodic
collection service.  Other tire haulers will respond to calls
from dealers when they have enough tires to warrant a pick-up.
The costs of these services vary by region, number of tires
collected at a time, distance, whether reusable tires have
already been culled, and other factors.  Collection service fees
range from about $.50 to $1.35 per tire.

     In some cases, tire dealers and municipalities may work out
cooperative arrangements that take advantage of tire haulers'
lower rates for large quantities.  For example, the tire dealer
may pay the municipality for use of a container kept at the
landfill, or the municipality may provide free disposal for
dealers who agree to keep trailers on their property and accept
the town's tires.38

     Tire dealers sometimes face the problem of finding that
others have illegally dumped truckloads of tires on their
property.  They then have little choice but to pay for the
disposal of these tires along with their own.
Options Facing Tire Haulers

     Some tire haulers choose to serve only large tire dealers or
chain stores, while others also do business with single-outlet
dealers.  In addition, some tire haulers serve municipalities,
either collecting tires from transfer stations or landfills, or
performing tire pile clean-ups.

     Most tire haulers cull out reusable or retreadable casings
and sell them, as this is the most valuable component of the
material collected.  Retreaders will pay from about $.80 to over
$4.00 per casing, depending on size.    Some reusable tires that
are not sold for use in this country are exported.  The price
obtained for these casings was unavailable for this report.  The
major tire collection companies say that they cull about 10 to 15
percent of their total haul for reuse or retreading.

     After this step, tire haulers vary substantially in the ways
they handle the remaining tires.  A few tire collection
operations represent the first stage of businesses that
themselves recycle tires into other intermediate or final
products.   An example of this type of business is F&B Enterprises

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                                                               17


of New Bedford, MA, which manufactures equipment for the fishing
and scalloping industry out of some of the tires it collects.
Other collection services may be provided by businesses that also
operate landfills, thus providing "in-house" disposal.
Similarly, the Tire Pond in Hamden, CT provides both collection
and disposal services.

     Some businesses both collect and recycle the whole tire,
such as Sawyer International of Hampden, ME, which makes tire-
derived fuel.  Others use only a portion of the tire or only some
of the tires collected, and must still find disposal or
purchasers for either whole tires or the scraps from their
operation.  Furthermore, many tire haulers do not use the tires
at all, and must dispose of all they collect.

     New England and New Jersey tire haulers sell some of their
tires to other recycling businesses, both within and outside the
region.  However, most of the tires collected are not ultimately
recycled.  The tire haulers usually must pay a tipping fee for
disposal at landfills, the Tire Pond, tire shredding operations,
or at permitted or unpermitted tire stockpiles.  Incinerators in
the region generally will not accept truckloads of tires.

     The costs of haulers' disposal options depend heavily on
tipping fees, which range from zero for illegal sites, to $100
per ton (about $l/tire) at permitted facilities.  At some
landfills, the tipping fee is the same as for other refuse, and
at others it is substantially more.40  The tipping fees that the
Exeter tires-to-energy facility is expecting to receive in its
first few years of operation are in the $35 to $40 per ton
range.

     Another factor affecting a hauler's choice of disposal site
is the cost of transportation to the facility.  A rough estimate
of the cost of transporting tires in fully-loaded trucks is $20
per ton per 100 miles, or 20 cents per tire per 100 miles.42  The
cost of transportation is significant because it means that low-
cost disposal sites are low-cost only within a certain radius.

     Haulers can be expected to seek the least-cost alternative
for their tire disposal needs.  Whether haulers include illegal
options in their decisions may depend on their business ethics
and/or their estimate of the risk of being caught and held
responsible, as well as the price differential when compared to
legal options.  Clearly, a tire hauler who collects tires for a
given service fee will not stay in business long if the only
disposal options cost nearly as much or more.
Options Facing Landfill and Stockpile Operators

     If not constrained by law or ordinance, landfill operators
can choose whether to accept tires from individuals and/or by the

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                                                               IS


truckload, and the tipping fee for this service.  An important
consideration in whether to continue to accept whole tires for
burial is whether new cells in the landfill will be opened in
which the tires can be placed as the bottom layer.  In this
position, the tires are much less likely to rise and disrupt the
cap.  Since disruption of the cap is an expensive situation to
remediate, tires are not buried near the top of a landfill.

     Landfill operators are increasingly requiring that tires be
cut or shredded before burial.  This significantly reduces the
volume of the tires and their potential for rising.  If the
landfill is shredding the tires onsite, this adds significantly
to the cost of disposal.  Estimates range upward from $.60 per
tire.43


     "Consumption" of Tire Shreds at Landfills

     The potential for shredded tires to replace some of the
daily cover consumed at landfills may offset some of the costs of
shredding.  Daily cover is the material placed over the waste
each day to cover the day's operating area and control vectors,
blowing litter, fire,, and moisture.  It typically consists of
soil found at the landfill site, and is usually spread to a depth
of at least 6 inches.  Tire chips have been used as a component
of daily cover in several states, including Florida and
Wisconsin, and are reportedly successful at controlling blowing
litter and vectors.  They are not as useful in controlling
moisture or fire,44 but the soil with which they are mixed may
serve these functions.  Another disadvantage of tire chips is
that protruding wire can puncture the pneumatic tires on landfill
equipment.  This is not a problem at landfills that use steel-
wheeled vehicles, however, or where tires can be replaced with
steel wheels.45  Whether it is economic for a landfill to use
tire chips will depend largely on the availability of
conventional daily cover onsite, or the price and transportation
costs associated with cover obtained offsite.

     Tire chips may also be used at landfills as erosion control
materials, as part of the drainage layer of a landfill's cap at
final closure, or as onsite roadbed construction material.
However, these consumptive uses of tires, including the daily
cover application, are currently being practiced at very few, if
any, landfills in the NEWMOA states.


     Tire Storage at Landfills

     Some landfills accept tires but do not serve as the final
disposal site for them.  For example, the Central Landfill in
Johnston RI, which receives about one third of the scrap tires
generated in Rhode Island, charges $75 per ton for dedicated
loads ($.75 per tire) or $5 per individual tire mixed with other

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                                                               19


garbage.  The tires are temporarily stored at a paved area on the
site before a private hauler takes them away for $70 to $100 per
ton ($.75 to $1 per tire).46  In this case,  the landfill is
acting as a transfer station for tires.


     Regulations and Guidelines Affecting Tire Disposal

     As of this writing, state regulations directly affect the
landfilling of tires only in Maine, although Vermont and
Massachusetts are considering bans on the landfilling of whole
tires.  In Maine, the facility operator must submit a plan
acceptable to the Department of Environmental Protection that
details the handling of tires.  This usually calls for tires to
be shredded or for whole tires to be placed only at the bottom of
a landfill cell.47

     State regulations also affect the above-ground storage of
tires at landfills and stockpiles.  Many pre-existing stockpiles
are being required to come into compliance with tire pile
regulations in order to obtain permits for continued acceptance
of tires.  For example, Maine regulations limit tire pile
dimensions, specify fire lane widths, and require buffer strips
around the storage site.  In addition, some storage facilities
must take measures to protect surface and groundwater and limit
access to the site.  Some facilities must provide escrow accounts
or other financial sureties to ensure the availability of
adequate funds for cleanup operations or final closure.48

     Similarly, Connecticut treats applications for permits to
establish and operate tire storage facilities as applications to
establish "bulky waste" disposal areas.  To obtain a permit, the
applicant must show that the facility will comply with bulky
waste disposal area guidelines, as well as guidelines developed
specifically for scrap tire storage.  The latter specify the
maximum dimensions of individual tire piles, minimum fire lane
widths, and additional fire prevention and control measures.  A
bond sufficient to cover the cost of onsite burial of the tires
must also be posted.49

     In New Hampshire, state regulations affect tire disposal
availability and tipping fees.  Towns or solid waste districts
are
required to provide a disposal site for tires, although this does
not necessarily have to be a landfill.  New Hampshire towns that
charge a special disposal fee at the time of vehicle
registration, an option they have under state law, are prohibited
from charging a tipping fee on tires.

     In general, special measures that must be taken to dispose
of tires at landfills, whether required by law or not, represent
increased expenses to the landfill for accepting this waste.  New
regulations or more widespread adoption of precautionary means of
dealing with tires can be expected to further increase this

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                                                               20


expense, resulting in higher tipping fees.  Similarly, compliance
with tire pile regulations represents an increase in operating
costs to stockpile owners, which will likely be reflected in
increased tipping fees by those who wish to maintain legal
operations.

     Like tipping fees for ordinary refuse, the tipping fees
charged for waste tires may not represent the true social
cost of disposal.  While the true costs of landfill disposal,
should be incorporated in a full cost-benefit evaluation
of waste tire management, estimation of such costs is beyond the
scope of this study.  When merely identifying the incentives that
face individuals and tire haulers when they consider their tire
disposal options, however, tipping fees are an appropriate
measure of cost.  Factors that increase the fees are relevant to
the choices that these people make.
Incineration for Energy

     Exeter Energy's tire incineration plant under construction
in Sterling, CT will begin operation in mid-1991.  The design of
the plant is based on technology used by Exeter's parent company
at its tires-to-energy facility near Modesto, CA.  That plant has
been in operation since 1987:

     The Sterling facility is designed to burn whole tires
unloaded directly from trucks or from onsite tire storage
cells.50  A separate conveyor will be available to feed shredded
tires, although these are expected to provide only a small
percentage of the fuel burned.  Two reciprocating grate
combustion systems will burn the tires at temperatures over
2,500F.  The steam produced in the two boilers will be piped to
a turbine to generate the electricity.  Underground transmission
lines will connect the facility to a Connecticut Light and Power
line in Plainfield.

     The plant's environmental controls will consist of a flue
gas cleaning system that will be comprised of thermal deNOx, a
baghouse, and a wet scrubber.  Fly ash collected in the baghouse
will be stored in a silo until shipped offsite.  Trace metals,
principally zinc, can be recovered from the ash with additional
processing.  The gypsum produced by the wet scrubber will be
dewatered onsite.  The bottom ash, the result of melting steel
belts, will also have to be shipped offsite.

     Exeter Energy has already arranged contracts for some of the
process's byproducts.  The gypsum will be sent to US Gypsum in
New York, and the zinc will go to the Zinc Corporation of America
in Pennsylvania.  Negotiations are still underway with cement
kilns that might accept the steel slag.51  The company also
emphasizes that the plant will not burn tires that would be
suitable for reuse or retreading.

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                                                               21


     Terms of the Electricity Purchase Agreement

     The Public Utility Regulatory Policies Act of 1978 requires
electric utilities to purchase the electric output of qualifying
cogenerators and small power producing facilities.  Since the
Sterling plant is considered a qualifying facility under the
appropriate criteria, Connecticut Light and Power (CL&P) must buy
its output.

     The rate at which Exeter will sell its power to CL&P is
based on the utility's avoided costs, i.e., what it would cost
CL&P to generate the power itself or purchase it elsewhere.  The
contract between Exeter Energy and CL&P specifies that the
utility will pay Exeter a fixed rate per kilowatt-hour that is
initially expected to be greater than CL&P's avoided cost.  In
later years of the term of agreement, CL&P is expected to pay
Exeter at a rate less than its then-current per-kilowatt-hour
avoided costs.  According to the contract,

     [t]he  initial  fixed  rate,  expected  to  be above  Buyer's
     [CL&P's] avoided  costs  in the  early years of the Term,  is
     necessary to  allow  Seller [Exeter]  to  obtain  financing and
     have  assurance of  adequate  cash  flow to  go forward  with
     construction of the Facility.   The payment rate expected to
     be below Buyer's avoided  costs in  the later years  of the
     Term  is necessary  to  provide  Buyer's ratepayers  with  a
     reasonable expectation of  recovering payments  above avoided
     costs made in the earlier years of the Term.52

Based on projections by Exeter and CL&P, the utility will start
receiving the benefits of the lower rates in the year 2000.53
The total savings to Connecticut ratepayers is estimated to be
$228 million over the life of the contract (not discounted to the
present).54


     Anticipated Effects on the Scrap Tire Market

     According to the projections accompanying the electricity
purchase agreement between Exeter and the utility, the plant will
consume 80,523 tons of tires per year during the first 10 years
of operation, and 83,321 tires per year thereafter.55   This is
the equivalent of about 8 million tires annually.  Some of these
tires will originate in New York,  so only a portion of the 8
million will represent consumption of tires from the seven states
included in this study.  A breakdown of tire origin by state was
not available.

     Not only is the volume of tires to be consumed significant,
but so is the price at which tires will be supplied to the
facility.   About 56 percent of the tires consumed by the plant
will be acquired through contracts with large volume tire
haulers.56  These contracts were established before  1989,  when
Exeter needed to show the Connecticut utility commission that

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                                                               22


oversees the contract with CL&P that the facility would have a
reliable source of fuel.  At the time the contracts were
arranged, Exeter believed that it would be receiving 100 percent
of CL&P's avoided costs of electricity generation, and that it
would not need to collect substantial tipping fees on the tires.
Thus, it offered the tire haulers very favorable terms.  For most
of the tires acquired under contract, Exeter will be paying only
the cost of transporting the tires to the facility.57

     Later in the negotiations with CL&P and the utility
commission, it was decided that Exeter would not receive 100
percent of CL&P's avoided costs, but that the difference would be
made up by the tipping fees Exeter could collect on the remaining
number of tires that would have to be acquired on the spot
market.  The savings to the utility would then be passed on to
its ratepayers.58  To take further advantage of any increases in
tipping fees that Exeter might obtain on the spot market, the
contract with CL&P also contains provisions whereby Exeter will
have to share a greater portion of the tipping fees in times of
good cash flow.5*

     The significance of these terms is that haulers who were
lucky enough to sign contracts with Exeter in the late 1980s will
have a very low-cost means of disposal for a combined 4.4 million
tires per year.  If typical tire disposal costs remain high over
the next 25 years, these haulers will earn comparatively high
profits on the portion of their business accounted for by their
pre-1989 Exeter contracts.  These contracts alone will probably
not affect tipping fees observed in the market, however; despite
the large number of tires accounted for by the contracts, the
total number of tires to be disposed of in the region is several
times this.
     Rhode Island Reaction

     Sterling, CT is upwind of a major reservoir that supplies
Rhode Island with drinking water.  Some Rhode Island residents
have expressed concern over the possible effects of plant
emissions on the reservoir.  While Rhode Island can not stop
construction or operation of the facility, the state legislature
passed a law that prohibits both the burning of used tires within
the state at facilities where they would be the primary source of
fuel, and the export of tires to facilities in other states that
burn tires within 30 miles of any Rhode Island reservoir
watershed.60  The Exeter plant falls under this  description.

     On its face, the Rhode Island law may represent an
unconstitutional restriction on interstate commerce.  Assuming it
is not challenged, however, the law is unlikely to have a serious
effect on the ability of Exeter to obtain tires, or the price it
will have to pay for them.  It is more likely to affect tire
haulers doing business in Rhode Island, who will be precluded
from disposing of their haul at this nearby facility.

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                                                               23


Retreading and Remolding

     Retreading refers to the process of removing the remaining
old tread from a tire and replacing it with new rubber tread.
Top capping refers to replacement of the tread alone, while full
capping includes replacement of part of the crown.  Bead-to-bead
retreading, or remolding, is a process used on radial tires that
involves a heat curing process in which a veneer of new rubber is
applied to the sidewalls, in addition to the tread and crown.  It
appears that remolding has some advantages over recapping in
terms of tire wear.  The only remolder in the northeast is in New
Jersey.

     Truck tires have long been retreaded for both technical and
economic reasons: truck tire casings are often durable enough to
outlast the tread several times and withstand several
retreadings; and new replacement tires are sufficiently expensive
to make retreading worth the cost.  For example, the state of
Maine has a contract for retreading services that enables them to
have truck tires retreaded at an average cost of $63 each,
while new replacement tires would cost about $217 each.61

     Lighter truck tires and passenger car tires are not as
widely retreaded, and it is these tires that represent the
majority of the scrap tire problem.  The retreading of passenger
car tires has declined in the past several years as consumers
have been faced with the choices of cheaper or longer-lasting new
tires.62  The growth in use of radial tires has helped to prolong
the initial life of a tire, but has led to lessened retreading
because radials are more difficult and expensive to retread than
bias-ply tires.  In addition, consumer concerns over the safety
of retreaded tires is frequently cited as a reason for the low
rate of passenger car tire retreading.

     According to the National Tire Dealers and Retreaders
Association63,  the number of tires retreaded in 1989, and the
number of new replacement tires sold were as follows  (figures are
in millions of tires):

                                  New       Retreads as %
     Type       Retreads      Replacement     of Total

     Passenger      14             150            8.5
     Lt. Truck       7              22.5         23.7
     Md. Truck      14.8            11.2         56.9

     Total          35.8           183.7         16.3

While figures for New England or the northeast are unavailable,
the NTDRA gave no reason to believe that the regional rate of
retreading was different from the national rate.  However,
Recycling Research, Inc., publisher of Scrap Tire News, suggests
that retreading in the industrial northeast is lower than the
national average.  Vermont was cited as a state with somewhat

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                                                               24


higher reuse and retreading.64  Another exception might be New
Jersey, although its higher rate is due principally to truck tire
retreading.65

     When guidelines for proper tire maintenance are followed, as
is often the case with truck tires, 80% of the casings are
suitable for retreading.  Only about 30 to 40% of passenger car
tires are suitable for retreading, however, because of improper
care.  This rate could be doubled if all tires are taken out of
service when they still have the legal limit of 2/32" tread
remaining.66  Some cheaper tires are constructed with casings
that would never be suitable for retreading.  Casings that have
been in stockpiles for too long are also unsuitable for
retreading.

     Retreaders of passenger car tires may pay anywhere from
under $1 to over $4 for a retreadable casing.    Retreaded and
remolded tires retail for about 20 to 35% less than new tires.
In addition, the retreader may receive some income from the sale
of buffings, or the powdered rubber that is a byproduct of
removing the old tread from the casing.  Buffings sell for about
10 cents per pound.68  Depending on the condition of the
casing, one or two pounds of buffings may be produced for every
passenger car tire retreaded.69

     Retreaders do not usually have trouble obtaining enough
quality passenger car tire casings.  The New Jersey remolding
company cited the price of the casings as a greater concern, and
the cost of advertising as a constraint on reaching the
private consumer market.70


     Individual Consumers of Replacement Tires

     From the consumer's perspective, the first question that
must usually be addressed is that of safety.  According to the
Federal Tire Program, retreaded passenger car tires do tend to
experience tread wear sooner than new tires, but they do not fail
outright (blow out or split apart) any more frequently than new
tires.71

     Assuming equivalent safety, the value of a retreaded
tire as compared to that of a new tire is based on the cost per
mile of service that the tire can be expected to provide, and the
terms of the warranty.  One Massachusetts tire dealer provided
the following "typical" figures for a customer considering
replacement tires for a full-size American car.  A good quality
new radial tire costs $60 and comes with a 40,000 mile warranty.
A retreaded radial tire costs $40 and is expected to last 25,000
to 35,000 miles.  The new tire would thus provide service for
0.15 cents per mile, while the retread would provide service for
0.13 to 0.16 cents per mile.  While a purchaser of retreads would
have to go through the trouble of replacing tires again sooner

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than a purchaser of new tires, the cost per mile of the two
products is similar.

     Important differences may appear in the terms of the
warranties, however.  Both kinds of tires are usually guaranteed
against defective workmanship or poor materials, but new tires
may carry better guarantees on tread wear or mileage.  This may
have a significant effect on the relative price per mile if a
tire wears out sooner than expected.

     Another factor that might affect the consumer's choice is a
disposal fee charged only on purchases of new replacement tires
but not retreads.  In the example above, a $2 disposal fee would
raise the cost per mile of the new 40,000-mile tire to 0.155
cents, and a $5 fee would raise it to 0.1625 cents.  The fee
would have the effect of making the retread more competitive with
the new tire.

     Of course, these numbers will vary by dealership, tire
quality, and tire size.  This example is simply meant to show how
the tire customer may approach the decision and how important
both service life and cost are.  There may be circumstances in
which the customer decides that the retreads are appropriate, but
it is not obvious that retreads will always or never be the
better purchase.


     Large Scale Purchasers of Replacement Tires

     Fleet managers also face decisions about whether to purchase
new or retreaded tires, and their calculations may be similar to
those of an individual.  Managers of government fleets face some
special conditions.  First, they are usually required to purchase
only from suppliers with which the government unit has a
contract.  To date, none of the New England states provide the
choice of retreaded passenger car tires to their fleet managers.

     One of the main reasons that state procurement officials do
not seek contracts with suppliers of passenger car retreads is
that they usually rely on the federal government's Qualified
Products List  (QPL), and no retreaded or remolded passenger car
tires have made it on to the list.  According to Ken Collings of
the Federal Tire Program  (FTP), which tests tires for inclusion
on the QPL, this is because the testing procedures require
retreads to perform as well as new tires.  This standard is used
even though most retreads are not designed to last as long as new
tires.

     In the typical FTP test, a vehicle with one new control tire
and three test tires is driven 20,000 miles with an 85% load.
This load is much heavier than what most vehicles usually carry,
and it enables the test results to be extrapolated to estimate
tire life under other conditions.  To pass, the test tires must
last within 5% as long as the control tires.  While most of the

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                                                               26


retreaded casings tested do not fail outright (i.e., split
apart), they wear out prematurely as compared to the control
tire, and this disqualifies them from inclusion on the QPL.72

     The state, county, and municipality procurement officials
who rely on the QPL do so because it provides a measure of
quality assurance.  Co11ings suggests that tire purchasers could
still obtain some degree of quality assurance for retreads
through use of the FTP'S test results by looking for
brands of retreads that wore out without failing.  These tires
may be appropriate for vehicles that are driven fewer than 25,000
miles per year and not at pursuit speeds.

     Given an independent estimate of the expected life of the
retreads, procurement officials could better evaluate the cost of
these safe but shorter-lived tires.  If procurement guidelines
require that contracts be awarded to the lowest bidder, there
will at least be a basis for comparing the cost-per-mile of
retreads with the cost-per-mile of new tires.  If life-cycle
costing or preferences for recycled materials allow an agency to
spend more for retreads, this information will be essential.


     Tire-Consuming Potential

     While none of the New England states or New Jersey currently
have contracts for suppliers of passenger car retreads, some may
be interested in using them on state fleets in the future.  New
Jersey is now in the process of trying to put a retread purchase
program in place, and will develop its own evaluation criteria if
the QPL does not approve a supplier.  Even if it succeeds in
arranging a contract with a retreader, the New Jersey Division of
Purchasing will have to convince fleet managers in each of the
state agencies to make use of the contract and actually buy the
tires.77

     Before mandating the use of retreads on its vehicles, a
state would probably want to establish the characteristics of its
fleets by conducting an inventory of the types and numbers of
vehicles used by each department.  Some vehicles may be kept only
a short time before trade-in, precluding the need for replacement
tires.  In some fleets, only a small percentage of tires may
be suitable for replacement with retreads.74

     Due to the decentralized nature of tire procurement in most
of the NEWMOA states, it was not possible to determine the
potential size of the region's market for retreads on state
vehicles alone.  Activity at the county or city level is unknown,
but may add significantly to the potential demand.  Further
research is needed to determine the size of the market for tires
in the public sector.  If the market turns out to be relatively
small, the success of a government program to buy retreaded or
remolded tires would be measured by its ability to encourage

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                                                               27
individual consumers to do the same, rather than by its own
contribution to scrap tire consumption.
Manufacturers Using Whole Tires

     There are very few manufacturers making finished products
out of whole tires in New England or New Jersey.  The combined
tire consumption in these applications is probably no more than
1.8 million tires per year.

     New inventions designed to consume scrap tires are sometimes
proposed.  Before such inventions are successfully marketed, it
is difficult to evaluate how practical they may ultimately be.
The proposal described at the end of this section is presented as
an example of a creative use for whole tires, but its viability
is unknown.
     Stamped Products

     F&B Enterprises of New Bedford, MA is the largest whole tire
consumer in the region.75  The company manufactures specialized
equipment used in the fishing and scalloping industries,
supplying about 400 boats.  Its products include such items as
dock bumpers, rollers, and chafing gear.  As a smaller part of
its business, F&B also makes non-pneumatic rubber wheels for
large highway lawnmowers and other vehicles used where the risk
of tire puncture is high.

     The principal manufacturing process involves stamping pieces
of the desired shapes out of the whole tire.   Bias-ply truck
tires are the most desirable raw material, although bias-ply
passenger car tires can also be used.  The company cites some
difficulty in obtaining the truck tires, and suggests this may be
due in part to lack of knowledge among potential local suppliers
that the company is seeking them.76  Another reason may be that
because of the high rate of retreading for truck tires, a
relatively small number need to be scrapped.  Due to the low
volume of local supply, the manufacturer obtains some of its
supply from as far away as New Jersey and Pennsylvania.

     Steel-belted radials can not be used in the stamping
process.  The radial tires that this company accepts are shredded
and disposed of in the New Bedford landfill.  The scraps from the
bias ply tires are chipped and sold to a crumb rubber
manufacturer in Pennsylvania.

     For some of the fishing industry applications, the products
represent beneficial additions to standard equipment that either
help the equipment perform better or last longer; the stamped
rubber products are not in competition with similar products made
of virgin materials.  The nearest competitors using recycled

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                                                               28


tires are in New Jersey and Tennessee, and do not substantially
affect the business. ' However, the majority of the company's
output, the fishing and scalloping equipment, serves a
specialized market that does not provide much opportunity for
growth.  Other markets would have to be developed in order for
business to expand.  The reliance on bias-ply tires may also
limit expansion of the stamping operation.


     Artificial Reefs

     Another application for whole tires is offshore fishing
reefs.  Cape May County, NJ has been building reefs from about
80,000 tires per year for several years.  The labor is supplied
by inmates from state correctional facilities.  Initially, there
was some difficulty from the reefs being broken apart by the
tide, but this problem was solved.  Atlantic County is now
applying for permission from the state to use tire reefs.  The
county would consume up to 15,000 tires per year.77

     The growth potential for this application is probably small.
New England waters tend to be rougher than those off New Jersey,
and breakage of the reefs might be more of a problem further
north.  Furthermore, the cost of reef construction may be as high
as $2.50 per tire disposed.78  This expense may be hard for a
state to justify on solid waste disposal grounds.   The cost may
be justified if the value of the fish habitat created, but this
determination would require further research.  Since fishing
reefs are a public good, it is unlikely that the private sector
would become engaged in constructing them, even if they represent
a socially beneficial way of recycling scrap tires.


     Mats and Liners

     At Tire Salvage, Inc., a small mat manufacturing operation
is conducted as a sideline to the tire disposal facility.  Whole
bias-ply tires are cut into strips and woven into mats that can
be used as truck bed liners, carpet pads, door mats, or other
applications.  The operation is currently consuming about 6,000
bias-ply tires per year.79  Even if this rate doubles,  as the
company plans, total output will remain small.

     Despite the size of the tire disposal operation at Tire
Salvage, the company claims that the number of bias-ply tires
coming in is sometimes insufficient to keep the mat operation
with a constant supply.  In general, tire pile clean-ups tend to
yield more bias-ply tires than do current discards because they
contain a higher proportion of old tires.  When the incoming
supply of bias-ply tires is low, the company can retrieve some
from the pond.  In fact, such retrieval accounted for more than
half the tires made into mats.80  This would suggest that other
businesses that would rely on bias-ply tires as their raw
material might experience unreliable supply.

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     Tire Tubing for Road Culverts or Septic Systems (Proposed)

     A Connecticut inventor has patented a means of connecting
tires sidewall-to-sidewall to create tubing for a variety of
purposes.  One proposed use is as a replacement for concrete or
plastic in road culverts and drains.  The tubes could be supplied
in five or ten foot lengths of various diameters.  A mile of
tubing would consume about 10,000 tires.  The inventor claims
that they would cost one-third to one-half less than the concrete
or plastic currently used, and would last 75 years longer.81

     Another proposed use for the tubes is in home or commercial
septic systems to replace both the holding tanks and the
leachfield galleys.  Home septic leaching systems traditionally
used hollow, precast concrete cylinders placed in trenches as the
galley portion of the system.  The sewage is released slowly
through perforations in the cylinders into surrounding stones,
and is then absorbed into the soil.  More recently, polyethylene
pipes are being installed, and no stones are required.  The MATES
system would replace the concrete cylinders with perforated tire
cylinders in the trenches.  Like the concrete, the tire cylinders
would also be surrounded by stones on the bottom and sides.  The
holding tanks would be constructed of truck tires, while the
galleys would be made of passenger car tires.  The inventor
claims the system would be easier to install and cost less than
concrete, but did not make comparisons to polyethylene.  He
estimates that sales equal to 5.8% of the Connecticut market
alone could consume about 680,000 tires per year.82

     Septic system use would require approval by the agency in
each state responsible for regulating underground septic systems.
Construction and design standards would have to be developed
before the system is approved, establishing how much pressure the
tires can withstand and how much fill is needed to cover and
protect the system.  The galley system would also have to be
rated as to the amount of effective area (stone/soil interface)
per lineal foot of tubing.  This enables calculation of the size
of a system necessary to serve a residence of a given size.83

     An important concern of the state agencies would be whether
the tires would leach any harmful constituents that could
contaminate groundwater.  While there has been some research on
the leaching characteristics of tires84,  none has been
performed that used septic effluent as the reagent.  A related
health and environmental concern might be that the diameter of
the tire tube would require burial at greater depths than is
typically needed, bringing the septic effluent closer than usual
to groundwater.  Since septic leachfields are already associated
with low levels of toxins, any act that would introduce greater
risk of groundwater contamination may meet with resistance.85

     The inventor is trying to license a manufacturer to produce
and install the tire tubing systems.  He estimates that capital
expenses would total $550,000 for a business processing 700,000

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                                                               30


tires per year.86



Intermediate Material Manufacturers

     Some tire processors make a product that is useful primarily
as an input to another product or process.  For example, tire
chips or shreds may be usable as a road construction material, as
a replacement for stone in septic leaching systems, or as a soil
conditioner.  Large granules may be used in paving aggregate or
playground surfaces, while smaller sized crumb may be used in
asphalt binder, roofing, or as an input to plasticized molding
material.  This section will discuss the manufacturers of the
intermediate material and some of the market considerations they
face.


     Tire Shredding

     There are several companies that shred tires in the region.
Some are in the business simply to perform tire pile cleanups or
reduce the volume of tires destined for landfills.  Others shred
tires with the goal of selling the chips as a usable product.

     Slices or shreds to be landfilled can be produced by
equipment through which the tires make a single pass.  For shreds
that will be put to some use, a smaller and more uniform output
is often required.  The equipment to produce a 2"x2" chip
typically includes a classifier, which screens out the desired
product chip size and returns oversize pieces to the shredder for
further reduction.  In general, the smaller the shred or chip
needed, the more expensive the equipment.87  Additional factors
that raise the capital costs of shredding operations are
generators (needed where there are no utility hookups), or
trailers to make the system mobile.

     One New England business, Palmer Shredding of Ferrisberg,
Vermont, had capital expenses of about $225,000 for equipment to
process 2,000 tires per day using a stationary system.88
Sawyer Environmental Recovery of Hampden,  Maine spent about
$500,000 to establish a stationary operation that shreds 800
tires per hour.

     When trying to raise the capital for their shredding
operation,  the Palmers at first found banks unwilling to lend to
them because there were no other similar businesses they could
research to evaluate the viability of the proposal.   The Palmers
then went through the federal Small Business Administration to
secure backing that satisfied a local bank.  This process took
about nine months.90

     Operating expenses for the systems are primarily labor and
energy.  Shredding systems typically require about three

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operators to load the tires and monitor the equipment.  Energy
requirements are in the range of 200 horsepower.51  Careful and
regular maintenance appears to be critical in avoiding
breakdowns, which can be a major problem.  Both Sawyer and Palmer
have experienced breakdowns.  Sawyer claimed a breakdown could
cost the company as much as $60,000.92   Good relations with the
equipment manufacturer was cited as an important factor in
running the system.  Sawyer and its equipment supplier are
working together on improving the design both of machinery
components and the system as a whole.

     Both Sawyer and Palmer are considering adding additional
equipment that will further process their output to meet
specifications required by more higher valued uses.  Sawyer plans
to add a secondary granulator that will take the first product
and further reduce it to a "one-inch" chip that is no more than 2
inches in any dimension.  This equipment will also remove 90 to
100% of the bead wire and 50% of the cord, as specified by the
paper mill interested in using the chips for fuel.  The cost of
this equipment, including a building in which to house it, is
estimated at $350,000.93

     Palmer Shredding is considering the purchase of a granulator
that would produce crumb small enough to use for playground
surfaces or as an additive to asphalt (see discussions below).
The $500,000 price tag on the equipment is seen as a major
obstacle, however. 4

     Depending on the form of the tire slice, shred, or chip,
shredding operations may produce some byproducts.  Typically,
shredders accept tires either on or off the rim, because the rims
can be removed and sold as #2 steel.  The price obtained for the
scrap varies from $50 to $85 per ton, and is usually around
$70.95  Inner tubes can be sold as butyl rubber.   Markets for
the waste wire, which at Sawyer accounts for about 5% of the
original weight of the tire, are not readily available.  Sawyer
is currently landfilling this material, but may try to sell it to
Dragon, a Maine cement manufacturer.96

     Currently, the largest consumer of tire chips produced in
New England or New Jersey is the export market.  Two companies
that shred tires are taking advantage of this outlet:
Metropolitan Tire of Newark, NJ operates a fixed shredding
facility, and Integrated Tire of Buffalo, NY performs onsite
shredding with mobile equipment (often used to accomplish tire
pile cleanups, such as the one in Danville, NH.)  Through the
Newark exporter TDF, Inc., both are shipping chips to Greece for
use as fuel in a cement kiln.97  The exact price received for
exported chips is not publicly available, but is probably in the
neighborhood of $35 to $40 per ton98, or $14 to $16 per cubic
yard.

     Other shredders are selling relatively small amounts of
chips to potential long-term consumers who are using them on an

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experimental basis.  The prices currently charged in these
situations may be lower than what the shredder would expect as a
long-term price.  A shredding company may offer the low price to
encourage experimentation, and thus help develop markets for the
material.  For example, Palmer Shredding is charging the Vermont
Agency of Transportation only $.40 per cubic yard, plus
transportation, for tire chips to be used in a shoulder-widening
project."  This price was low enough to enable the state to try
the material in this application.

     From the perspective of the shredder, however, this may or
may not be a sustainable price.  Forty cents per cubic yard
translates to only one cent per shredded tire.100
Clearly, Palmer's tipping fee on the tires, about 55 cents each
for bulk loads101,  would represent a much larger percentage of
the business's revenue than the sale of the shreds.102

     However,, the sale price of chips may not need to cover
the cost of shredding, for the business to be profitable overall.
If by selling the chips the cost of disposal is avoided, a
company might continue to earn enough from the tire collection
side of the business.  For example, suppose a company accepts
tires for $1 apiece and would face disposal costs of $80 per ton
at a landfill or other facility.  This disposal expense is
equivalent to about $.80 per tire, or 80 percent of the revenue
generated by collection.  If the tires could be shredded and sold
at the cost of shredding, the company would avoid this
expense completely.  Even if the sale of chips did not cover the
cost of shredding, the company may find that it is worth taking a
"loss" on the shredding operation to enable it to continue the
profitable tire collection service.  An important observation is
that over a rather wide range of prices potentially obtainable
for tire chips, the tipping fee will probably remain the dominant
source of revenue for a shredding operation.  Thus, factors that
affect the tipping fee will be more important to the business
than factors that affect the price of chips.


     Crumb Rubber

     "Crumb" or "granulated" rubber is a form of recycled rubber
that contains no fiber or metal.  It can range in size from half-
inch granules down to 10, 20, or 30 mesh and smaller.  A
passenger car tire yields about 12 pounds of crumb.103   The maker
of crumb rubber closest to New England and New Jersey is the
Chambersburg, PA plant of Baker Rubber.  The combined output
of this company's plants is about 60 million pounds of crumb per
year, which represents 40 to 50% of the granulated rubber
consumed in the United States.104  A total of  about 5 million
tires per year are processed by the company, of which they
estimate 425,000 per year originate in New England or New Jersey.
An additional 280,000 come from New York.105

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     The capital costs for a whole-tire-to-crumb rubber system
that processes 8,000 tires per day (about 2 million per year) are
on the order of $3 million.  Smaller systems cost proportionately
somewhat more.106


     Rubber-Plastic Polymers

     Details on the technical and economic aspects of reprocessed
tire rubber used as a feedstock in molded products is difficult
to obtain due to the proprietary nature of the information,  the
two patented processes discussed here represent the first stages
in the process of converting scrap tires into molded rubber-
plastic products.


          TireCycle (Proposed)

     TireCycle is a patented system for completely recycling
scrap tires into materials that serve as inputs to other
processes.  The tires are first shredded and ground to various
sizes, and all metal and fiber are removed.  The rubber particles
are then treated with a series of patented liquid polymers that
aid in the blending of the rubber with plastics or virgin rubber.
The finished TireCycle product can be supplied in powder, pellet,
or compound form.  The fiber component will be sold to Teledyne-
Honarch, and the metal will be sold to scrap dealers.107

     In 1989, a TireCycle facility that was subsidized by the
state of Minnesota closed due to financial and other
difficulties.  Nevertheless, a New England entrepreneur, has
purchased a license from the patent holder, Rubber Research
Elastomerics of Minnesota, and is trying to set up a plant in
Rhode Island that would use the same technology.  At full
capacity, the plant would consume 3 to 4 million tires per year,
producing 72 million pounds of rubber product, and 14 million
pounds each of fiber and metal.  TireCycle of New England
believes that the problems faced in Minnesota, including the need
to retool the plant twice, and the plant's location hundreds of
miles from the nearest source of tires, would not be factors in
Rhode Island.108

     TireCycle of New England will not be involved in the tire
collection business.  It will rely on the existing trucking
system to supply the material.  At first, the company expects to
be able to collect a tipping fee on the tires, but believes the
operation will be sufficiently profitable that it would
eventually be able to pay for tires, if that becomes necessary.

     According to the company, the current demand for the
principal TireCycle product is on the order of 130 million pounds
per year.109  No independent verification of this figure is
available.  Among its potential customers, the company cited two
tire manufacturers and a major producer of molded rubber

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household products.  Demonstration quantities of the product have
already been provided to these firms.110

     One potential problem the company forecasts in developing
some markets is that a manufacturer might demand more of the
product than one plant could produce.1"  This is the  problem of
minimum efficient scale: it may not be worthwhile for a
manufacturer to develop a consumptive use of the feedstock below
a certain volume.  While two or more plants the size of the one
planned for Rhode Island might produce enough for such a
customer, investors are usually unwilling to finance such a large
project without some demonstrated success on a smaller scale.
Furthermore, a customer may be hesitant to develop a production
line that depends on a single supplier for an important input; if
the one supplier goes out of business, the investment in that
production line will have been wasted.

     Currently, the principal constraint on TireCycle of New
England is raising the $10 million in capital necessary to
purchase property and begin construction.  Once the company
raises $2 million from private sources and finds a site for the
facility, it will be able to apply to the Rhode Island Industrial
Facilities Corporation for state-issued taxable industrial
revenue bonds.  The terms of such bonds are generally more
favorable than what can be obtained in the private capital
market.112

     The Rhode Island Department of Economic Development is
helping TireCycle locate a site for its facility.   The company's
advocate at the DED has been advised by staff of the Department
of Environmental Management's Office of Environmental
Coordination that the TireCycle process is a good one.  Given the
state's opposition to the Exeter Energy tire incineration
facility in Sterling, CT, it is perhaps not surprising that the
DEM is supportive of the TireCycle proposal.  However, there is
no formal means by which the Departments of Environmental
Management or Economic Development can influence the decisions of
the quasi-public corporation that approves applications for
industrial revenue bonds.113


          Typlax

     R.W. Technology of Cheshire, CT has also developed a
patented process for recycling tires that combines granulated
rubber with plastics to make a polymer suitable for injection
molding.  The capital costs of setting up a plant can range from
$5 million to $30 million, depending on capacity.114   So  far,
R.W. Technology has one licensee, American Typlax Systems of
Washington, PA, which is still in the process of setting up its
plant.  At full capacity, expected to be reached in 1992,
American Typlax will collect six million tires and produce 150
million pounds of product per year.115

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     According to American Typlax, the firm's products will  -
participate in the 30 billion pound per year "non-visible" share
of the nation's 57 billion pound total plastics market.116
This refers to products such as piping or industrial goods for
which appearance is not important.  Demonstration quantities of
the product have also been provided to manufacturers of
automotive carpet backing and compartmentalized containers.

     R.W. Technology and American Typlax have considered
licensing additional companies to use the technolpgy.  Currently,
the midwest seems a more likely site for a second plant than the
northeast.  The high costs of land, labor and electricity in the
New England were cited as obstacles to locating there.
Electricity is a major operating expense in the Typlax process;
according to American Typlax, the cost of electricity in
Pennsylvania is less than half that in New England.1*7


     Pyrolysis

     Pyrolysis is the thermal decomposition of a substance in the
absence of air or oxygen.  The pyrolysis of tires yields such
products as oil, gas, and carbon black.  Research and
experimentation with tire pyrolysis is ongoing, but little
commercial activity is taking place because the process has not
yet proven to be economically viable.  Recent process
improvements may change this, however.  A company that plans to
build a commercial-scale plant in Detroit, MI estimates the
capital costs of a tire pyrolysis plant at $4 to $5 million.118
No proposals for building tire pyrolysis facilities in New
England or New Jersey were discovered as of this writing.
Consumers of Intermediate Products: Tire-Derived Fuel

     The rubber in tires is a synthetic made of petroleum
products.  When burned, the heat content of tires is comparable
to that of other fossil fuels.  "Tire-derived fuel", or TDF, is a
term that is used loosely to describe any whole or reduced form
of tires that can be burned.  Depending on the degree of
processing, it may be referred to as tire chip fuel, which has a
high percentage of the tire wire remaining, or rubber derived
fuel, with most or all non-rubber materials removed.  Since the
metal in tire chips does not burn, the heat value of TDF
increases with the percentage of wire removed.

     Table 4 lists the average heat content for several types of
fuels, including TDF.  Measured in terms of BTUs per pound, TDF
(with some of the wire removed) contains about 21% more heat
potential than bituminous coal; tire chip fuel contains about 11%
more.119   The differential  is  greater  for  other  grades  of  coal.
Understanding that it is primarily the heat content of a fuel the
industrial consumer is buying is important to understanding how

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                                                              35A
                            Table 4
                   HEAT CONTENT OF COMMON FUELS
         Fuel


         Gas

         Oil

         RUDF

         TDF

         TCF

         Coke

         Coal

         Coal

         Coal

         Wood
Grade


Natural

No. 6 "Bunker C"

Rubber Derived Fuel

Tire-Derived Fuel

Tire Chip Fuel

Petroleum

Lignite

Subbituminous

Bituminous

Wet Wood ("Hog Fuel")
Average Heat Content


1,000 BTU/cu ft

151,000 BTU/gal

16,000 BTU/lb

15,500 BTU/lb

14,200 BTU/lb

13,700 BTU/lb

 7,300 BTU/lb

10,500 BTU/lb

12,750 BTU/lb

 4,375 BTU/lb
Source: Rouse Rubber Industries, Inc., as presented in testimony
given by Mike Rouse before the House Committee on Small Business,
Subcommittee on Environment and Labor and Subcommittee on
Regulation, Business Opportunity and Energy; Hearing on Scrap
Tire Management and Recycling Opportunities, 10 April 1990.

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                                                               36


TDF competes with more conventional fuels.

     The costs of different fuels are typically compared as price
per million BTU.  Thus, tire chips selling for $45-55 per ton
cost from $1.29 to $1.77 per million BTU.120   Bituminous  coal
selling for $55 to $65 per ton costs the equivalent of $2.11 to
$2.50 per million BTU.  Even on the basis of equivalent heat
content, some fuels command a higher price than others.  Oil is
typically more expensive than coal, which in turn in more
expensive than wood, for the same heating value.

     Since TDF competes most closely with coal as an industrial
fuel, the lowest price for coal may be viewed as the ceiling on
the selling price for TDF, when both are expressed in terms of
heating value.  To compare this price with prices obtainable for
tire chips in other applications, it is more useful to express
the price in cost per ton, per cubic yard, or per tire.  If chips
could be sold for $2.40 per million BTUs (an average price for
coal delivered to industrial users is Maine121) ,  that would  be
equivalent to $74.40 per ton (= $2.40/million BTU x 31 million
BTU/ton).  This ceiling price is also equivalent to $26.57 per
cubic yard or 60 cents per tire.122  At  a hypothetical  selling
price of $55 per ton123, TDF would  earn  $19.64  per  cubic  yard or
45 cents per tire.   Thus, it appears that TDF manufacturers
willing to sell their product at $55 per ton would be competitive
with coal on the basis of heating value.

     Some industrial facilities, particularly those designed to
handle mixed fuels, are capable of replacing a portion of their
conventional fuel supply with TDF.   Among the characteristics of
a facility that may potentially burn TDF are the ability to
withstand very high temperatures and the ability to hold solid
fuel long enough for complete combustion.   Furnaces that burn
coal on a grate are often mentioned as candidates for burning
tire-derived fuel.  Facilities that already have significant
pollution control equipment in place are also better positioned
for considering TDF.

     The two types of plants most frequently discussed as
consumers of TDF are cement kilns and pulp and paper mills.
Currently, two cement kilns in this country are burning TDF, as
are several pulp and paper mills.  None of these facilities are
located in New England or New Jersey.   As indicated earlier,
however, there is a high probability that at least one paper mill
in Maine will soon begin using TDF, and an additional four or
five mills in that state have the type of boiler that can
accommodate TDF.  A cement kiln, also in Maine, may be capable of
burning whole tires at some point in the future.  The
following sections discuss the use of TDF by paper mills and
cement kilns in greater detail.

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                                                               37


     Pulp and Paper Mills: Champion International

     Multi-fuel paper mills typically burn a combination of oil,
coal, and biomass.  The oil and coal are used to boost the total
BTU content of the fuel and control the burning of wood and
sludge wastes.  TDF has been successfully shown to replace some
of the coal in multi-fuel boilers.

     The Champion mill in Bucksport, ME started experimenting
with TDF three years ago.  It expects to receive amendments to
its licenses from the Maine Department of Environmental
Protection (DEP) during the fall of this year that will allow it
to burn TDF on a regular basis.  Champion's experience provides
an instructive case study on some of the important issues facing
a paper mill considering the use of TDF.

     Champion's first trial burns used locally supplied tire
chips that had most of the wire remaining in them.  These chips
caused mechanical problems in the fuel conveyor system.  Champion
then tried chips from which 75% to 80% of the wire had been
removed.  These chips, supplied by a shredder in Georgia, proved
more satisfactory.124   Champion paid only the cost of
transportation for the TDF from Georgia. 25

     Champion conducted test burns using up to 3.5 tons of TDF
per hour.  This accounted for roughly 5% of the total BTU content
of its fuel.126  Initially,  the plant engineer encountered some
technical difficulties with the new fuel.  For example, the rate
of ventilation had to be adjusted to account for differences in
the TDF's burning characteristics as compared to the low-sulfur
coal it was partially replacing.  Eventually, however, the higher
temperatures at which the boiler operated with the TDF enabled
more complete combustion of the sludge.127  A shutdown inspection
of the boiler in May 1990 confirmed that no damage had occurred
as a result of tests with the new fuel.128

     Both the Bureaus of Air and Solid Waste Management of the
Maine DEP have been involved in the monitoring of Champion's TDF
experiments, and in amending the plant's licenses.  One area of
concern to the Solid Waste regulators is the storage of chipped
tires.  They are investigating precautions to avoid arson or
accidental fire.  They are also concerned about a backlog of TDF
accumulating if the boiler needs to be shut down and the fuel
continues to be delivered.129

     According to the Bureau of Solid Waste Management, the
composition of the mill's ash does not change much when TDF is
burned; while the concentration of zinc  increases, cadmium and
lead levels are lower.130  The  ash does  not  qualify as a
hazardous waste131 and will continue to  be disposed of at the
mill's own landfill, along with sludge and general mill wastes.

     According to the Air Bureau, stack  tests were conducted with
TDF burned at the rates of 1.5, 2.5 and  3.5 tons per hour, and

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                                                               38


were compared to baseline emissions per unit of heat produced.
The only significant difference in emissions was for zinc, which
went up almost ten-fold when TDF was burned at 3.5 tons per hour.
Other results were a slight increase in cadmium, decreases in
beryllium and chromium, and no significant change for lead,
hydrocarbons, SO2 or NOX.132  The facility's current license
does not specify a limit on zinc, but the new license will
include limits for several heavy metals, including zinc.133

     Maine regulations normally require that any change in fuel
other than that specified in the license constitutes a
"modification1* of the facility and requires a new license.  To
get a new license, the facility must submit to Best Available
Control Technology (BACT) analysis for environmental controls.
This type of analysis includes consideration of technical,
environmental, and economic factors.  However, Champion
International presented a bill to the legislature earlier this
year to obtain an exemption from the BACT analysis requirement
for industrial boilers that switch to TDF.  The bill passed and
became effective 15 July 1990.134  A BACT analysis  of  the
facility might have taken three or four months; it is not clear
whether the results of the analysis would have suggested any
changes in environmental controls.135

      A spokesperson for Champion estimated that the emissions
monitoring conducted during the trial burns and the testing of
the ash cost the company about $50,000.136  In addition, the
company expended considerable human resources on the TDF project
in terms of the time and effort of environmental engineers,
public relations specialists, attorneys, and headquarters
executives.  In exchange, Champion expects to save about $500,000
per year on fuel costs and is "excited to part of the solution to
a problem" by consuming up to 3 million tires per year.137


     Cement Kilns: Dragon Products

     Cement kilns are frequently mentioned as ideal consumers of
tires as fuel.  Among the advantages of burning tires at these
facilities are that the exceptionally high temperatures allow
thorough combustion, the plants usually have sufficient
environmental controls already in place, and they have the
capacity to incorporate some or all of the steel slag into their
finished product, thus reducing the volume of byproducts.  Cement
manufacturers in the U.S., Germany, Greece, and Japan, have kilns
that burn whole tires.138

     The only cement kiln in New England  is operated by Dragon
Products in Thomaston, ME.  This is a "wet process" kiln and is
currently incapable of burning tires unless ground very fine.
Dragon is frequently approached by tire chippers who wish to sell
TDF, but the chips are too large to be used in this type of
kiln.139

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                                                              39


     However, the company is considering converting the kiln to
the "dry process".  This major capital modification would not be
undertaken specifically to enable the burning of whole tires, but
the capacity to use tires as fuel would be one of its benefits.
The cost of the conversion is estimated at $4 million for design
and construction.  Additional conveyor equipment would be
necessary for handling tires, but its cost would be insignificant
in comparison to the primary plant modification.  The earliest
that the conversion would take place is 1993 or 1994.  Once
converted, the kiln could consume 3.75 million tires per year,
which would represent about 25% of its fuel needs.140

       According to Garrett Morrison of Dragon Products, one
concern about using tires would be the ability to secure a
sufficient supply on a regular, long-term basis.141   Given the
avoided cost of coal consumption, however, Dragon may be able to
provide a very competitive means of tire disposal that would
ensure it of adequate supplies.  Unlike companies that charge a
tipping fee to dispose of tires, Dragon may be able to offer to
pay for whole tires.  The amount they would be willing to pay
would depend on how much is saved through lowered expenditures on
coal.

     To estimate a lower bound on the annual savings to Dragon
from burning whole tires, we can estimate the fuel value of whole
tires and figure how much coal the tires would be replacing.  If
the heat content of whole tires is 12 to 14,000 BTU per pound,
3.75 million tires at 20 Ibs each would be the equivalent of at
least 900,000 million BTU.  The bituminous coal that the plant
currently burns has a BTU value of 12,500 BTU per pound and
costs about $45 per ton.142   Thus,  36,000  tons  of  coal  could be
replaced, saving the company about $1.62 million per year.  On a
per-tire basis, the lower bound estimate of Dragon's savings is
$.43 for every tire burned (= $1.62 million / 3.75 million
tires).

     This suggests that Dragon should be willing to pay up to
$.43 per tire.  Given that most other New England disposal
options will probably be charging tipping fees for whole tires,
however, it seems unlikely that Dragon would actually have to pay
anything for its tires.  More likely, it will be able to collect
a tipping fee, further increasing the profitability of burning
tires.
Consumers of Intermediate Products:
Roadway Maintenance and Construction

     The feasibility of using crumb rubber as an additive to
paving materials has been a subject of research and
experimentation since the late 1960s.  Engineers have developed
several different ways of incorporating crumb rubber into paving
and pavement repair materials, and all the northeast states have

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                                                               40


had at least some experience with one or more of these methods.
More recently, some states have begun looking into the potential
for using tire chips in various road construction and maintenance
projects.  These applications include slope stabilization,
embankment fill, and subgrade road beds.  This section will cover
the status of research in these areas, and the economic and other
factors that would affect the use of tire-derived materials in
roadway projects.


     Crumb Rubber Additives to Asphalt Cement

     There are two principal means of incorporating crumb rubber
into asphalt.  The more common method calls for the addition of
tire buffings (a byproduct of retreading) or fine mesh crumb
rubber to the asphalt binder.  During the heating and blending
process, which requires specialized equipment, the rubber has an
opportunity to react with the asphalt, forming a thick, elastic
material.  This process is referred to as the "wet" or "Arizona"
process, and the product is appropriately called "asphalt-rubber
binder" or "pre-reacted asphalt rubber".  It can be used as a
crack/joint sealant for maintenance purposes, or as a surface
treatment.  For the latter, the asphalt-rubber binder is sprayed
on the road at a thickness of about 0.6 gallons per square
yard,143 and  is  then covered  with  aggregate  and  rolled.   This may
serve as the driving surface, or it may be covered with
additional pavement.144  The  surface treatments  are patented
processes.

     Crumb rubber accounts for at least 15% by weight of the
asphalt-rubber binder,145  and as much  as 30%.rt6  In New England,
the typical range is 18 to 25%.147 Once the aggregate  is
included, the rubber accounts for only 1 to 2% of the total
weight of the material.148

     The other means of incorporating rubber into asphalt is
known as the "dry" process, or "hot mix" application.  It
involves the replacement of some of the mineral aggregate with
rubber particles of various sizes.  "PlusRide" is the patented
trademark for the replacement of specific sizes of aggregate in
specified ratios.  The rubber accounts for 3% of the PlusRide
mix.  Generic (unpatented) versions of this process are also
used, in which various sizes of aggregate are replaced with
corresponding sizes of crumb.  The results are sometimes referred
to as "rubber-filled" pavements or "rubber-modified asphalt
concrete" (RUMAC).

     Many advantages are claimed for both asphalt-rubber binder
systems and rubber-filled pavements.   They include better
longevity with less cracking, better traction or less skidding,
reduced glare, reduced noise, and faster melting of ice, as
compared to conventional asphalts.  Despite the numerous
experiments by cities and state departments of transportation,
however, it is difficult to characterize the use of asphalt

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                                                              41


rubber or rubber modified asphalts as either successful or
unsuccessful.  In some cases, asphalt-rubber or rubber-filled
pavements have outlasted their conventional counterparts; in
others, they have deteriorated more rapidly.

     Generalizing about the success of the pavements is
complicated by variables characterizing both the application
method and the site.  Among the application variables are the
percentage rubber incorporated, the size of the particles, the
mixing and laydown temperatures, and the thickness of material
applied.  Then, an application technique that appears to work in
one setting may not work in another due to site-specific
conditions.  These variables may include climate, slope, traffic
load, or whether the new pavement is laid over cracked, old
pavement or a new base.  Technical reports have been prepared for
many of the individual road, bridge and airport runway projects
in the region.  A comprehensive evaluation of the results is
clearly needed, however.


          Tire-Consuming Potential

     A useful way to think about the tire-consuming potential of
asphalts containing crumb rubber additives is to express the
number in terms of tires consumed per mile paved.  Caution must
be taken in interpreting this ratio since it is sensitive to such
variables as the thickness of the pavement and the proportion of
rubber in the material.

     The following estimates for a two-lane road (36 feet wide)
with 2-inch thick pavement are based on industry estimates,
adjusted for local practices:


                    Tires Consumed      Miles Needed to Consume
                       Per Mile           One Million Tires

Asphalt-Rubber
Binder System149               5,469              183

RUMAC  (patented
or generic)150           11,080               90
More research is needed to adjust these estimates for different
paving practises in specific locations.  More research is also
needed to determine the miles of roadway in the NEWMOA states for
which these applications might be practical.

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                                                               42


          Costs and Cost-Effectiveness

     The initial costs for either of the rubber-added pavements
are higher than for conventional asphalt concrete.  Rubber-
asphalt binder may cost as much as $350 per ton, as compared to
$120 per ton for conventional binder.151   Specially designed
equipment is needed to spray the rubber asphalt binder on the
road.  Some experts say the total costs of a rubber-asphalt
pavement, including aggregate and construction, may be 50 to 100%
higher than for a conventional asphalt concrete pavement.152

     For the PlusRide or generic rubber-modified asphalt
concretes, the extra expense is encountered for the aggregate mix
containing the rubber.  The crumb rubber itself costs about $.12
per pound, or $7.20 per ton of PlusRide mix.  According to one
New Jersey contractor, adding the rubber to the mix takes more
labor, requires more fuel to achieve higher mixing temperatures,
and results in a slower production rate than the manufacture of
conventional mixes.  In addition, the plant can not make
conventional asphalt mix on the same day, but must be dedicated
to making the special mix for a given period of time.153   This
suggests there would be economies of scale if a plant could
specialize in mixes containing rubber.

     Two more factors lead to a higher cost for RUMACs.  First,
both the PlusRide and generic versions require a greater amount
of binder, the more expensive component, as a percentage of total
material.   Whereas conventional asphalt concrete  is 6% binder,
generic RUMAC is 7% binder and PlusRide is 7.5% binder.154
Second, contractors using the PlusRide formula must also pay a
royalty of $2.50 to $4.50 per ton, depending on project size, to
the holder of the U.S. and Canadian marketing rights.155

     Other factors may offset the higher price per ton for the
PlusRide or generic rubber-filled mix.  For example, the lower
density of the rubber-filled mix allows one ton to cover a
greater area.  The increase in yield per ton of PlusRide is
approximately 6%.156   More significantly,  the ability to  obtain
the same level of performance from a thinner layer of pavement
would offset the higher cost per ton.  The City of Newark
calculated that by laying the PlusRide mixture at  a thickness of
only 1.5", as compared to 2M for conventional mix, the final cost
of the aggregate was virtually equivalent.157


          Costs per Tire Consumed

     One way of looking at the economics of using  tire rubber
in asphalt mixes is to compare the cost per tire consumed.  This
can be estimated by assuming that pavements containing rubber
additives are identical in performance to conventional asphalt,
and then spreading the increase  in cost for the rubber-consuming
pavements over the number of tires consumed by each.

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                                                               43


     To maintain consistency with the above estimates for tire-
consuming potential, we again consider a 36-foot vide two-lane
road, one mile long. .The cost of asphalt mix for a conventional
pavement, two inches thick, is $76,032. 15S  The cost  for mix
that uses asphalt-rubber binder is $110,168. 159   Subtracting the
cost of mix for the conventional pavement, and dividing  by the
5,469 tires consumed, the cost per tire is approximately $6.24.

     The cost of the generic RUMAC process mix for the one-mile
road is $90,911. 16  This translates to a cost of $1.34  per  tire
consumed.

     Since one of the advantages claimed for the crumb-rubber
additives is that they allow for the use of thinner pavements, we
can also compare the cost of a 1.5-inch rubber-added pavement to
the cost of the 2-inch conventional pavement.  These calculations
yield a per-tire cost of $1.61 for the asphalt-rubber binder
system, and a savings of $0.95 per tire for the generic  RUMAC
mix.  Of course, thinner pavements will consume fewer tires than
thicker pavements.

     The above cost estimates for a one-mile long two-land road
are summarized as follows:

               2" Conv        2" A-R     2"     1.5" A-R    1.5"
               Asphalt        Binder    RUMAC    Binder     RUMAC

Installation
Cost            $76,032     $110,168   $90,911   $82,626  $68,142

Tires Consumed               5,469    11,080     4,102    1,662

Savings (Cost)
per Tire                      ($6.24)  ($1.34)    ($1.61)   $0.95


     To compare the overall cost-effectiveness of any RUMAC or
asphalt-rubber pavement to conventional pavements, additional
information is needed.   After initial costs are considered, the
degree of maintenance and the time until the section will require
repaving (the pavement's "design life") are also relevant.   Some
of the current research on asphalt-rubber pavements focuses
specifically on estimating the design lives of various
thicknesses under various conditions,  or determining what
thickness needs to be used to achieve a desired design life.161
Once maintenance and rehabilitation factors are added, better
estimates of the discounted "lifecycle" costs of the pavements
can be made and compared.  These may differ substantially from
those presented above.

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                                                               44


          Planning and Budgeting Considerations

     Understanding the design life of a pavement and being able
to calculate its lifecycle cost are important for planning
highway maintenance schedules.  The timing and predictability of
pavement maintenance requirements are important to planners who
want to know how many projects can be accomplished with a given
budget, and how long they can expect them to last.

     Even if pavements containing crumb rubber additives prove to
be cost-effective from the point of view of those responsible for
highway construction and maintenance, procedures for allocating
maintenance and construction funds may pose an obstacle to their
use.  The Federal Highway Administration requires that states
have a pavement management system that ranks pavements in the
state according to the degree and timing of the reconstruction or
rehabilitation they are expected to need.  Mathematical equations
considering many variables are usually involved.  Once the
pavements are ranked, the state must follow a strategy for
addressing the problems in each class.  In essence, this strategy
is an optimizing model that attempts to fix the most lane-miles
for the least amount of money.162

     A principal constraint in this system is the amount of money
available at a given time.  It may be that the most efficient
long-term solution for a particular pavement section would be to
use a treatment that has high initial costs, but would be
expected to last a relatively long time.  If, many pavements are
in need of immediate attention, however, and currently available
funds can cover only low-cost, short-term repairs, the more
efficient long-term solutions may not be possible.
Transportation officials may be constrained from choosing a more
durable, high cost treatment for one section if it will mean
other sections will have to go untreated.  Short-term budget
constraints will tend to work to the disadvantage of pavements
characterized by high initial costs but greater longevity, such
as those using crumb rubber additives.


          Factors Affecting Costs in the Future

     The patent on PlusRide will expire in 1992 and the patents
on the asphalt-rubber binder systems will expire later in the
decade.  In addition,, economies of scale might be available if
there were a greater demand for crumb rubber additives.  One
example, cited above, might be the savings realized at a hot mix
plant that makes the hot mix by not having to switch back and
forth between producing mixes with and without rubber.  Another
factor that could bring down the cost of the crumb rubber itself
would be a locally available supply.  Currently, the crumb rubber
used in northeast paving projects comes from Pennsylvania and
Ohio.  Finally, an increase in the number of contractors who use
crumb rubber additives might increase the competition in this
field and lead to lower bids on projects.

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                                                               45
          Recyclability Issue

     A final issue that must be resolved is whether pavements
containing crumb rubber additives are recyclable.  Currently, old
pavements can be recycled into new paving material, eliminating
the need to dispose of great quantities of waste.  If pavements
made with crumb rubber additives are not recyclable, the
technology may eventually exacerbate the solid waste problem,
rather than help solve it.  Proponents of crumb rubber additives
claim the new pavements are recyclable, but other have expressed
concern on this question.163


     Tire Chips in Transportation Construction Projects

     Several uses for whole, sliced or chipped tires in
construction projects have been proposed.  In most of these
applications, tire chips would serve to replace or augment
regular or lightweight fill material, as in embankments, for
subgrade road beds, for slope stabilization, or as backfill
behind retaining walls and bridge abutments.  Tire chips have
also been proposed as a replacement for stone in roadway
subdrains.  4 Additional  proposed uses of  waste  tires  include
mats of tires tied together to strengthen soft subgrades, tire
retaining walls, and sound barriers consisting of mounds of tire
rubber that are covered with soil and then landscaped.165


          Physical Properties

     Important characteristics of tire chips as a construction
material are that they are light in weight and very porous.
These properties are attractive for uses in swampy areas and
where good drainage is needed.  Since tire chips are not subject
to rotting, they present an advantage over wood chips and sawdust
under conditions where biodegradation might be of concern.166
On steep terrain, tire chips can be used to help hold ordinary
fill in place and prevent slope failures.

     Transportation engineers have expressed a need for more
research and experimentation to better understand the properties
of tire chips in construction applications.  Specifically, they
need more information on the material's compressibility,
resiliency, and weight-bearing capacity, by itself and in
combination with other materials.  Currently, researchers at the
University of Maine are conducting a study funded by the New
England Transportation Consortium that will address
compressibility, weight-bearincr capacity, and the use of tire
chips behind retaining walls.16'  Compaction and  compressibility
of tire chips are also being investigated by researchers at the
University of Wisconsin, where a test embankment has been
constructed as part of a landfill access road.  The embankment

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                                                               46


has sections in which tire chips are used alone, mixed with
onsite soil, or layered with soil.168


          Environmental Concerns

     Another question that must be resolved before tire chips are
used in some construction applications is whether they will leach
harmful substances.  This was the focus of a recent study for the
Minnesota Pollution Control Agency,169  and is  a component  of  the
University of Wisconsin study, cited above.  The Minnesota study
indicated potential problems with barium, cadmium, chromium,
lead, selenium, and zinc under sufficiently acidic laboratory
conditions, and with polyaromatic hydrocarbons under basic
conditions.  The study recommended that "the use of waste tires
be limited to the unsaturated zone in a roadway designed to limit
infiltration of water through the waste tire subgrade. I|17 The
Wisconsin study concluded that shredded tires pose little or no
likelihood of affecting groundwater.171  Both  reports  cited the
need for additional field studies.


          Recent Projects

     A limited number of projects using tire chips in roadway
projects are being tried in New England.  In Georgia,  Vermont,
the town is experimenting with the use of tire chips to provide
better drainage on a dirt road that becomes impassably muddy in
the spring.17*   For this  project,  the top two  feet of  a  400
foot length of road were excavated.  Two hundred cubic yards of
chips were then placed in the roadway at a depth of one foot.
The dirt and gravel were then replaced, and the chips compressed
to a depth of about three inches.  The outcome of this experiment
will not be known until the spring.  Another project in Vermont
is using tire chips to flatten and widen a roadside slope,
creating a shoulder and eliminating the need for a guardrail.173
The chips represent 60% by volume of the total fill material
needed for the job.


          Tire-Consuming Potential

     Most of the proposed applications for tire chips in road
construction projects would involve using the chips in place of
or to extend other fill material.  State transportation agencies
typically classify fill in several different grades, and these
classifications may vary by state.  To obtain a rough estimate of
the volume of tire chips that might be used as fill replacement,
state transportation officials provided estimates of the amount
of low-grade fill or common borrow currently used in a year.
These estimates are as follows:

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                                                              47
          State                 Volume of Fill

          Connecticut174         250,000  cubic yards  (CY)
          Maine175               250,000  to  300,000 CY
          Massachusetts         no estimate available
          New Hampshire176       300,000  CY
          New Jersey177          220,000  CY
          Rhode Island178        300,000  to  375,000 CY
          Vermont179             250,000  CY

     These figures are easily converted to numbers of tires using
the rule of thumb of 40 whole passenger car tires to one cubic
yard of tire chips.  The following table converts the above
figures to whole tires, and calculates the number of tires that
could be used if 10% of the fill volume is replaced with tire
chips:


                         Whole Tire     Potential Annual
                         Equivalents    Consumption
     State               (millions)     at 10% Replacement
     Connecticut         10
     Maine               10 to 12
     Massachusetts       ?
     New Hampshire       12             1,200,000
     New Jersey           8.8             880,000
     Rhode Island        12 to 15       *~	~"~
     Vermont             10
1,000,000
1,000,000 to 1,200,000
7
1,200,000
  880,000
1,200,000 to 1,500,000
1,000,000
     Tire chips are not the only material being considered as a
replacement for fill.  State transportation agencies are also
investigating opportunities for construction projects to consume
demolition debris, glass, plastics, synthetic aggregates made
from sewage sludge, and vitrified toxics.  Both the physical
properties and the costs of using these materials will be
instrumental in determining which, if any, will be used.

     In New Jersey, the Department of Transportation's Recycled
Materials Task Force is actively seeking materials that could
replace some percentage of the borrow currently purchased.  They
have set an informal first goal at 10%, which may be increased.
Glass, because it is so similar to the sand already used, is the
material the NJ DOT is likely to approve first.180
          Cost Factors

     The materials with which tire chips typically will be
competing for roadway applications are common borrow,  sand,  and
gravel.  The prices paid  for these materials vary substantially
across the region.  In Rhode Island, for example, the  common
borrow used in roadway reconstructions ranges from $2  to  $10 per

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                                                               48


cubic yard, and averages about $8 per cubic yard.181   In Maine,
the price of common borrow is in the range of $2 to $3 per cubic
yard.182   Lightweight  borrow  may  cost  several  times this.183
The New Jersey DOT is currently paying about $13 per cubic yard
for borrow/fill.184  Some  of  this variability  may  be due to the
proximity of construction sites to the source of the material,
and the cost of transportation.

     The prices of other competing materials also vary.  In
Vermont, crushed stone is only about $3 per cubic yard'185  but
may cost considerably more in southern New England.  In New
Jersey, the crushed glass that is used to replace aggregate in
bituminous concrete applications costs about $4.80 per cubic
yard.186   Glass  to be  used as fill  will not  need to be crushed as
finely, and may therefore be cheaper.

     In general, where tire chips can be used to replace
conventional construction materials, the prices of the
conventional materials will serve as a ceiling for the price  of
the tire chips.
Consumers of Intermediate Products: Play Surfaces


     Tire rubber's resiliency and low compactibility properties
have led to uses in athletic and play surfaces.  Crumb rubber can
be used as a soil amendment for grass turf or as a "soft bulk"
surface for playgrounds, jogging trails, and horse arenas.  As a
soil conditioner for athletic fields, the material offers the
opportunity to reduce watering and aeration; the technique is
promoted primarily as a means of softening the turf and saving on
maintenance costs, and its expense would have to be justified on
those grounds.  As a soft bulk surface, crumb rubber competes
with a variety of other materials that vary with respect to
physical advantages and disadvantages, as well as cost.


     Soil Conditioning

     A Colorado company is currently promoting the idea of
rehabilitating football fields by adding crumb rubber to the top
layer of the soil to produce a less dense turf.187   This patent-
pending process involves the removal of the top six inches of
soil and combining it with metal-free 1/4" crumb rubber.  Yard
wastes and sewage sludge can also be incorporated in the
procedure.  The rubber typically accounts for about 15% of the
total volume of the soil mixture.  The soil is then replaced on
the field, with new sod or seeding on top.  As of 1987, the
Environmental Protection Agency, Region VIII did not oppose the
use of crumb rubber as a soil amendment based on its chemical
characteristics.18a

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                                                               49


     The advantages claimed for the process are better survival
of the grass, fewer bald spots, less water needed (30-80%), lower
maintenance costs, less compaction of the turf, and fewer or less
severe injuries due to the softer surface.  The most beneficial
applications are likely to be where the turf is most heavily
trafficked.  The rubber additive seems to help worn turf
recuperate itself, without the need to reseed.  Savings on
maintenance may include the costs of aerating the soil,
fertilizing, reseeding, and special care during the germination
of the grass seedlings.

     In 1988, Colorado State University used this system to
rehabilitate a football practice field.  The project consumed
120,000 pounds of crumb rubber, the equivalent of 10-12,000 tires
at 10-15 pounds of crumb per tire.  The cost of the crumb, not
including transportation, was $.10 per pound, or $12,000.  This
represents one-sixth of the total installation cost of about
$72,000.  The CSU installation is expected to last at least 25
years.189   Artificial  turf,  by comparison,  costs  about $1 million
to replace every 8 years, and the best natural turf may cost up
to $80,000 per year to maintain.190

     A study is currently underway at Michigan State University
to evaluate the effectiveness of crumb rubber as a soil
amendment.  The preliminary findings of controlled experiments on
a football practice field and on heavily trafficked plots of a
golf course indicate better survivability of the grass and a
softer surface.191  Data are also being collected on the severity
of football injuries on the experimental versus control turf, but
are too preliminary to evaluate yet.

     Data are not available on maintenance cost savings resulting
from either the Colorado or Michigan projects.  However, some
simple present value calculations can be performed to show that
if the soil treatment results in maintenance savings of 20% per
year for 25 years, the project will result in positive discounted
net benefits.192  Any  savings due to reduced water consumption
are likely to be more substantial in the western  (drier) parts of
the country than in the northeast.

     One factor that may increase the attractiveness of using
crumb rubber as a soil amendment would be the development of
standards by the American Society for Testing and Materials for
athletic field construction and measuring field hardness.  The
ASTM is currently working on developing such standards, but they
probably will not be completed before 1994.193 While
organizations responsible for athletic fields, such as
universities or public school systems, would not be required to
follow ASTM guidelines, the existence of such guidelines may
affect the outcomes of injury lawsuits, and thus the requirements
of companies that insure such organizations.  Given the lack of
alternatives for creating softer turf, the use of crumb rubber
may become the best means of meeting the standards.

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                                                               50


          Tire Consuming Potential

     In order to consume 1 million scrap tires per year, 100
fields consuming 10,000 tires each (or other projects of the same
size) would have to be rehabilitated with the crumb rubber soil
amendment per year.  Note that once treated, we assume that a
field would not be in the position to consume tire rubber again
for at least 25 years.  Thus, the idea would be somewhat of a
victim of its own success.

     According to estimates in a market study for the Colorado
company promoting the technique, professional and semi-
professional teams and NCAA and NAIA schools manage about 2,800
football fields nationwide.  An additional 2,800 soccer fields
are managed by NCAA or NAIA schools.  These numbers increase
about 24-fold if parks, high schools, and junior colleges are
included.194   Further  study would  be  required  to  determine  a
reasonable number of fields in the NEWMOA states for which the
investment would be feasible.  The company has indicated that the
opportunity to perform a demonstration project in the New England
area would be an important step in convincing regional
groundskeepers and athletic directors to try the system.195


     Playground Surfaces

     In 1981, the Consumer Products Safety Commission developed
guidelines for impact attenuation for public playground playing
surfaces.  These guidelines recommend that the residual
(unabsorbed) impact of a child falling from playground equipment
be no more than 200 g's.196  While not regulations,  the
guidelines have been used  in a New Jersey court as the standard
for playground safety.197

     Several types of material, including rubber mats and a
variety of soft bulk surfaces, can be used to provide a cushioned
surface beneath playground equipment.  Rubber matting is
relatively expensive, at approximately $12 to $14 per square
foot, and it does not meet the guideline for impact attenuation
for falls from heights above about 5 or 7 feet.  Soft bulk
surfaces, when laid at a depth of 6 to 12 inches, can often meet
the guideline for falls from a height of 10 feet.198

     The most commonly used soft bulk surfaces materials are pea
gravel, sand, wood chips,  and wood fibers.  Granulated rubber
made from scrap tires can  also serve as a soft bulk surface.  One
company that sells 1/2" granules for this purpose receives about
$.10 per pound for the product.  This is the equivalent of about
$1.40 per square foot, 6  inches deep.199  This is more expensive
than pea gravel and sand,  but less than wood fibers.200

     Among the advantages  of rubber granules as  compared to some
of the other materials are that they provide good impact
attenuation, they retain  this property in wet and freezing

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                                                               51
weather, they are subject to less frequent need of replacement,
they are too light to cause harm if thrown, and they do not
attract animals to the play area.  Among their disadvantages are
that the surface tends to be dirty, hot, and smell of rubber.  In
addition, there is concern that the granules are highly
flammable.  They have been banned from playground use in
Australia for this reason.201


          Tire-Consuming Potential

     Given the need for 14 pounds of 1/2" granules for each
square foot of playground surface, a 50' x 50' play area would
require 35,000 pounds of crumb rubber.  At 10 to 15 pounds of
crumb per tire, this is the equivalent of about 2,300 to 3,500
tires.  Assuming that the rubber granules would need to be
replaced every 3 years, about 1,000 play areas of this size would
need to use rubber granules as a soft bulk surface in order to
consume 1 million tires per year.  More research would be needed
to determine a reasonable number of play equipment areas that
might use crumb rubber as a ground cushion.

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                                                              52


IV. FACTORS AFFECTING SCRAP TIRE CONSUMPTION


     To say that the consumption of scrap tires in the NEWMOA
states will increase over the coming years appears to be a
reasonable statement.  In addition to the large projects
discussed earlier, it seems plausible that some new uses for tire
chips and crumb rubber will develop and expand, although it is
difficult to predict precisely what these will be.  From the
solid waste perspective, the relevant questions are how fast
scrap tire consumption will increase, whether consumption will
eventually be sufficient to accommodate all the scrap tires being
generated (as well as eliminate those in stockpiles), and how
soon this might all occur.

     Given that there are already several ways in which scrap
tires can be consumed, it is important to discover what factors
are limiting the expansion of these activities.  Also of interest
are the factors that may be inhibiting new uses of scrap tires.
This section will summarize the findings on these points,
including the following:

     o    low-cost alternatives for scrap tire disposal;
     o    competition with existing products;
     o    attitudes toward new products and methods;
     o    minimum efficient scale of production or consumption;
     o    capital outlays;
     o    transportation costs;
     o    lack of standards and specifications;
     o    lack of coordination in research;
     o    environmental concerns; and
     o    limited size of some markets.


Low-Cost Alternatives for Scrap Tire Disposal

     Tipping fees can represent a significant source of revenue
for some tire-consuming businesses.  Low-cost alternatives for
scrap tire disposal exert downward pressure on tipping fees and
will thus tend to hurt these businesses.  Whether these
alternatives are landfills that charge low tipping fees or
unregulated tire stockpiles, the effect will be the same on the
tire processor who must offer a competitive tipping fee.  If
tipping fees at disposal sites rise, recyclers can also raise
their tipping fees and increase their revenues.

     This analysis probably represents the majority opinion, but
not everyone knowledgeable about tire recycling opportunities
would agree that increasing tipping fees is the answer to
increasing tire recycling.  Some would argue that a business
should not rely heavily on tipping fees because the fees
represent an unreliable source of revenue that can be undercut at
any time.  This argument raises two interesting points.  If any
undercutting that takes place is the result of inexpensive

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                                                               53


disposal opportunities, the importance of low-cost disposal as a
deterrent to recycling is highlighted.  To the extent that the
undercutting is due to another business finding a more profitable
use for the tires, and thus offering lower tipping fees to a tire
hauler, the undercutting represents evolution in the consumption
of scrap tires to more highly valued uses.  Uncertainty about
future tipping fees illustrates the current state of flux in the
market for scrap tires.


Competition with Existing Products

     Most of the ways in which scrap tires can be consumed do not
represent provision of completely new goods or services.  Whether
tires are burned for energy, incorporated into paving materials,
used as a feedstock to produce molded products, or turned into
septic leach fields, they are doing something that other
materials already do.  Therefore, they must compete with the more
familiar means accomplishing the same basic ends.

     This competition can take several forms.  One of the most
obvious is price.  If the tire-derived product performs the same
function as another material, it must do so more cheaply in order
to be adopted.  Good examples of this are retreaded tires or
tire-derived fuel.  If the performance of the tire-derived
product differs somewhat from the performance of the conventional
material, the consumer must decide whether any improvement in
performance is worth the additional price, whether any decrease
in performance is worth the savings, or how a different mix of
attributes of the tire-derived product compares to the bundle of
attributes of the conventional material.  Potential consumers of
retreaded tires, rubberized asphalt, or crumb rubber playground
surfaces face these questions.

     Existing markets may also present barriers to entry to new
businesses trying to establish tire-derived products.  In the
industrial fuels market, for example, companies that have the
kinds of boilers that could burn TDF will typically have well-
established relationships with the suppliers of more traditional
fuels.  TOF suppliers may find potential customers unwilling to
deal with them directly, for several reasons.  These customers
may have long-term contracts with other suppliers, they may fear
potential unreliability of supply, or they may find that the
transaction costs of dealing with a new supplier or suppliers
outweigh the benefits of purchasing the product.  As discussed
above, the possibility of regional energy marketers including TDF
in their offerings may be a critical step in overcoming these
types of barriers.


Attitudes Toward New Products and Methods

     Another factor affecting a new product trying to compete
with existing products is the uncertainty associated with the new

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                                                               54


item's characteristics.  A major reason for the slow pace of
adoption of crumb rubber additives to asphalt appears to be the
uncertainty on the part of transportation engineers as to how the
pavements will behave under various conditions.  This uncertainty
can translate into risk for the person authorizing use of the new
material.  Even if the benefits of a new product or process look
substantial, people are reluctant to choose something that might
work better when they can continue to use something they know
works well.  Standard operating procedures in both private
industry and the public sector may slow the adoption of tire-
derived materials in new uses.


Minimum Efficient Scale

     For many products, the cost of production will depend on the
quantity produced, and efficiencies of scale may be realized only
at relatively high levels of output.  Thus, the need for a plant
producing aggregate mix for road pavements to switch processes
when producing mixes with or without rubber adds to the cost of
the product; a plant dedicated to producing only the rubber-
containing mixes might be able to do so more cheaply.  When
production costs are high for small quantities, it is also
difficult for a firm to "ease into" a new activity gradually.
Sometimes a plant must be built at the minimum efficient scale,
or not at all.  As the minimum required size of a facility
increases, the amount of capital needed also increases.  For
example, TireCycle of New England is trying to establish a plant
that will consume 3 million tires per year; one of the challenges
facing the company is raising the $10 million needed to get a
business of this size started.

     Related to the scale of production, is the scale of
consumption.  A new producer of an intermediate product, such as
TireCycle or crumb rubber, must be assured of sufficient demand
for the output of a large facility.  For a crumb rubber plant to
locate in the northeast, it might want to see significant local
use of crumb rubber additives to asphalt concrete, for example.
It is possible that such uses have been low because of local
unavailability of the material or the high cost of transporting
it from distant producers.  If so, it may be difficult for the
producer to estimate the demand for the product at the price that
could be offered when the product is locally supplied.

     Conversely, some potential consumers, such as manufacturers
of plastics or molded rubber products, may find it worthwhile to
buy the feedstock only if it can be assured of large quantities
on a reliable basis.  As mentioned in the earlier discussion of
TireCycle of New England, the quantities demanded by some
potential consumers might exceed the output of a single plant.
A similar situation might exist for TDF, in which it would take
two or more suppliers to produce enough fuel to interest a paper
mill or other industrial consumer.

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                                                               55


Capital Outlays

     Many uses for tires require new capital stock.  Whether the
investment is a $100 million incineration facility, a relatively
minor alteration to a fuel feed system, or new equipment to spray
asphalt-rubber binder, businesses need to raise capital to
undertake the project.  If the cash is unavailable internally, it
will have to be borrowed.  In general, raising capital for
innovative investments is more difficult than for proven
enterprises.  This is because new companies and new technology
are associated with greater risk.  The viability of new business
proposals may be difficult to evaluate when there are few similar
businesses upon which to base comparisons.  When lenders and
investors are willing to supply the needed capital, they must be
compensated for the higher risks of default by higher interest
rates on loans and bonds.


Transportation Costs

     The cost of transportation is an important consideration in
trying to determine the appropriate geographic scale from which
to view the size of potential markets for tire-derived products.
Transportation costs can figure significantly in at least two
stages: getting scrap tires to the processor, and delivering the
finished product to the end user.  If intermediate processing
stages are involved, additional transportation costs may be
incurred.  Since transportation costs increase with distance,
total costs of tire-consuming activities will depend on the
proximity of the processors both to their sources of tires and to
their customers.

     The use of tire chips as fill in a Vermont road
rehabilitation project provides a good example of the effect of
transportation costs can have on the economics of a tire-
consuming activity.202  The  State paid  about  $1.50  per cubic  yard
of tire shreds, of which only about 45 to 50 cents was received
by the company that did the shredding; the remainder was spent on
transporting the shreds to the construction site.  The parties
considered setting up a portable shredder onsite instead of
shipping the finished product, but a lack of scrap tires near the
site meant that whole tires would also have to be brought in,
more than offsetting any savings this approach would have
provided.  (Ultimately, however, the tire shreds cost less than
the crushed stone the project would otherwise have used.)

     If transportation costs are significant, they may tend to
offset the economies of scale achieved by very large tire
processing facilities.   The larger the facility,  the wider the
geographic area necessary for it to obtain a steady supply of
tires.  However, the greater the distance the tires have to be
transported,  the more expensive they will be.  Those in the tire
hauling and recycling businesses in the region often say that it
is not profitable to ship tires more than 150 to 200 miles.   Of

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                                                               56


course, this will depend on how important transportation costs
are to total costs, and how close to the margin these firms are
operating; the more profitable the overall business, the less
important tire transportation costs will be.  The evidence that
some chipped tires from eastern Massachusetts are finding their
way to Pennsylvania to be processed into crumb, or from northern
New England to exporters in Newark, suggests that transportation
over 200 miles may be worthwhile in some circumstances.  One
regional estimate for whole tire transportation costs is
approximately 0.45 cents per tire per 100 miles.203   Chipped
tires are substantially less expensive to truck because they are
less bulky.


Lack of Standards and Specifications

     The use of tire-derived products is sometimes hampered by a
lack of product standards.  In some cases, the existence of
standards can be a prerequisite for using the product.  An
example of this would be the need to rate the "effective area" of
tire galleys for septic fields, so that contractors could install
the systems in compliance with health regulations.  In other
cases, standards are .not required, but might highlight the
advantages of a tire-derived product.  For example,  the
development of standards for athletic field hardness may greatly
encourage the use of crumb rubber as a soil amendment.

     In general, the lack of product standards contributes to
uncertainty about product characteristics and variability.  Lack
of standards and specifications can hamper communication between
suppliers and consumers, and make it difficult to measure product
quality.  Insufficient knowledge about the engineering properties
of tire-derived products means that individual consumers must
conduct their own tests.  Testing can be expensive or beyond the
technical capability of some potential users.  If an organization
such as the American Society of Testing and Materials were to
publish standards or specifications for TDF and tire chips or
crumb rubber of various sizes, more companies or state agencies
may be encouraged to discover ways they can use these products.

     In the public sector, where procurement can be highly
institutionalized, potential users sometimes need authorization
to use certain materials.  In addition to understanding the
engineering properties of materials such as tire chips, for
example, those in charge of roadway maintenance may need to have
the material listed along with other approved materials from
which to choose.  They may also need established contracts with
suppliers of the material.

     While specifications for car and truck tires exist, the
inability of retreaded tires to meet federal specifications for
passenger car tires appears to be a serious obstacle to state
procurement.  Managers of state automobile fleets are usually
constrained by purchase contracts that determine from whom they

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                                                               57


may buy replacement tires or retreading services.  Lack of
contracts with suppliers can limit their procurement options.

     The lack of standards may also pose liability questions that
discourage the use of tire-derived products.  One paving
contractor interviewed said that if a pavement using a crumb
rubber additive failed, the contractor would be protected from
liability if it could say it had followed the federal or state
department of transportation's specifications for materials and
procedures.  When no such specifications exist, contractors are
hesitant to bid for risky projects that might expose them to
financial liability.204

     When no appropriate national standards exist for a
particular product, states may develop their own.  Thus, New
Jersey is planning to develop its own standards for procurement
of retreaded passenger car tires if the federal government, due
to its strict standards for long wear, does not approve any.  For
some products, such as construction materials and home septic
systems, states are accustomed to devising their own
specifications.  In addition to some duplication of effort on the
part of the states, individual state standards can sometimes make
it difficult for manufacturers to provide a uniform product that
meets everyone's specifications.  Opportunities may exist for
cooperative state efforts in devising standards for some tire-
derived products.


Lack of Coordination in Research

     Highway construction and maintenance activities represent
some of the most promising scrap tire applications, in terms of
volume of tires consumed.  They also represent areas where
additional research is needed before those responsible for roads
can be expected to make more widespread use of tire-derived
products.  While substantial research into crumb rubber additives
has already taken place, much of the information gathered is not
easily accessible.  The Federal Highway Administration (U.S. DOT)
serves as a clearinghouse for information on research projects
that received federal funds, but it has limited data on projects
that did not use federal funds, since state, county,  or municipal
projects are not required to submit results of their tests to the
FHWA.  5  Furthermore,  those responsible for these  projects  may
not have documented their experiments in a way that would be
useful to others.  Given the complexity of this research, and the
specificity of the results to various climatic and topographic
variables,  there would appear to be an advantage to coordinating
any further research at the regional level.


Environmental Concerns

     The full effects of some tire-consuming activities on the
environment have not been clearly established.   One area of

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concern is the composition of leachate resulting from tires in
underground applications, such as subgrade road beds.  Based on
the very few studies on this subject, it appears that tires
should not be used in highly acidic or highly basic environments
where the leachate could enter groundwater.  However, there is no
consensus yet as to appropriate precautions that might be
necessary for less extreme conditions.

     Concerns have also been expressed about fumes given off by
asphalt concrete containing crumb rubber additives.  Worker
safety would be of primary interest here.  No studies on this
subject were uncovered in the course of this research.

     Burning tires as fuel can have environmental impacts in the
form of air emissions and the disposal of ash.  When TOF is used
to replace coal at existing industrial facilities, the net
environmental impacts could be assessed by comparing operation
with the TDF to operation of the same facility with its
traditional mix of fuels.  In the case of newly built tires-to-
energy plants, the plant's emissions may represent a net increase
in pollutants in the vicinity or downwind of the site.  However,
to the extent that the increase in generating capacity represents
a decrease in energy generated elsewhere, overall emissions
within a larger geographic area may or may not be affected.
Thus, it is the distributional concerns associated with siting a
tires-to-energy facility that are more likely to present a
problem.

     While the environmental impacts of tires-to-energy
facilities are important to establish in weighing the
desirability of such plants, a full analysis was beyond the scope
of this paper.  It is assumed here that the state permitting
process will adequately protect the health and welfare of
residents downwind of a plant.  If this is not the case,
incineration for energy may represent an intermedia transfer of
the scrap tire problem, rather than a solution to it.

     Finally, it should be noted that not all consumptive uses of
scrap tires represent an equal reduction in the volume of tire
waste.  For example, the manufacture of crumb rubber yields only
about 10 to 12 pounds of usable product from a 20 pound tire.
While some of the byproducts, such as the rims and beadwire, may
also be recoverable, much of the tire may still need to be
disposed of in a landfill.  If applications can be found for tire
chips from which the wire and fabric need not be removed, such as
construction fill, a much smaller percentage of the original tire
will be left as byproduct.


Limited Size of Some Markets

     While scrap tires do make good backyard swings, those
charged with finding alternatives to scrap tire disposal quickly
recognize that the market is limited.   Unfortunately, several

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other scrap tire uses are similarly limited.  For example, the
manufacture of fishing reefs from whole tires is not likely to
consume a significant number of tires on a sustainable basis.
Nor will specialized gear for scalloping vessels, crumb rubber
tracks for horse-training arenas, or rubber railroad grade
crossings find large markets.  This is not to say these uses are
unprofitable or unwelcome, but simply that they are not likely to
have a significant impact on scrap tire consumption, even if the
potential markets are fully exploited.

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                                                               60
V. POLICY OPTIONS FOR DECREASING SCRAP TIRE DISPOSAL


     The focus of this section will be to explore the
implications of various policy options designed to decrease the
rate of scrap tire disposal.  Given our initial framework of a
stock of scrap tires to which new additions are made every year
and from which a certain number of tires are consumed, it is
clear that the rate of scrap tire disposal could be reduced in
two ways: a lowered rate of scrap tire generation, or an increase
in scrap tire consumption.  The first policy option discussed
below is to do nothing.  Most of the remaining proposals address
the factors identified in the previous section that tend to work
against increased consumption, and would thus affect scrap tire
disposal by increasing consumption.  They include:

     o    regulating tire disposal and hauling;
     o    promoting coordinated research;
     o    developing standards and specifications;
     o    public sector consumption;
     o    demonstration projects;
     o    subsidizing tire consumption;
     o    assisting companies with capital costs; and
     o    raising revenue to fund these activities.

     The proposals considered here are those that could be
implemented at the state or regional level.  Additional options
may be available at the national level.  One such option was
proposed in Congress this year by Representative Esteban Torres
of California.  The Torres bill will also be described.

     This discussion is not intended to be a full policy
analysis.  A more complete analysis would include more background
on the history of tire recycling, the dynamics of unregulated
dumping, and the market for waste disposal services in general.
In addition, the full social costs of tire disposal would have to
be addressed.


The No-Further-Action Alternative

     Each of the NEWMOA states has already addressed its scrap
tire problem through some combination of regulations, guidelines,
procurement, or economic development activity.  Recent events in
the private sector have suggested that the consumption of scrap
tires will increase over the next several years even if the
states take no further actions.  As discussed in the section
"Expected and Potential Near Future Changes in Scrap Tire
Consumption," above, some of the anticipated uses are very
significant in terms of the number of scrap tires to be consumed
as a percentage of the annual generation rate.

     Tables 1, 2 and 3 are reproduced on the next page to allow
comparison of potential tire consumption to current scrap tire

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                          Tabte 1
                 CURRENT GENERATION AND STOCK


Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
New Jersey
Annual
Generation
3,500,000
1,200.000
6,000,000
1,000,000
t, 000,000
500,000
9,700,000

Stockpiles
15,000,000
50.000,000
30,000,000
1,500,000
40,000,000
10,000,000
8,000,000
TOTAL
  22,900,000
- 155,000,000
                 Table 2
     CURRENT CONSUMPTION AND DISPOSAL
Destination
Tires per Year
Retread
Export
Manufactured Products
Experimental Uses
Subtotal
Disposal
3,000,000
2,400,000
1,800,000
300,000
7,500,000
15,400,000
Annual Generation
  22,900,000
                                                                              Table 3
                                                                                            60A
                                                                                       ADDITIONAL FUTURE ANNUAL TIRE CONSUMPTION
                                                                             MOST PROMISING LARGE CONSUMERS
Exeter Energy

Champion

Another Paper Mill



         SUBTOTAL
 8,000,000

 3.000,000

 3,000,000



U.000.000
                                                                                                  STARTING DATE


                                                                                                      1991

                                                                                                  Fall 1990

                                                                                                      1992
                                POTENTIAL LARGE CONSUMERS


                                Tirecycle                   3,000,000

                                Dragon Cement               3,750,000

                                State Road Projects         5,400,000
                                (use of chips as
                                substitute for
                                10X of clean fill)

                                         SUBTOTAL          12,150,000
                                                                                                                            1994 (?)
                                TOTAL
                           26,150,000

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generation.  The figures on the top half of Table 3 suggest that
the most promising large consumers could together consume over
half the current annual generation rate, or 14 million out of 23
million (from Table 1), and close to the number of tires
currently being disposed of in the seven NEWMOA states (15.4
million, from Table 2).  The only state actions required to
achieve this annual rate of consumption are permitting and
monitoring of the industrial facilities.

     At this point, it should be noted that the scrap tire
generation rate may also rise.  Factors that would contribute to
this rise are increases in population and in the number of miles
driven.  The following table shows how many scrap tires would be
generated per year at selected dates in the future if the current
generation rate were to grow by 2 percent or 4 percent per year.
(These growth rates were selected primarily for illustrative
purposes and are with not based on specific projections of the
growth in scrap tire generation; however, they are consistent
with national estimates of scrap tire generation for 1984 through
1987.206)


                        Table 5

        SCRAP TIRE GENERATION RATES (Millions/Yr)
                WITH EXPONENTIAL GROWTH


     Year           2% Growth/Yr        4% Growth/Yr

     1989                22.9                22.9
     1994                25.3   *             27.9
     2000                28.5                35.3
     2010                34.7                52.2


These figures are important, because any increases in scrap tire
consumption will not happen instantaneously, but over a period of
time.  Even if consumptive uses grow enough to account for the
current annual generation, by the time that rate of consumption
is achieved, the annual generation rate will probably be higher.

     If in addition to the 7.5 million tires currently consumed,
all the consumption listed on Table 3 except the road
construction projects were realized, a total of about 28 million
tires per year would be consumed by the private sector.207  This
would not happen until several years from now at the earliest,
but even with the scrap tire generation rate growing in the
interim, this level of consumption might be close to the annual
generation rate in the mid-1990s.  It is emphasized, however,
that considerable uncertainty is associated with all but the
first one or two projects listed on Table 3.

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     In order for progress to be made in reducing the existing
stockpiles listed on Table 1, scrap tire consumption must proceed
at a higher rate than scrap tire generation.  Thus, additional
consumptive uses would have to be found.  In order to eliminate
the estimated 155 million tires stockpiled in the region over a
period of 10 years, the annual consumption rate would have to
exceed the annual generation rate by 15 to 16 million tires per
year.  To eliminate the tire piles in 20 years, the excess rate
of consumption would have to be about 8 million tires per year.

     It is difficult to predict whether the economics of tire
consumption will be sufficiently attractive to achieve these
rates through normal operations of the market.  Entrepreneurs can
be expected to invest in the most profitable activities first,
which currently appear to be those associated with the use of
tires as fuel.  The conversion of scrap tires into feedstocks for
other manufacturing processes, such as rubber-plastic polymers,
may represent other highly-valued uses.  Additional technological
advances may improve the outlook for some processes, such as
pyrolysis, or create new investment opportunities of which we are
as yet unaware.  Small-volume specialty applications may also
prove to be profitable forms of tire consumption.  As these
opportunities are exhausted, however, only less profitable
investments will remain, and these may not be sufficiently
attractive to lead to the consumption of the remaining number of
scrap tires generated.

     The public sector's opportunities for increasing scrap tire
consumption include direct use of tire-derived materials or
taking actions that make investments in tire-consuming activities
more attractive to the private sector.  While both these
approaches will be discussed in greater detail in the policy
options that follow, one of the potentially large forms of public
consumption is included on Table 3 for comparison purposes.  The
use of tire chips as a substitute for 10 percent of the clean
fill used in state road construction projects could consume over
5 million tires per year.  When added to the private sector uses
that might develop over the next few years, public sector
consumption could play a significant role in ensuring that the
annual generation of scrap tires is consumed, or in starting to
reduce existing tire stockpiles.


Regulating Tire Disposal and Hauling

     Regulating the disposal of scrap tires to safeguard public
health and safety could include such means as requiring that fire
prevention and vector control measures be taken, limiting the
dimensions of tire piles, requiring financial sureties from
stockpile operators, or prescribing how tires are to be
landfilled (e.g., only sliced or shredded).  Compliance with the
regulations will usually have the effect of increasing the costs
of landfilling and stockpiling.  If these costs are passed on in
the form of higher tipping fees to those using the facilities,

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tire haulers will have an increased incentive to find lover-cost
means of disposal.  Non-disposal consumers of scrap tires would
thus be able to charge a higher fee for taking the tires from the
haulers.  This can increase the profitability of existing tire
consumers, and might encourage them to expand.  Higher tipping
fees may encourage the development of new businesses that consume
scrap tires.  Public consumption of tires would also look more
attractive, as the effective cost of using scrap tires in public
works would decline.

     Since higher tipping fees increase the incentive to find
lower-cost disposal, they will also increase the incentive for
illegal disposal.  To the extent that the higher tipping fees are
passed along to tire dealers and car owners, these individuals
will also face increased incentives for illegal disposal.
Enforcement against illegal dumpers would have to tighten in
order for the positive effect of the higher disposal fees to
reach the scrap tire consumers.


     Enforcement: Tracking Systems, Licensing and Deposits

     One way to make illegal disposal more difficult would be to
develop a tracking system that records the movement of all tires
from the point of first discard, such as at a tire dealer, to the
point of final consumption or disposal, such as a manufacturing
operation or landfill.  An important component of any tracking
system would be to license all tire haulers and require that they
keep records of the volume of material they handle.  The
licensing of tire processors may also be necessary

     Some individuals in the tire business interviewed for this
study felt that a tracking system would be very cumbersome and
unworkable.  One potential problem is that scrap tires often move
across state boundaries, and that neighboring states would have
to have compatible reporting requirements.  But others in the
industry welcomed the idea, saying that it would benefit
legitimate businesses.  Since many businesses already keep
records like this, a tracking system would not necessarily
represent a great deal of additional paperwork.  Development of a
tracking system would probably best be accomplished with input
from tire dealers, tire haulers, and others in the tire disposal
and recycling industry.

     If a state has reason to believe that illegal dumping by
individual consumers is an important contribution to the scrap
tire problem, it may want to provide car owners with incentives
to return their used tires to appropriate locations, such as tire
dealers.  One way to do this would be to impose a deposit scheme
on the sale of new replacement tires, much like that on beverage
containers.  Since deposit schemes rely on voluntary compliance,
the deposit would have to be set high enough to provide consumers
with sufficient incentive to return the tire to an appropriate
facility.  However, a deposit at that level, perhaps $5 or $10

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per tire, might be high enough to discourage the purchase of
replacement tires in the state.  Residents of one state may find
it worthwhile to buy their replacement tires across the state
line to avoid the deposit.  Thus, regional coordination may be
necessary for such a scheme to work.


Promoting Coordinated Research

     Despite over 20 years of experimentation with crumb rubber
additives to asphalt concrete, little consensus has emerged as to
the applicability of the technologies in northern climates.  It
may be that sufficient data have been collected to develop
guidelines for use of the materials under various conditions; if
so, there is a need for some synthesis and evaluation of the data
currently available.  Economic analyses could then be performed
that take into account not only the initial costs of the
pavements, but also their durability, performance, and
maintenance requirements.  If the data are still insufficient to
do this, additional field research would be necessary.  The
NEWMOA states could try to coordinate any further research such
that the results would be useful in addressing concerns common to
the region.

     Research on the use of tire chips in construction projects
is just beginning.  The interest of the New England
Transportation Consortium in this area was instrumental in
funding the research project currently underway at the University
of Maine.  The Consortium was formed in 1984 by member states
Maine, New Hampshire, Vermont, Rhode Island and Massachusetts.
Based at the Center for Transportation Studies at the
Massachusetts Institute of Technology, the Consortium selects and
funds transportation-related  research projects to be carried out
by state universities in conjunction with the state departments
of transportation.  Given the large potential for roadway
construction projects to consume tire-derived products in various
ways, additional research in this area appears desirable.  The
NEWMOA states could explore the potential for pooling resources
and coordinating further work through the NETC on additional
transportation-related proj ects.


Developing Standards and Specifications

     A number of uses for tire-derived products would be aided by
the development of product standards or specifications.  Some of
these standards may be most appropriately developed at the
national level, through such organizations as the American
Society for Testing and Materials or branches of the federal
government.  Where these standards are inadequate or slow in
forthcoming, states may want to consider developing their own.
New Jersey's consideration of developing its own standards for
retreaded passenger car tires is one example.  For other
products, such as home septic systems or some construction

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materials, specifications are traditionally written at the state
level.  In these cases, states may help each other speed the
development of specifications by sharing information they have
gained about new tire-derived products.


Public Sector Consumption (Procurement)

     Some of the largest potential tire-consuming activities that
may prove to be economically feasible are activities that are
typically financed by the public sector.  Foremost among these
are road construction and maintenance projects.  The Departments
of Transportation in some of the NEWMOA states have already begun
to explore the feasibility of using tire-derived materials, as
well as other forms of solid waste, in these projects.  While
public officials responsible for solid waste will naturally want
to encourage further research and experimentation, they should
understand the technical and financial constraints facing
transportation officials that may hamper progress in this area.
Mandating the use of tire-derived materials before the
engineering or budgeting implications are sufficiently understood
may only serve to antagonize the people whose cooperation is most
necessary.

     The purchase of retreaded tires for publicly owned vehicles
is another area where the public sector can directly affect scrap
tire consumption.  While the use of retreading services for truck
tires is a common practice,  the purchase of retreaded passenger
car tires is not.  If specifications for these tires can be
developed, and supply contracts established, increased retread
purchases may help expand the market for retreaded tires.  More
research is needed to determine the number of tires potentially
involved and whether this number is significant in light of the
magnitude of the scrap tire problem.  More research may also help
determine whether the public sector's example of using retreads
would encourage more private consumers to buy them.

     One way of encouraging the use of tire-derived products in
the public sector would be to allow price preferences for them.
Some states already have price preferences for products made from
recycled materials, which could be extended to include tire-
derived products.  In Massachusetts, for example, products made
with recovered materials may be given a price preference of up to
10%.  The Massachusetts Department of Environmental Protection is
currently working with the Department of Public Works to
determine whether to recommend that the Massachusetts Purchasing
Agent consider asphalt-rubber a recovered material.208

     If price competition is the major reason for low levels of
use of tire-derived products, a price preference may result in
greater use of the tire products.  If the reason for not using
tires is related not to price but to some other factor, such as
uncertainty about engineering properties, the price preference is
less likely to affect consumption of the tire-derived product.

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Demonstration Projects

     As a means of exchanging information about new technologies
or products, demonstration projects can help educate potential
consumers and lessen the uncertainty associated with new
products.  Some of the past paving projects using crumb rubber
additives may be regarded as demonstration projects.
Demonstration projects for other applications may be helpful,
such as the use of crumb rubber as a soil conditioner on heavily
trafficked public lawns or athletic fields.  If these projects
are successful, they may encourage use of the product in either
public or private settings.


Subsidizing Tire Consumption

     One way to increase the attractiveness of tire-consuming
activities would be to offer a rebate for every tire, or portion
thereof, consumed.  The rebate could be offered either to the
processors or end-users of tire-derived products.  If the
consumer is the party that receives the rebate, the effect of the
policy is to lower the cost of using the product.  Tire
processors may be able to capture some of this savings by raising
the price of their products.  If the processor receives the
rebate, the effect on the business will be much the same as a
rise in the tipping fee; the subsidy will represent income from
the acceptance of tires rather than from the sale of the finished
product.  Since processors may pass some of the benefit of the
subsidy along to consumers in the form of lower prices, the net
effect on price and quantity of material exchanged is likely to
be about the same whether the rebate is paid to the processor or
the consumer.

     While a subsidy would have a similar effect on tire-
consuming businesses as an equivalent increase in tipping fees,
such as might come about through tightened regulation of tire
disposal, two differences might be important.  First, unlike
tipping fees that may fluctuate with changes in market
conditions, subsidies offer the potential of a more stable source
of revenue.  If the subsidy is perceived as reliable in the
business community, it may reduce the risk associated with a new
tire-consuming enterprise, and enhance an entrepreneur's chances
of securing financing from lending institutions.  Second, to the
extent that unregulated dumping is encouraged by high tipping
fees, a subsidy may promote recycling without this undesirable
side-effect.

     Two states that currently have subsidy programs are Oregon
and Oklahoma.  Oregon's program, begun in November 1988, offers a
one-cent per pound ($20 per ton or about $.20 per tire)
reimbursement to users of products derived from Oregon's waste
tires.  The program is funded by a $1 per tire tax levied on the

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sale of new replacement tires.209  While there was  little
activity during the first year of the program,  by March 1990, the
state paid out $273,000 in reimbursements210, which accounts  for
over 1.3 million tires.

     According to the Oregon Department of Environmental Quality,
about 97 percent of the subsidies were paid to businesses using
the tires for energy recovery, and 3 percent for non-energy uses.
This pattern is explained by the fact that the subsidy can
represent as much as a 50 percent savings in fuel applications,
but is far less valuable in other applications where factors
other than the cost of materials determine the overall cost of
the tire-consuming activity.211  In  reaction to  this pattern,  and
in recognition of EPA's stated "solid waste hierarchy" that deems
recycling to be preferable to incineration, a rule change in
January 1990 allowed a higher rate of reimbursement for non-
energy demonstration projects.212  Whether this  change has had an
appreciable impact on the distribution of the subsidy by type of
tire consumption was not available as of this writing.

     Since businesses both within and outside Oregon are eligible
for the rebate, the Oregon program has affected scrap tire usage
in neighboring states.  A Washington pulp mill uses TDF from
Oregon because of the subsidy,213and a California  cement kiln
has reduced its consumption of California tires in favor of those
from Oregon.214  While these  results are evidence that a subsidy
the size of Oregon's can indeed affect the decisions of some
industrial consumers, they also suggest that states be aware of
the potential for interstate consequences of various tire
policies, and that regional coordination be considered.

     Oklahoma's subsidy program is newer and has thus generated
less data.  It nevertheless offers some interesting ideas.   Like
Oregon's program, Oklahoma's subsidy is financed by a $1 fee on
new replacement tires.  Unlike Oregon, the subsidy is paid to the
first-stage processors of tire-derived products, and not to the
end-users.  The state offers permitted scrap tire processors up
to $.50 per tire processed.  In order to qualify for
reimbursement, at least 25 percent of the tires processed by the
facility must be collected from tire dumps identified on a
priority list developed by the State Department of Health.215

     One hazard the Oklahoma program faced in its early stages
was that the fund created by the fee on new tire purchases
accumulated about $1 million over nine months before the first
request for reimbursement by a private sector processor.  The
delay was due in part to the time it took to promulgate
regulations, institute the permitting process, and  identify
priority clean-up sites.  Meanwhile, the accumulation of the fund
gave the impression that the program was not active, and prompted
some members of the state legislature to try to repeal the act
that created it.  The repeal attempt failed, but some have
suggested that criticism of the program could have been avoided

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if the timing of the implementation of the fee had been delayed
until later in the program process.216

     As with other policies whose effect would be to increase
per-unit revenue to a tire processor, a subsidy will be most
effective when it is the cost of the tire-derived product that is
the principal constraint on increased consumption.  To be
effective, the subsidy must be large enough to bridge the gap
between what producers are willing to accept for a particular
product and what consumers are willing to pay.  It will be
interesting to see if the higher value of the Oklahoma subsidy,
at $.50 per tire, results in more varied enterprises consuming
scrap tires than the Oregon subsidy, at $.20 per tire, which has
thus far supported primarily TDF.  If the principal barriers to
consumption of tires in a particular application are lack of
product specifications, environmental concerns, or other non-
price factors, a subsidy program will have little effect on
increasing tire consumption in that application.

     Some of the issues that have to be addressed in creating a
subsidy program are the administrative costs of the program,
whether public activities, such as road construction, would be
eligible for the subsidy, and how to make the subsidy appear
reliable in the view of those who would be making investment
decisions that rely on it.  In addition, some legal issues may
affect the design of a subsidy program, for example, whether the
constitutions of any of the NEWMOA states prohibit the direct
subsidization of private industry*


Capital Cost Assistance

     To address the capital barriers facing potential new tire
recyclers (or existing firms that wish to expand), it has been
suggested that states make subsidized capital available directly
to entrepreneurs.  This could be accomplished through industrial
revenue bonds, low interest loans, or loan guarantees.  State-
issued industrial revenue bonds typically carry interests rates
that are a little lower than those charged by other lenders or
investors.  The Exeter Energy facility is being constructed with
the assistance of bonds backed by the state of Connecticut, and
TireCycle of New England is trying to qualify for Rhode Island
industrial revenue bonds.  The ability of a company to obtain
state backing for a portion of its capital needs may help
convince private lending institutions of the legitimacy of the
business proposal and make it easier for the company to gain
additional private financing.217   For smaller  businesses,  backing
by the federal Small Business Administration may be an option.

     There are at least two important reasons to view this
approach with caution, however.  First, the announcement of
special low interest loans for tire recycling may elicit many
applications from private entrepreneurs.  The state would need
the ability to evaluate all these proposals and determine which,

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if any, present good risks for the state.  The state may or may
not have the expertise available to make such evaluations.
Personnel with expertise on solid waste issues may not be trained
in finance, and those in the state's department of economic
development, if it has one, may have financial expertise but be
unfamiliar with solid waste concerns.  Developing cooperative
relationships between these types of people may be a prerequisite
to evaluating the business proposals.

     Secondly, some in private industry believe that there is
still a shortage of good ideas about how to use scrap tires, but
that there is no shortage of investors actively seeking tire
recycling opportunities and willing to put money into promising
ventures.219  To  the extent that  this is  true,  we would  expect
that the proposals most likely to result in viable business
ventures that will need no further support are already fully
capitalized.  For a state to identify a successful proposal that
others overlooked, it would have to have better information than
private capital markets about the likelihood of success of tire-
consuming enterprises.  Given the scarcity of state funds for
such activities,  and the difficulty in evaluating proposals,
state assistance for capital needs may represent a particularly
risky expenditure of public funds.

     The failure of the state-subsidized TireCycle plant in
Minnesota is sometimes given as an example of the dangers of
public investment in private recycling industries.  Among the
problems that the enterprise faced were political factors that
led to the siting of the plant at an economically unfavorable
location.219  The political pressures potentially  associated with
choosing recipients of large sums of money should be considered
in the development of a program designed to lower capital
barriers.

     New York State's Department of Economic Development
currently offers "secondary materials technology adoption loans"
for businesses engaged in the recycling of a variety of
materials.  A limited number of loans have been made for tire-
related activities thus far.  As this program develops, it may
offer important lessons to other northeast states considering
this approach to addressing capital cost barriers to increased
tire recycling.


Raising Revenue

     Most of the policy options discussed above require
expenditure of public funds.  The source of these funds could be
either general revenue, allocations from existing agency budgets,
or new taxes or fees earmarked for a scrap tire program.  How
much money the selected program will require may influence a
decision about which type of funding to pursue, and how high to
set the fee.

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     New taxes or fees could be imposed at one of several points.
One option is to charge a fee at the point of tire disposal.
This has the advantage of raising public consciousness about any
social costs of tire disposal that may not be reflected in the
normal cost of disposal.  It has the disadvantage of reducing the
incentive to bring tires to appropriate disposal sites, and it
may result in an increase in illegal dumping.

     Alternatively, a disposal tax could be imposed at the point
of new replacement tire purchase.  This, too, would raise
consumers' awareness of the costs associated with the product.
The tax could be imposed on new replacement tires only, giving
retreaded tires a slight, advantage.  Unlike a fee at the point of
disposal, this tax would not affect disposal behavior.  The
logistics of collecting the tax from tire sellers would have to
be considered, and tire dealers may have to be compensated for
their participation by allowing them to keep a small percentage
of the tax.

     Administratively, imposing an additional fee at the time of
vehicle registration may be the easiest course.  It would also
avoid the problem of consumers crossing state lines to avoid
taxes on new tires.  A disadvantage of this approach is that
people who drive very little, and thus generate the fewest scrap
tires, would pay just as much as those who drive a lot and
consume more tires.  Similarly, a tire disposal fee imposed at
the time of vehicle title transfer might be easy to collect, but
would affect those who buy or sell used cars frequently more than
other drivers.  Either of these approaches raises a question
about fairness.


National Legislation

     Early in 1990, Representative Esteban Torres of California
proposed comprehensive scrap tire legislation designed to create
economic incentives for scrap tire recycling.220  The  "Tire
Recycling Incentives Act" would place the responsibility for tire
recovery on tire manufacturers and importers.  These businesses
would have to guarantee, through their own activities or through
the purchase of recycling "credits", that a certain percentage of
their tires had been recycled.  Credits would be generated by
licensed recyclers who consume tires in an EPA-approved manner.
The amount of recycling credit created for each scrap tire
processed would depend on the type of processing.  A market for
recycling credits would develop as tire manufacturers and
importers are required to obtain an increasing number of credits
for every tire they sell.

     Another important provision of the proposed legislation is a
ban on land disposal, except for the monofilling of shredded
tires.  Other aspects of the legislation include requirements
that each state inventory its tire collection and storage
facilities and develop an abatement plan.  States are also

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charged with licensing scrap tire haulers,  and licensing all
scrap tire collection, storage, and recycling facilities.
Inspection, enforcement, and monitoring the tracking system are
likewise state responsibilities.  The legislation does not
provide the states with any funds to carry out these activities,
although it does not prohibit them from levying any of their own
fees or taxes on tires to pay for the required programs.

     National legislation would do much to avoid the interstate
side-effects possible when each state develops its own program
for addressing scrap tires.  This coordination would come at the
cost of an additional layer of bureaucracy, however.  It is also
unclear how states with existing programs would be affected by
the new regulations.  The Tire Recycling Incentives Act did not
pass this year, but due to the serious implications the
legislation could have for the market for scrap tires, state
solid waste officials will want to be aware of any further
developments in this area.

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VI. CONCLUSIONS


     The markets for scrap tires and tire-derived products
currently reflect considerable uncertainty about future
conditions in the NEWMOA states.  Despite the few large consumers
about to come on the scene, namely Exeter Energy, Champion
International, and perhaps another paper mill, plenty of scrap
tires will still be available for additional large-scale
consumers who can find profitable uses for them.  Some
entrepreneurs must be optimistic about the potential for recycled
rubber to break into the market for rubber-plastic polymers, or
companies such as TireCycle and R.W. Technology would not exist.
However, these firms also appear to be having some difficulty
attracting investors (although this is hard to tell without more
information than the companies are willing to divulge).  One
reason may be that their products will be only marginally
profitable.  Alternatively, the products may be quite profitable,
but the risk factor may be keeping investors away.

     Without more detailed information about the internal
finances of potential tire-consuming companies, it is difficult
to determine whether increased tipping fees would be of much help
to them.  Tipping fees may have the greatest impact on companies
that do relatively little processing and produce a relatively
simple product, such as tire chips for fill or fuel, where the
cost (or negative cost) of the input has a large effect on
overall profitability.   For more intensely processed, higher
valued products, the initial cost of the material input may be
less important, and the impact of tipping fees on overall
profitability may thus be less significant.  This latter
description may apply to rubber-plastic polymers or pavements
using crumb rubber.  For these uses of scrap tires, the capital
costs of establishing a plant or increases in labor may pose more
of a barrier than the cost of the tire inputs.  Thus, measures
that increase tipping fees may not have much of an impact on
them.

     From the perspective of solid waste management, we do not
particularly care about the value of the final product, be it a
simple dock bumper or high-tech polymer, as long as the processes
that make it are sustainable and self-sufficient in the
marketplace.  If these conditions can be met by raising the
tipping fee, then policies that result in higher tipping fees are
worth exploring.  Moreover, the risks involved in capital cost
assistance to potential recyclers suggest that other avenues be
tried first.

     One logical place to begin working on tipping fees is to
require that appropriate safety measures be taken at landfills
and tire storage facilities.  Since there may be social costs
associated with tire stockpiling that are not properly considered
by stockpile operators, in the form of fire hazards, risk of
disease, and aesthetics, this action is defensible even on

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theoretical grounds.  As the costs of these operations rise,
disposal site operators would have to raise their tipping fees.
As discussed earlier, a permitting and tracking system for both
facilities and tire haulers may be necessary to achieve higher
tipping fees without additional unregulated disposal sites
appearing.

     Another way to increase front-end revenue to tire consumers
would be to offer a per-unit subsidy on consumption.  This would
not be incompatible with measures to increase tipping fees
through regulation of disposal and hauling.  One question
deserving further research would be a comparison of the
administrative costs of providing a subsidy to the administrative
and enforcement costs of achieving an equivalent increase in
tipping fees by regulatory means.

     If states pursue either or both of these means of making
tire consumption more attractive, and if these measures would
have the most impact on relatively simple forms of recycling,
then additional policy initiatives to stimulate demand should
complement the increased attractiveness in tire shredding or
chipping.  This suggests that research on the use of tire chips
to replace sand and gravel in construction applications would be
more fruitful than state-assisted polymer research, for example.
It should be noted that such research may aid not only public
consumption of the material, but private construction activities;
as well.  If the additional front-end revenues from higher
tipping' fees and/or subsidies help the more complicated
processing methods become profitable, efforts to increase the use
of shreds and chips can always be abandoned.

     Before any measures are taken, beyond the regulation of tire
disposal for health and safety reasons, solid waste officials
should seriously consider waiting to see what happens in the
private market over the next few years.  In addition to the
consumption opportunities identified within the seven states
discussed here, it is possible that the export of tire products
will increase, or that new tire-consuming capacity in New York,
Pennsylvania, or Canada will appear.  The risk in waiting, of
course, is that nothing will develop and that the severity of the
tire disposal problem will grow.

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                              NOTES


1 Robert Snyder,  Consultant,  Tire Technology, Inc.  Personal
communication, 2 October 1990.
2 Robert Snyder.
3 Robert Snyder.
4 The story is considerably different for heavy truck tires,
which are still consistently retreaded because of the substantial
cost savings as compared to the purchase of new tires.  While
these casings, too, must eventually be discarded, they represent
a relatively small component of the scrap tire problem.
5 Paul Bedrosian, U.S. Environmental Protection Agency, Region I,
3 October 1989, unless otherwise noted.
6 Maine Department of Transportation, Technical Services
Division, "Preliminary Report on the Use of Tire Rubber in
Pavements," March 1990, p. 1.
7 Massachusetts Executive Office of Environmental Affairs,
Department of Environmental Protection, "Toward a System of
Integrated Solid Waste Management: The Commonwealth Master Plan,"
June 1990.  Generation rate listed is 5.5 to 6 million tires per
year.
8 Ron Gagnon, Rhode Island Department of Environmental
Management.  Personal communication, 27 November 1990.
9 Al Morrison, Vermont Agency of Environmental Conservation,
Department of Solid Waste.  Personal communication, 6 August
1990.  The stockpile estimate should be considered very rough.
10 New Jersey Department of Environmental Protection,  "Emergency
Solid Waste Task Force Preliminary Report," 6 July 1990.  The
generation rate estimate does not seem to include the 20-30% of
tires estimated to be culled by jockeys for resale or retread.
Furthermore, the rate is apparently based on a recycling market
development study by Arthur D. Little, Inc., that offered this
figure as the 1986 generation rate.  It represents 8.4 million
passenger car tires and 1.28 million truck tires, or a total
"passenger car equivalent" of 13.5 million tires.  The ADL report
projected the scrap tire supply to grow to 17.6 million passenger
car equivalents per year by 1993.  Thus, a 1990 estimate may be
closer to 15 or 16 million tires generated per year.
11 See "Markets for Scrap Tires," research presented by Hope
Pillsbury, U.S. Environmental Protection Agency, and Jacob
Beachey, Franklin Associates, at the First U.S. Conference on
Municipal Solid Waste Management, 13-16 June 1990.
12 For example,  the National  Tire Dealers and Retreaders
Association and Recycling Research, Inc. (publisher of Scrap Tire
News).
13 John Bittner,  National Tire Dealers and Retreaders
Association.  Personal communication, 24 July 1990.
14 Assumptions:   22.9 million tires generated annually in the
NEWMOA states; 80 percent of scrap tires resulting from tire
replacement; 8.5 percent of passenger car tires retreaded
nationally; 16.3 percent of car, light truck, and medium truck
tires retreaded annually.

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                                                               75


15 The rate at which tire haulers say they cull for reusable or
retreadable casings provides a rough check on this figure.
Haulers say they pull about 10 to 15% of the tires they collect
for these uses, but that the tire dealers have sometimes picked
out the best tires already.  Thus, 16.3% seems to be a reasonable
figure for the rate of retreading.
1  If we assume that the generation rates reported do not include
tires to be retreaded, we obtain an estimate of 4.5 million tires
retreaded per year in the NEWMOA states.  Calculation:  .163 =
x/(22.9 + x), where x is the number of tires retreaded.
   Warren Schambeau,  Metropolitan Tire Converters.  Personal
communications, 24 July and 10 August 1990.
18 Kevin Parks, Integrated Tire.   Personal communication,  18 June
1990.
19 Chris Chisseri,  Oxford Tire Supply.  Personal communication,
30 July 1990.
20 Tom Ferreira, F&B Enterprises.  Personal communication,  27
June 1990.  Based on 4,000 passenger car tires and 1,000 truck
tires per day, 5.5 days per week.  The tires are not completely
used; 20 tons of leftover material is disposed of at the New
Bedford landfill per day.
21 Joe Carpenter,  New Jersey Office of Recycling.   Personal
communication, 6 August 1990.
22 Tim Baker,  Baker Rubber.  Personal communication,  9 August
1990.
23 The two companies involved in this exchange provided widely
varying estimates of the amount of material involved.
24 John England, Connecticut Department of Environmental
Protection.  Per communication with Carole Ansheles, NEWMOA, 25
July 1990.
25 Bruce Eber, Tire Salvage, Inc.  Personal communications with
Amy Barad and Paul Bedrosian, EPA Region I, 27 June and 8 August
1990.
26 Electricity Purchase Agreement between Exeter Energy Limited
Partnership and the Connecticut Light and Power Company for the
Exeter Energy Sterling Project,  1 December 1989, p. 6..
27 Chris Chisseri,  Oxford Tire Recycling of Connecticut.
Personal communication, 12 July  1990.
28 Kevin O'Reilly,  Oxford Energy Company.  Personal
communication, 29 June 1990.
29 Eric Kennedy, Maine Department of Environmental Protection,
Air Bureau.  Personal communication, 22 June 1990.
30 Andrea Maker, Champion International.  Personal communication,
18 June 1990.
31 Bill Murdoch, Sawyer Environmental Recovery, 26 July
1990 and Tom Flaherty, Sprague Energy,  26 July 1990.
32 Andrea Maker, Champion International; Tom Flaherty, Sprague
Energy; and Mark Hope, Waste Recovery,  Inc.
33 Mark Hope.
34 Garrett Morrison, Dragon Products.  Personal communication, 18
August 1990.
35 Steven Roberts,  TireCycle of New England.  Personal
communication,  22 June 1990.

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                                                               76


36 Chris Chisseri,  Oxford Tire Recycling.  Personal
communication, 30 July 1990.
37 Rhode Island General Laws, 63-23-2.
38 Bruce Eber, Tire Salvage, Inc.  Personal communication, 27
June 1990.
39 Frank Mann, Pol-X International.  Personal communication, 23
July 1990.
40 Paul Bedrosian,  Environmental Protection Agency, Region I.
41 Electricity Purchase Agreement between Exeter Energy and
Connecticut Light & Power,  Exhibit J-l, Exeter Financial  Pro
Forma, 1989.
42 Ray Gile, International Soil Systems.  Personal communication,
28 September  1990.
43 Mike Kennedy,  Waste Management, Inc.  Personal communication.
   Kay Beaton, R.W.  Beck and Associates, in letter to William
Evans, New Hampshire Department of Environmental Services,  9
February 1990.
45 Mike Kennedy,  Tire and Fuel Reduction Group,  Waste Management,
Inc.  Personal communication, 10 July  1990.
   Adam Marks, Rhode Island Solid Waste Management Corporation.
Personal communication, August 1990.
47 CMR 406.3.
48 CMR 406.3-5.
49 Connecticut Department of Environmental Protection, Solid
Waste Management, "Guidelines for Rubber Tire Storage Areas."
50 The description here is based on the Electricity Purchase
Agreement between Exeter Energy Limited Partnership and the
Connecticut Light and Power Company, 1 December 1989.
51 Kevin O'Reilly,  Oxford Energy Company.  Personal
communication, 29 June 1990.
5* Electricity Purchase Agreement, p. 7.
   Electricity Purchase Agreement, Exhibit J-l,  Exeter Financial
Pro Forma.
54 Philip Rettger,  Vice President, Oxford Energy Company.
Personal communication, 9 October 1990.
55 Electricity Purchase Agreement.
Jf Ibid.
57 Philip Rettger.
58 Philip Rettger.
   Exeter will have to share tipping fees only when it meets
certain conditions of positive cash flow that exceed
expectations.  Electricity  Purchase Agreement, Appendix J,
Description of Method of Sharing of Excess Tip Fee Revenues.
* Rhode Island P.L.  1989,  23-63-2.
   Eugene Bishop,  Maine Department of Transportation.   Inter-
Departmental Memorandum, 8  August 1990.
   John Bittner,  National Tire Dealers and Retreaders
Association.  Personal communication, 24 July 1990.
   John Bitter.  These figures exclude heavy truck tires,  which
are often retreaded two or  more times each.
   Mary Sikora, Recycling Research.   Personal communication, 16
October 1990.
65 According to a Preliminary Report of the New  Jersey Emergency
Solid Waste Assessment Task Force, Appendix D, 6 July 1990, 20

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                                                               77

                     
percent of the state's scrap tires are retreaded.  However,
relatively few of these are passenger car tires and many are
heavy truck tires.  Insufficient data are included to separate
the rate of retread for each category.
66 JJbici.
67 Frank Mann,  Pol-X International.   Personal communication, 23
July 1990.  Chris Chisseri, Oxford Tire Recycling of Connecticut,
cited a figure of $1.50 and up.  Personal communication, 12 July
1990.
68 Frank Mann.
69 Lola Cline,  Cline Retreading Co.   Personal communication via
Paul Bedros ian, 7 August 1990.
7 Frank Mann,  Pol-X International.
   Ken Collings,  Federal Tire Program.   Personal communication,
30 July 1990.
72 Ken Collings.
73 Joe Sullivan,  New Jersey Division of Purchasing.   Personal
communication, 23 July 1990.
74 Allen S.  Caldwell,  U.S.  EPA, Region VII.   Personal
communication, 12 July 1990.
75 Tom Ferreira,  F&B Enterprises.   Personal  communication,  27
June 1990.
76 Tom Ferreira.
77 Joe Carpenter, New Jersey Office of Recycling.   Personal
communication, 6 August 1990.
78 Franklin  Associates,  Ltd. "Market Development Study for
Tires," prepared for Hope Pillsbury, Office of Solid Waste, U.S.
Environmental Protection Agency, Draft of 30 August 1989.
79 Bruce Eber,  Tire Salvage, Inc.   Personal  communication,  27
June 1990.
80 Bruce Eber.
81 Mickey Tracy,  MATES Tire Systems.   Personal communication, 5
July 1990.
82 MATES Tire Systems Business Plan,  15 May  1990.
   Dr.  Frank Schaub, Connecticut Department  of Health.   Personal
communication, 19 July 1990.
84 See "A Report on the RMA TCLP Assessment  Project," prepared by
the Radian Corporation for the Rubber Manufacturers Association,
25 September 1989; and "Waste Tires in Sub-grade Road Beds: A
Report on the Environmental Study of the Use of Shredded Waste
Tires for Roadway Sub-grade Support," prepared by the Twin City
Testing Corporation for the Minnesota Pollution Control Agency,
19 February 1990.  The former found no values exceeding proposed
regulatory values for any of the organics or metals tested.  The
latter reported the concentrations of some metals leached under
acid conditions  (ph 3.5 or 5) to exceed Minnesota Department of
Health Recommended Allowable Limits for drinking water under
worst-case conditions.
85 Don Robisky,  Vermont Department of Public Health.   Personal
communication, 8 August 1990.
86 Mickey Tracy.
87 Matt Mayo,  Triple S Dynamics.  Personal communication,  10
August 1990.

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                                                               78


88 Jane Palmer,  Palmer Shredding.   Personal communication, 2 July
1990.
89 Bill Murdoch,  Sawyer Environmental Recovery.  Personal
communication, 26 July 1990.
90 Jane Palmer.
91 Matt Mayo.
92 Bill Murdoch.
93 Bill Murdoch.
94 Jane Palmer.
95 Jane Palmer.
96 Bill Murdoch.
97 Warren Schambeau,  Metropolitan Tire Converters, Inc.  Personal
communication, 10 August 1990.
98 Kevin Parks,  Integrated Tire.   Personal communication, 18 June
1990.
99 Ron Frascoia,  Vermont Agency of Transportation, Materials and
Research Division, per Carole Ansheles, NEWMOA, 8 August  1990.
100 Assumes  a  cubic yard of chips  is the equivalent of 40 whole
tires.
101 Jane Palmer.
102 Note:  The  term "revenue is used here rather than "income",
because neither the tipping fee not the price  of the chips used
is net of expenses, i.e., costs of collection  (transportation,
labor), or processing  (energy, labor, depreciation on  equipment).
103 Bill Stoler,  Baker Rubber.   Personal communication, 10 July
1990.
104 Tim Baker, Baker  Rubber.   Personal communication,  20 July
1990.
105 Tim Baker.
106 Robert Snyder, Tire Technology,  Inc.  Personal communication,
28 October 1990.
107 Steven Roberts, TireCycle  of New England.   Personal
communication, 14 August 1990.
108 Steven Roberts.   Personal  communication,  22 June 1990.
109 Steven Roberts.
110 Steven Roberts.   Demonstration quantities are supplied by
Rubber Research Elastomerics in Minnesota and  Eagleton &
Goldsmith in Ohio, each of which performs half the process.
Together, they generate 40,000 to 50,000 pounds per week  of  the
rubber product.
111 Steven Roberts.
112 John Riendeau, Rhode Island Department of Economic
Development.  Personal communication, 26 June  1990.
113 John Riendeau.
114 John Minicucci, R.W.  Technology.   Personal communication, l
August 1990.
115Mike Deep, American Typlax Systems,  Inc.   Personal
communication, 1 August 1990.
116 Mike Deep.
117 Mike Deep.
118 John H.  Fader, "Scrap Tires: A Potential Alternative Energy
Source to Replace 40,000 Barrels of Oil per Day," Environmental
Manager, October  1990, p. 30-34.

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                                                               79


119  Based on information provided by Rouse Rubber -Industries,  in
testimony given by Mike Rouse before Representative Esteban
Torres, 10 April 1990.
    To  express  price per ton as  price per million BTUs,  first
divide the price per ,ton by 2000 to get price per pound, then
divide by the number ;of BTUs per pound and multiply by l million.
    Tom Flaherty,  Sprague Energy.   Personal communication,  29
October 1990.
122  The conversion from price per ton to  price per cubic yard  is
based on the following assumptions: tires lose 20% of their
weight in the conversion to TDF  (most of the wire removed) and
10% of their volume.  Thus, while 40 whole chipped tires (with no
wire removed) fill a cubic yard and weigh 800 pounds, 44.4 tires
are needed to make a cubic yard of TDF, which will weigh only 704
pounds.  At these ratios, a ton of TDF takes up about 2.8 cubic
yards.
123  suggested by Tom Flaherty as a plausible selling price.
    Andrea Maker,  Champion International.   Personal
communication,  18 June 1990.
125  Mark Hope,  Waste Recovery, Inc.   Personal communication,  18
June 1990.
126  Michael  Barden,  Maine Department of Environmental Protection,
Bureau of Solid Waste Management.  Personal communication, 25
June 1990.
127  Andrea Maker.
128  Irving D. Hodgkin,  Chamption International,  in letter to
Michael Barden, Maine Department of Environmental Protection,
Bureau of Solid Waste Management, 8 June 1990.
129  Michael  Barden.
130  Michael  Barden.
131  Michael  Barden.   Based on total metals and EP Toxicity tests.
Other states may use other tests, with important implications for
the use of TDF.  For example, in Washington, bioassays are used
on ash to be landfilled.  When TDF is burned in wood processing
facilities,  the concentration of zinc has been high enough to
cause the ash to fail the test.   One Washington pulp mill that
has been using TDF as a fuel supplement for ten years has a
variance for its ash due to grandfathering, but no other paper,
pulp, or wood processors in the state can use TDF because the ash
would have to go to the state's only hazardous waste landfill.
Source: Dale Clark, Washington Department of Ecology, Waste
Reduction, Recycling and Litter Control Program.  Personal
communication,  12 June 1990.
132  Eric Kennedy,  Maine Department of Environmental Protection,
Air Bureau.   Personal communication, 22 June 1990.
133  Eric Kennedy.
134  Eric Kennedy.
135  Eric Kennedy.
136  Andrea Maker,  21 June 1990.
137  Andrea Maker,  18 June 1990.

     Note: We can use Champion's estimates of tire consumption
and cost savings to calculate Champion's implicit savings per
million BTU:

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                                                               80
3 million tires = 30,000 tons x .8 x 31 million BTU/ton
                = 744,000 BTU

$.5 million / .744 million BTU = $0.672 savings per million BTU.

This estimate suggests that the earlier computations comparing
the cost of TDF to the cost of coal were reasonable.

138  Garrett Morrison,  Dragon  Products,  Inc.   Personal
communication, 26 July 1990.   See also,
SCS Engineers, et al., Feasibility study to Site and Operate a
Tire Recycling Facility in Washington State, for the Washington
State Department of Trade and Economic Development, Business
Assistance Center and the Washington State Department of Ecology,
January 1989, p. 2-7.
139  Garrett Morrison,  25  June 1990.
140  Garrett Morrison,'18  August  1990.
141  Garrett Morrison.
142  Garrett Morrison.
143  Asphalt Rubber  Producers  Group,  Uses  of  Asphalt Rubber.
144  When the  asphalt-rubber with aggregate is the final  driving
surface, it is called a chip seal.  When the chip seal is applied
to a stressed surface, it is called a "SAM", or stress absorbing
membrane.  When it is covered by a layer of asphalt concrete, it
is called a "SAMI", or stress absorbing membrane interlayer.
145  H.B.  Takallou,  "Benefits  of  Recycling Used Tires in  Rubber
Asphalt Paving," in testimony before the House Committee on Small
Business, Subcommittee on Environment and Labor, and Subcommittee
on Regulation, Business Opportunities and Energy, 18 April 1990.
146  Douglas Bernard,  Chief, Demonstration Projects Division,
Federal Highway Administration,  U.S. Department of
Transportation, in testimony before the House Committee on Small
Business, Subcommittee on Environment and Labor, and Subcommittee
on Regulation, Business Opportunities and Energy, 18 April 1990.
147  Joe  Wedge,  Asphalt Rubber Systems.  Personal communication,  9
July 1990.
148  H.B.  Takallou.
149  Based on  3,416  tons of asphalt mix  required for a 3-inch
thick pavement (H.B. Takallou, BAS Engineering Consultants, in
testimony before the House Small Business Subcommittees on
Environment and Labor, and on Regulation, Business Opportunity
and Energy,  18 April 1990).   Tonnage for 3-inch pavement was
reduced by 2/3 for 2-inch thickness.  Conversion to number of
tires assumes the binder accounts for 7% of the asphalt mix, the
binder is 20% crumb rubber,  and 12 pounds of crumb can be
obtained per tire.
150  Takallou,  op. cit.  No revisions to estimate made.
151  Tim  Baker,  Baker Rubber.   Personal  communication,  20 July
1990.
152  Douglas Bernard,  op.  cit.
153  Al Conforti  and Michael Snure, R.A. Hamilton Corp.   Personal
communication, 10 July 1990.

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                                                               81


154  H.B.  Takallou,  in  testimony presented by Michael  D.
Harrington, PaveTech Corporation before the House Committee on
Small Business, Subcommittee on Environment and Labor, and
Subcommittee on Regulation, Business Opportunities and Energy, 18
April 1990.
155  PlusRide Asphalt,  Inc.   Promotional materials.
156  According to the PlusRide marketer,  the density of the mix is
140 pounds per cubic foot, as compared to 150 pounds per cubic
foot of conventional asphalt concrete mix.  H.B. Takallou,
PaveTech Corporation.
   However, the density can vary with the type of aggregate used.
The City of Newark, NJ quotes a density for their conventional
mix at 155 pounds per square foot.  Frank J. Sudol,  Newark
Department of Engineering.  Materials accompanying press release
of 21 November 1988.
   Furthermore, the contractor that supplied the mix used in
Newark found that his aggregate resulted in a higher density  for
the mix, thus requiring more tons of mix than applications in
other parts of the country.  Michael Snure, R.A. Hamilton Corp.
Personal communication, 10 July 1990.  Presumably, however, the
rubber content of this mix still reduced its overall density  as
compared to a mix composed entirely of New Jersey's conventional
aggregate.
1ST frank J. Sudol.  Materials  accompanying press release.
158  Takallou,  op.  cit.   Estimate of  $114,048 for 3-inch pavement
is based on 3,564 tons at $32 per ton.  Using 2/3 the tonnage
would cost  $76,032.
159  Takallou,  op.  cit.   Cost of asphalt-rubber binder is
estimated at $47 per ton; quantity based on 2/3 of 3,516 tons.
160  Takallou,  op.  cit.   Cost of RUMAC mix is estimated at $41 per
ton; quantity based on 2/3 of 3,326 tons.
161  Jack Van Kirk,  California Department of Transportation.
Personal communication, 2 July  1990.
162  Michael Heitzman,  Federal Highway Administration,  U.S.
Department  of Transportation.   Personal communication, 3 July
1990.
163  Douglas Bernard.
164  Donald Kavenaugh,  Massachusetts  Department of Public Works,
personal communication, 19 July 1990; and Mike Bennett, Rhode
Island Department of Transportation, Design Division, personal
communication, 24 July 1990.
165  Maine Department of Transportation, Technical Services
Division, The Use of Tire Rubber in Pavements  (Preliminary
Report), March 1990, p. 11.
166 Twin City Testing1Corporation, Waste Tires in Sub-grade Road
Beds: A report on the Environmental Study of  the Use of Shredded
Waste Tires for Roadway Sub-grade Support, prepared for the
Minnesota Pollution Control  Agency,  19  February  1990, p.  1.
167  Dana Humphrey,  University of Maine.  Personal communication,
11 July  1990.
168  Peter Bosscher,  University  of Wisconsin (Madison), Department
of  Civil and  Environmental  Engineering.  Personal communication,
18 July  1990.  See  also, Tuncer B. Edil, Peter J. Bosscher,  and
Neil N.  Eldin, Development  of Engineering Criteria for Shredded

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                                                               82


or Whole Tires in Highway Applications, Interim Report to the
Wisconsin Department of Transportation, June 1990.
169  Twin City Testing Corporation,  op.  cit.
J  Ibid.,  p.  34.
171  Edil,  et al.,  op.  cit.,  p.  16.
172  Herb Webster,  Town of  Georgia,  Vermont.   Personal
communication, August 1990.
173  Raymond Cyr, Vermont Agency of  Transportation.   Personal
communication, 5 July 1990.
174  Dr.  Charles Dougan,  Connecticut Department  of  Transportation,
Director of Research and Materials, .Report to the General
Assembly on the Feasibility of Expanding the Use of Materials in
Projects Undertaken by the Department of Transportation, December
1988, p. 15.  The state generates an average excess of 630,000
cubic yards of clean fill material per year, suggesting little
opportunity for using tire chips in highway embankments.
However, the annual demand for subbase material averages 249,700
cubic yards per year.  Specifications for this material are that
it consist of "a clean soil-aggregate mixture of bank and crushed
gravel, crusher-run stone, or a combination thereof." (p. 15)
The volume demanded of this material is listed on the table as a
potential consumer of tire chips.
175  Warren Foster,  Maine Department of  Transportation, Technical
Services Division.  Personal communications, 12 and 18 July 1990.
In 1989, the Maine used 200,000 cubic yards of common borrow.
However, the legislature recently passed a bill providing $30
million per year for the next several years for rebuilding the
state's primary highway system.  Some of the projects related to
this reconstruction will involve embankments and retaining walls.
The annual consumption of fill during these years is expected to
be about 250,000 to 300,000 cubic yards.
176  Rick Antonia,  New Hampshire Department of Transportation.
Personal communication, 20 July 1990.
177  Cathy Diringer,  New Jersey  Department of Transportation,
Recycled Materials Task Force.   Personal communication, 8 August
1990.  This figure represents the amount of "zone 3 borrow/fill"
purchased in 1989.
178  Mike Bennett,  Rhode Island  Department of Transportation,
Design Division.  Personal communication,  24 July 1990.  Rhode
Island is currently involved in some large highway construction
projects that require large volumes of fill.  One such project
may use 200,000 cubic yards, and another may use an additional
200,000 to 300,000 cubic yards.  These projects are not typical,
however.  The estimate presented here is based instead on an
ongoing program to reconstruct old roads with narrow lanes and no
shoulders.  A typical reconstruction project consumes about
15,000 cubic yards of common borrow, and 20 to 25 such projects
are completed each year.
179  Milon Lawson,  Vermont  Agency of Transportation,  Materials  and
Research Division.  Personal communication,  24 July 1990.
180  Cathy Diringer.
181  Mike Bennett.
182  Warren Foster.

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                                                               83

1 S3
   Maine  Department of Transportation,  Technical Services
Division,  Preliminary Report on the Use of Tire Rubber in
Pavements, March 1990, p. 13.
184 Cathy  Diringer.
185 Bill McGrath, Vermont Department of  Economic Development.
Personal communication, 2 July 1990.
186 Based  on  a price of $3 per ton,  and  a density of 120  pounds
per cubic yard.  Cathy Diringer.
187 Ray Gile,  International  Soil  Systems.   Personal
communication, 11 July 1990.
   Diana  Shannon,  Chief,  RCRA Compliance Monitoring Section,  US
E.P.A.,  Region VIII, in a letter to Bill Lawsen, Colorado
Department of Agriculture, 9 January 1987: "Based on the chemical
data that [the president of a company promoting the use of crumb
rubber]  submitted for the proposed soil amendment... the
concentrations are an order of magnitude less than those
standards for the characteristic of EP toxicity  (40 CFR 261.24)."
3 Ray Gile.
190 John N. Rogers,  Department of Crop and Soil  Sciences,
Michigan State University.  Personal communication, 27 September
1990.
191 John Rogers.
192 Based  on  an installation cost of $72,000,  conventional annual
maintenance costs of $50,000 per year,  and a discount (interest)
rate of 10%.   Higher conventional maintenance costs, a higher
savings rate, a longer time horizon, or a lower interest rate
will increase the attractiveness of such a project; the opposites
will decrease the value of the project.
193 John Rogers.
   International Soil Systems,  Inc.  April 1990 Business Plan.
   Ray Gile.   Personal communication, 28 September 1990.
   U.S. Consumer Product Safety  Commission, A Handbook for
Public Playground Safety, Volume II: Technical Guidelines for
Equipment and Surfacing, p.  22.
T QP7
   Dr. Francis Wallach,  Total Recreation Management Services.
Personal communication, 20 July 1990.
198 Francis Wallach.
199 Ken Richardson,  Tire Turf Systems.   Personal communication,
11 July 1990.  Cost based on 14 pounds needed to cover a square
foot 6 inches deep.  For purposes of comparison, a cubic yard  of
1/2" granules weighs 756 pounds, and thus costs about $75.
200 Wallach.   Pea gravel and sand are about $1 per  square foot,
while wood fiber is about $2.80.  However, wood fiber surfaces
need to be replaced more frequently than rubber granules.
201 Francis Wallach.
202 Bill McGrath, Vermont Department of  Economic Development.
Personal communication, 2 July 1990.
203 Maine  Department of Environmental Protection,  Bureau  of Solid
Waste Management,  Report to the Legislature on Tires, White
Goods, & Demolition Debris,  May 1989, p. 25.  Figure based on
estimate of 68 cents per ton per 150 miles, cited from a 1988
interim report for the State of New Hampshire by R.W. Beck, and
100 tires per ton.

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                                                               84


204 Robert Vail, Vice  President,  R.A. Hamilton  Corp.   Personal
communication, 10 July 1990.
205 Michael Heitzman,  U.S.  Department of Transportation,  Federal
Highway Administration, Pavement Division.  Personal
communication, 3 July 1990.
206 Franklin Associates,  Ltd.   Market Development Study for
Tires, Draft Report, prepared for Hope Pillsbury, U.S.
Environmental Protection Agency, 30 August 1990, Table 2.
207 To be precise,  some of  this consumption depends  on public
expenditures because it includes a small number of retreaded
truck tires purchased by the public sector,  and crumb rubber
additives to paving materials that are typically paid for by
states or cities.  However, the volume of material accounted  for
by these uses is probably only a small percentage of the 7.5
million tires currently consumed.
208 Massachusetts  Executive Office  of Environmental  Affairs,
Department of Environmental Protection, "Toward a System of
Integrated Solid Waste Management: The Commonwealth Master Plan,"
June 1990,  p. 53.
209 The fee  is also used to cover the costs of  other aspects of
Oregon's waste tire program, including the permitting of tire
storage sites, the licensing of tire haulers, and the cleanup of
some tire piles.  Additional tire pile cleanups have been
privately financed.
210 Deanna Mueller-Crispin,  Oregon  Department of Environmental
Quality.  Personal communication, 15 June 1990.
*11 Deanna Mueller-Crispin.
212 Deanna Mueller-Crispin.
213 Dale Clark,  Washington  State Department of  Ecology.   Personal
communication, 12 June 1990.
214 Deanna Mueller-Crispin.
215 Thomas E.  James,  Science and Public Policy  Program,
University of Oklahoma, and Richard Brooks,  Solid Waste Division,
Oklahoma State Department of Health, "State Incentives for
Private Sector Scrap Tire Recycling: The Oklahoma Program,"
presented at the First U.S. Conference on Municipal Solid Waste
Management, 13-16 June 1990.
217 John Riendeau,  Rhode Island Department of Economic
Development.  Personal communication, 26 June 1990.
218 Mike Kennedy,  Waste Management,  Inc.,  Tire and Fuel Reduction
Group.  Personal communication, 10 July 1990.
219 Steven Roberts.
220 H.R. 4147.

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