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  This guidebook was conceived during a planning session convened by U.S. Environmental Protection
  Agency Region 5 in February 2004. After consideration of the extensive input obtained during
  and after this session, U.S. EPA Region 5 and the Illinois EPA partnered to create and publish the
  guidebook. U.S. EPA Region 5 would like to specifically thank Mr. Terry Gray of T.A.G. Resource
  Recovery for providing his expertise in preparing this document. The following individuals also made
  significant contributions to the document:
    Michael Blumenthal, Rubber Manufacturers Association
    Larry Bowerman, U.S. EPA Region 9
    Jack Brunner, Tetra Tech EM Inc.
    Jan Rae Clark, Florida Department of Environmental Protection
    Paul Crissman, North Carolina Department of Environmental and Natural Resources
    Craig Detweiler, Entech, Inc.
    Toni Duggan, New Mexico Environment Department
    Jeff Edwards, Nebraska Department of Environmental Quality
    George Gilbert, Kentucky Department of Environmental Protection
    Mike Giuranna, U.S. EPA Region 3
    Mark Hope, Tire Disposal & Recovery Inc.
    Paul Koziar, Wisconsin Department of Natural Resources
    Bob Large, Ohio EPA
    Allan Lassiter, Virginia DEQ
    Todd Marvel, Illinois EPA
    Ethan Mayeu, Mississippi DEQ
    Ken McDaniel, Indiana Department of Environmental Management
    Pam Moore, North Carolina Division of Waste Management
    Chris Newman, U.S. EPA Region 5
    Hope Pillsbury, U.S. EPA Office of Solid Waste
    Mel Pins, Iowa DNR
    Dave Quarterson, Liberty Tire Services Inc.
    Paul Ruesch, U.S. EPA Region 5
    Harry Smail, Ohio EPA
    Pamela Swingle, U.S. EPA Region 4
    Jim Waldron, Tri-Rinse, Inc.
    Anne Weinkauf, Indiana DEM
    Rhonda Zimmerman, Michigan DEQ

        Scrap Tire Cleanup
               A Resource for
           Solid Waste Managers
          Across the United States
                  January 2006

     U.S. EPA Region 5
Waste, Pesticides and Toxics Division
 77 West Jackson Boulevard (DW-8J)
   Chicago, Illinois 60604-3590
     Illinois EPA
    Bureau of Land
  1021 N. Grand Ave. East
     P.O. Box 19276
Springfield, Illinois 62794-9276

 Section                                                  Page




   MARKETS	18      j
   PROPERTY ISSUES	19      \

   CONTRACTS	25      1

   SITE SURVEY	27      |
   EQUIPMENT	27      *
   SECURITY	29      *
   SAFETY	30      ซ
   COMMUNICATION	32      \
 SECTION 6 - SUMMARY	35      *



               CDC  Centers for Disease Control and Prevention

               DEM  Department of Environmental Management

              DENR  Department of Environment and Natural Resources

                DEP  Department of Environmental Protection

               DEQ  Department of Environmental Quality

               DNR  Department of Natural Resources

              DWM  Division of Waste Management

               DOT  U.S. Department of Transportation

                EPA  Environmental Protection Agency

                GIS  Geographic information system

                GPS  Global positioning system

                IFB  Invitation for bid

              IWMB  Integrated Waste Management Board

                PTE  Passenger tire equivalent

                RCC  Resource Conservation Challenge

                RFP  Request for proposal

                RFQ  Request for qualifications

               RMA  Rubber Manufacturers Association

                TDF  Tire-derived fuel

                TRA  Tire removal agreement

tire management programs involving stockpile abatement.
                                        Despite over 20 years of efforts to address scrap tires,
                                        large stockpiles continue to be a problem across the
                                        United States. Based on data compiled by the Rubber
                                        Manufacturers Association (RMA), it is estimated
                                        that 275 million tires remained in stockpiles across
                                        the United States in 2003 and that approximately 290
                                        million new scrap tires are generated each year. RMA
                                        also estimates that more than 90 percent of the illegal
                                        scrap tire accumulation and associated stockpiles are
                                        concentrated in 11 states.  Although some of the states
                                        have abatement programs in place and are currently
                                        reducing stockpile inventories, others have yet to
                                        establish and consistently fund comprehensive waste
Large scrap tire stockpiles present a threat
to human health and the environment
for several reasons.  They provide an
ideal breeding ground for mosquitoes,
which can carry and transmit life-
threatening diseases such as dengue fever,
encephalitis, and the West Nile virus.
A dictionary definition of a stockpile is a supply
of material intended for future use. However, the
practical reality is that few waste tire stockpiles
have future use without regulatory and enforcement
programs. History has shown repeatedly that
even stockpiles at operating processors have to be
controlled. Therefore, a stockpile referred to in
this guidebook is any accumulation of waste tires,
regardless of intended use.
Stockpiles may also catch fire as a result of
lightning strikes, equipment malfunctions,
or arson. The longer a stockpile is
unabated, the more likely it is to catch
fire.  Some experts no longer consider the question of "if" a stockpile will catch fire but "when" it
will burn. Tire fires typically cause air, surface water, soil, groundwater, and residual contamination
that has negative impacts on human, animal, and plant life. When ignited, scrap tire piles generate
                                                     dense, black smoke containing partially
                                                     combusted hydrocarbons. The smoke
                                                     plume can negatively impact residences
                                                     and businesses in its path as well as
                                                     the air quality in a broad area for a
                                                     long time. In addition to smoke, some
                                                     tire fires produce large quantities of
                                                     pyrolytic oils containing hazardous
                                                     compounds. Under certain conditions,
                                                     these oils can penetrate porous soils
                                                     to contaminate groundwater that may
                                                     be used as drinking water. The oils
                                                     can also reach surface water and cause
                                                     substantial fish kills, as the oils quickly
                                                     deplete dissolved oxygen levels. Finally,
                                                     the residuals (ash, wire, and unburned
                                                     rubber) from a tire fire often require
                                                     special handling and disposal.
Photo courtesy of Paul Ruesch, U S EPA
                                                                 Section 1: Introduction

                                                    State, federal, and local agencies have spent
                                                    hundreds of millions of dollars over the past
                                                    several decades in responding to tire fires and as a
                                                    general rule, it is five to ten times more expensive
                                                    to remediate a fire site than to simply remove the
                                                    tires before they catch fire. In addition, stockpiles
                                                    in urban areas are impediments to redevelopment
                                                    of brownfield properties for constructive use and
                                                    for revitalization of economically stressed areas.
                                                    Finally, scrap tire stockpiles encourage open
                                                    dumping of other wastes.

                                                    Scrap tire stockpile cleanup has been given
                                                    increased priority by many states and local
                                                    jurisdictions as the threats described above manifest
     themselves over and over. Many state legislatures have established comprehensive programs and
     have committed funds to address the problem. In addition, stockpiles present an opportunity for tire
     recycling, reuse, and energy recovery. In response to requests for federal leadership, the U.S. EPA
     established a group of individuals representing manufacturers, processors, recyclers, and end users
     of tire products as well as state agencies to formulate a strategy for addressing scrap tires. As part of
     the Resource Conservation Challenge (RCC), the group established a goal for mitigation of 55 percent
     of stockpiled scrap tires by 2008. Because state governments have primary authority over scrap tire
     stockpiles, U.S. EPA is working on several projects designed to add value to efforts to mitigate the
     problem (see http://www.epa.gov/region5/solidwaste/tires.htm).
                                              01 Wt W. I
U.S. EPA, in cooperation with several
states, developed a simple approach
for conducting an inventory of
scrap tire stockpiles and developing
geographic information system (GIS)-
based maps of stockpile locations. The
maps and associated GIS databases
of site information, both maintained
by individual states, will assist in
establishing a baseline that can be
used to foster the development of new
markets for scrap tires and to prioritize,
plan, budget, and track the progress of
statewide cleanup efforts.  In addition,
U.S. EPA is holding forums in target
states to convene key players in tire pile
mitigation efforts in order to present best
practices and case studies for successful
tire cleanup and firefighting efforts (see http://www.epa.gov/epaoswer/non-hw/muncpl/tires/index.

The purpose of this guidebook is to document best practices for scrap tire stockpile mitigation in order
to assist readers nationwide in planning, managing, and completing abatement projects in a safe,
efficient, and cost-effective manner.  The target audience includes state, county, and municipal health
and solid waste officials as well as cleanup contractors across the United States. Currently, no federal
laws or regulations exist that specifically define a "scrap tire" or address scrap tire management.
Therefore, readers should contact the appropriate state agency to determine state-specific requirements
and identify applicable cleanup or abatement programs.
State  Involvement
States are the driving force behind control and abatement of scrap tire stockpiles. Broad state
adoption of regulations and regional coordination of neighboring states and local governments
have dramatically decreased the incidence of illegal scrap tire storage and disposal. However, local
regulations have a limited impact on controlling statewide scrap tire movement and accumulation.
Scrap tires  can be transported short distances inexpensively, so they usually are moved to the nearest
unregulated jurisdiction or the destination with the lowest disposal cost. Concerns over the costs and
hazards associated with large stockpiles as well as the proliferation of new stockpiles have driven most
  Federal Scrap Tire Enforcement Authority

  Under Section 7003 of the Resource Conservation and Recovery Act, EPA has enforcement tools
  that can be used to decrease environmental conditions that present "imminent and substantial
  endangerment to health or the environment." This authority specifically mentions scrap tire stock-
  piles and is a tool that can be used at the federal level to remediate scrap tire piles that pose the
  greatest endangerment to health or the environment. For more information, visit: http://www.epa.
This section defines important regulatory and
enforcement roles that states have assumed to control
and abate scrap tire stockpiles. Many stockpiles
were created decades ago when such storage was
unregulated.  As a result, many states are forced to fund
the cleanup of these "legacy" stockpiles because those
involved in creating the stockpiles lack the resources
necessary to clean them up. Because states have
different industrial, economic, political, and geographic
characteristics, no single scrap tire program is
universally applicable. Therefore, this section discusses
alternatives that can be applied to specific conditions.
A complete inventory of state scrap tire programs,
including legislation, regulations, guidance, and
contacts, can be found at http://www.rma.org/publications/scrap_tires/index. It is important to note
that when state programs sunset without continuation of enforcement provisions, there is renewed
vulnerability to illegal stockpile formation.
          Photo courtesy of Mel Pins, Iowa DNR
Unfortunately, scrap tire stockpiles do not have a positive net value, as abating stockpiles costs more
than can be derived from product revenue.  If stockpile owners are unable or unwilling to fund
cleanups, the stockpiles become public liabilities, and funding to abate the associated public health and
environmental hazards must be provided.

States generally establish funding mechanisms within the enabling legislation that initiates their
scrap tire programs.  These programs are implemented by the regulatory agencies that are typically
responsible for the following activities:
                                                                Section 2: State Involvement

       •    Creating, implementing, and enforcing
           regulations governing storage, transport,
           processing, and disposal of scrap tires

       •    Working with the private sector to
           develop the processing and market
           infrastructure required to use scrap tire

       •    Abating existing stockpiles

       •    Addressing human health and
           environmental hazards associated with
           illegal scrap tire accumulations prior
           to cleanup (for example, mosquito
           prevention and abatement and fire
           prevention and planning)

     In general, most programs begin by
     documenting the extent of the problem by
     identifying, quantifying, and prioritizing
     stockpiles. Because most abatement programs
     seek to constructively use scrap tires removed
     from stockpiles, the presence of a processing
     and market infrastructure is important.
     Moreover, one should bear in mind that in most
     cases, the responsibilities and activities listed
     above compete for limited financial and staff resources.

     Effective scrap tire programs generally have the financial management characteristics discussed below.

     Dedicated Funding Source. Effective scrap tire programs require consistent and continuing funding.
     Ongoing monitoring and enforcement programs are required to prevent new stockpiles from forming
     after remediation of existing stockpiles.  Variability in funding negatively impacts annual cleanup
     volumes,  cash flow, capital utilization, and markets, thereby weakening the industry's infrastructure
     as well as government monitoring and enforcement programs.  Dedicated trust funds have been
     used successfully to achieve uniformity but are  vulnerable to recapture or readjustment during state
     budget shortfalls.  If recapture occurs during the early program stages, stockpile abatement may be
     delayed.  Once stockpile abatement is completed and other program objectives are achieved, recapture
     of uncommitted and underutilized funds may be appropriate. However, trust fund residuals have also
     been successfully used to continue monitoring, enforcement, and abatement activities.
Factors Influencing a Scrap Tire
Abatement Program
  •    Quantity: The number of stockpiles and
       the total scrap tire quantity affect the
       abatement schedule.

  •    Resources: Financial and staff resources
       required to plan, perform contracting
       for, and monitor multiple site abatement
       projects must be available.

  •    Access: Obtaining site access for
       abatement can be a prolonged legal
       process, depending on the procedures
       defined in the enabling legislation.

  •    Infrastructure: Capacity limitations of
       both contractors and markets must be
       recognized to avoid detrimental impacts
       on the use of scrap tires being generated.
       The overall objective should be to create a
       sustainable infrastructure for using scrap
       tire resources over the long term.
       Using a Dedicated Trust Fund for Scrap Tire Abatement in Oregon

       Oregon initiated its waste tire management program in 1988, placing the net revenue from its
       $1.00 per tire fee (minus $0.15 per tire for the dealer and $0.035 per tire in administrative costs)
       in a dedicated trust fund. Between 1988 and 1993, Oregon abated 3,823,440 tires at 63 sites at a
       cost of $3,749,041. An additional 101 voluntary cleanups involving 500,000 tires were performed.
       The fund also supported market development and established an ongoing regulatory framework
       for processors and haulers. When the program sunset in 1993, about $1.4 million remained in
       the trust fund. This fund (plus annual interest payments and small licensing fees) was used to
       support continuing regulatory licensing and enforcement activities as well as abatement of small,
       residual stockpiles. In 2003, approximately $600,000 remaining in the trust fund was recaptured
       by the legislature during a severe budget shortfall. Enforcement efforts are now supported under
       the general umbrella of solid waste management fees levied on landfills.
Section 2: State Involvement  4

Adequate Resources. In general, funding levels equivalent to at least $1 per scrap tire have proven
to be adequate to implement comprehensive programs, with 35 to 50 percent of the funds initially
committed to stockpile abatement.  Examples of states with successful abatement programs at this
funding level include Florida, Illinois, Iowa, and Oregon among others.

Funding Flexibility and Accrual.  Abatement funds are often accrued in the early program stages
while scrap tire stockpiles are being identified, prioritized, and legally accessed. This funding allows
subsequent contractual commitments to be met and provides contingency funds for unpredictable
events. As abatement activities are completed, it is generally appropriate to shift funding to other
program priorities or to reduce revenue in order to reflect the lower financial requirements associated
with permitting, enforcement, and market development activities.

Regulations and infrastructure are necessary for an abatement program to be effective and efficient.
If management transport and disposal of the scrap tires generated each day are not controlled by
regulations, new stockpiles will be created as old ones are cleaned up. Regulatory and permitting
requirements for scrap tire-related businesses vary widely from state to state.  While some states
have been successful with limited permitting or no permitting at all, others monitor tire movement
with comprehensive  manifest systems and require permits for all businesses involved. There have
been successes and failures in both approaches. The primary objective of a regulatory or permitting
program should be to ensure the proper transportation, storage, and disposal of scrap tires and prevent
formation of illegal stockpiles.

Processing and Storage Facilities.  Some of the largest
scrap tire stockpiles have been created at processing
facilities or at storage facilities formed in anticipation
of future processing,  often before state programs were
enacted.  In some cases, the developer does not intend
to create  a viable facility, just to collect tipping fees
as long as possible or until the facility is at capacity.
In other cases, a viable facility encounters financial,
equipment, or market problems, and if the problems
cannot be resolved, the facility fails. In  either case, the
facility owner or operator ends up leaving behind a
public liability.  In an effort to prevent either situation,
virtually all state programs regulate processing and
storage locations to control  scrap tire accumulation.       Photo courtesy of Gary Mew, Pnmary Power

Storage facilities are generally required  to be permitted or registered in order to store  any scrap tire
quantity  above a stated minimum that can typically range from 50 to 10,000 tires. The minimum
should be carefully considered. A low minimum forces many commercial tire stores to use inefficient
collection methods such as frequent hauling of small quantities  of scrap tires.  A low minimum may
also unnecessarily increase  the burden on both the stores and regulators by requiring  registration.
Experience has shown the optimum quantity to be 1,500 to 2,500 tires, which allows a store to
accumulate a truckload of tires for optimum hauling efficiency plus a limited additional scheduling
buffer. The stored tires should be kept under cover and secure to control public health and fire

Processing and larger storage facilities should be permitted or registered. Moreover, they should be
monitored regularly to ensure their conformance with appropriate regulatory criteria  such  as zoning,
building, and fire codes as well as engineering criteria governing stockpile size and separation, fire
control, mosquito and rodent control, runoff, and other critical factors. Maximum storage limits are
normally established during permitting. Low limits can impair efficient operations by preventing
                                                                       Section 2: State Involvement

     maintenance of adequate inventories to compensate for inherent variations in supply, equipment
     maintenance downtime, or market fluctuations. On the other hand, high limits can increase public

     An effective compromise allows accumulation of 2 to 4 weeks of scrap tire and/or product inventory
     based on a facility's demonstrated operating and sales history, provided that the storage conforms to
     fire and safety codes and engineering criteria. In addition, financial assurance should be required to
     cover retrieval and disposal costs for the maximum permitted quantity of tires based on contractual
     disposal rates or third-party quotations. If third-party rates are used, they should include detailed
     descriptions of retrieval, transport, and disposal methods along with locations and costs to allow
     confirmation of their validity. Inadequate financial assurance for actual site abatement may result
     from third-party estimates that are grossly understated  as a mutual favor between processors or a
     misunderstanding of financial assurance requirements.  Therefore, it is advisable for a regulatory
     agency to require that removal cost estimates be based on contractual or historical costs.
       Florida Enforcement Efforts Targeting Haulers and Tire Store Owners

       As part of its efforts to control illegal dumping and scrap tire stockpile formation, the Florida
       Department of Environmental Protection has developed regulations requiring scrap tire haulers
       to register with the state and tire stores to use only registered haulers. Enforcement officers in
       Hillsborough County, Florida, conducted a "sting" operation in which undercover officers posing
       as unregistered haulers offered to take scrap tires at below-market cost from tire stores. At the
       conclusion of the operation, 24 store managers who accepted the offer were served with warrants
       from the State Attorney's Office for a statutory violation punishable by a fine of up to $1,500 and
       1 year in jail.  The judge was generally lenient with the managers as first-time offenders but
       promised to exercise the full force of the law if the offense was repeated.  The sting served as a
       warning to store owners and focused broad public attention on proper tire disposal practices.
       The county has had few repeat offenders and has stated that additional sting operations may be
       conducted if there are indications of illegal scrap tire hauling activity.
     Haulers. Haulers are generally considered to be the
     weak link in the scrap tire management chain. The
     business is extremely competitive, and ultimate disposal
     charges represent a major percentage of the revenue that
     haulers collect from tire dealers. The incentive to reduce
     cost is substantial, especially among smaller haulers
     with no long-term capital commitment to the business.
     For this reason, controls are often necessary to reduce
     the possibility of haulers using inappropriate disposal
                                                           Image courtesy of Todd Marvel, Illinois EPA
     One option is to register haulers annually and to provide a decal for display at a prescribed location
     on each transport vehicle. This option allows enforcement officials to check compliance from their
     vehicles. Haulers can submit quarterly, semiannual, or annual summaries of collected tire quantities
     and disposal locations, keeping detailed records for at least 3 years that are subject to spot audits. Also,
     requiring processors and disposal sites to maintain records by decal number provides a cross-checkable
     audit trail.

     Some states require financial assurance for each scrap tire-related vehicle or business, with the amount
     ranging up to $20,000 per business. This measure can exempt small haulers; however this is the group
     that is most likely to illegally dump tires. This measure can also have a negative impact on smaller
     haulers operating in rural areas, which may be viewed  as discriminatory against small business. Most
     states either do not require hauler bonds or keep them relatively small on a per-vehicle or per-business
Section 2: State Involvement   6

basis. In addition, some states only require bonding or financial insurance for commercial car-for-hire

Tire Stores.  Tire stores can play a key role in preventing illegal scrap tire disposal. When a store
owner or operator receives a quote for tire disposal that is below the market price, it likely involves
illegal disposal. If the owner or operator is required to keep records of the registered hauler decal
numbers and the tire quantities handled, an auditable trail is maintained. Periodic record review,
enforcement for noncompliance, and tracking tires collected by unregistered haulers back to the
source are all useful deterrents to illegal tire disposal.  A state with a manifest system can reinforce
the responsibility of stores by requiring them to maintain a copy of each completed manifest showing
the ultimate disposal site, as has been done in Oklahoma and Texas. Other states require hauling and
disposal receipts to be maintained on the store's property;  however, the receipts are not required to be
submitted to the regulatory agency. This still allows for the regulatory agency to conduct audits  of a
used tire store's records without the administrative costs of a formal manifest system.

Enforcement and cost recovery tactics are integrally linked. With a goal of facilitating site access and
scrap tire stockpile removal, it is important to avoid creating legal and economic obstacles that may
delay abatement activities.

Several states have provisions allowing their agencies to enter into access and abatement agreements
at public expense without cost recovery. This approach expedites site cleanup, and the site owner
or operator usually welcomes the assistance. However, the approach increases public expense and
provides no incentive to mitigate sites, many of which (1) are established and operated with no regard
for regulatory compliance for many years or (2) were established before regulations were implemented.
Such leniency may lead to additional stockpile formation, as the site owner simply opens another site
nearby and resumes scrap tire collection and accumulation activities, typically under a different name.

On the other hand, states such as Illinois, Nebraska, New York, and Ohio have provisions that give
their agencies site access to conduct stockpile abatement without forfeiting cost recovery.

Most state programs require the regulatory agency to prove in court that a scrap tire stockpile
represents a  public health or environmental hazard. Furthermore, the state must prove that the
landowner has been given every reasonable opportunity to achieve compliance and remedy the hazard.
  Illinois Use of Tire Removal Agreements

  One option for avoiding enforcement and cost recovery obstacles is use of a voluntary tire removal
  agreement (TRA) between the owner of a property where scrap tires are located and the regulatory
  agency. This voluntary, written agreement, which is established pursuant to statutory authority,
  allows the removal of all scrap tires from the property at no cost to the state.

  Provisions must be established in the TRA to ensure that the removal action is conducted in a
  manner that is fully protective of human health and the environment during the entire period
  of the agreement. Statutory authority may allow for maximum removal schedules such as the

    •    Three months if the site contains 1,000 tires or less

    •    Six months if the site contains more than 1,000 but less than 10,000 tires

    •    One year if the site contains 10,000 or more tires

  Extensions of the removal schedule may be allowed if the property owner is operating in good faith
  to execute the agreement.
                                                                     Section 2: State Involvement

     Because of false starts on cleanups, repeated failures to comply, and court delays, this process can be
     time-consuming, cumbersome, and expensive. The measures discussed next can enhance the efficiency
     and effectiveness of the process.

     Dedicated Legal Assistance. Gaining priority for legal resources within a regulatory agency can be a
     major obstacle. In addition, frequent changes in legal staff can further slow the process. Dedicating
     legal staff in both the regulatory agency and attorney general's office can help to achieve successful
     legal efforts.  Legal staff familiarity with the process, the players, and effective arguments is a key factor
     in winning repeated cases.
       Forced Removal Actions in Illinois

       State of Illinois Compiled Statute 415, Title XIV, governs all used tire management practices (see
       http://www.epa.state.il.us/land/tires/index.html).  Section 55.3d of this statute enables the Illinois
       EPA to notify a landowner of the environmental and public health hazards associated with a
       scrap tire stockpile. The landowner then has an opportunity to develop, submit to the Illinois
       EPA, and implement an abatement plan meeting the specific requirement outlined in the 55.3.d.
       Notice. If the landowner is unwilling or unable to comply with the removal schedule, or does not
       submit a removal schedule in response to the Notice, the state is granted access to the property via
       existing statutory authority. As an added precaution to confirm the protection of the landowner's
       constitutional rights, the Illinois EPA uses an access agreement that is signed by the landowner
       prior to the removal action.  If the landowner refuses to sign the access agreement, the Illinois EPA
       will then go into court to seek access from a judge. Illinois EPA's access agreement is available at

       Under Illinois' program, if the waste tire site contains in excess of 250,000 passenger tire
       equivalents (PTE) or 3,125 tons, then the landowner is given the opportunity to enter into a
       cost recovery reimbursement schedule not to exceed 5 years. This allows the recovery of costs
       without going through the full formal enforcement process, provided the landowner remains
       in compliance with the reimbursement schedule.  The landowner has an incentive to reach an
       agreement because the Illinois EPA has a legal right to levy additional punitive damages not to
       exceed two times the actual expenditures associated with the stockpile abatement.
     Initial Legal Support.  Rigorously supporting the initial legal proceedings (complaints, testimony,
     and depositions) with sound preparation, good research, and expert testimony encourages defendant
     negotiation and capitulation. Furthermore, when the strength of cases and the commitment to follow
     through are recognized by others in the scrap tire industry, they are encouraged to comply with
     regulations in order to avoid similar confrontations.

     Negotiations. When cases are strong and the regulatory agency is determined, some site owners
     recognize the economic advantage of mitigating their sites on their own. They can typically mobilize
       Dedicated Legal Support Services for Scrap Tire Cases in Wisconsin

       The Wisconsin DNR reimbursed the state Attorney General directly from its waste tire fund for
       a lawyer and support services dedicated to scrap tire cases. The dedicated attorney's repeated
       experience with scrap tire cases enhanced efficiency and effectiveness, eliminating significant
       blockades in the legal process. During the 1988 to 1997 period of Wisconsin DNR's program, the
       State of Wisconsin abated almost 11 million tires at 162 sites and encouraged removal of almost
       4 million tires from an additional 408 sites. The state pursued cost recovery for some sites and
       achieved judicial judgments or negotiated agreements for a total of $866,750, with about $330,000
       actually being collected as of program sunset.
Section 2: State Involvement

contractors and select disposal methods at a lower cost than the agency.  Additionally, they can avoid
the legal costs and state administrative expenses that would be incurred in legal cases.  Providing a site
owner with information on the difference in costs associated with different types of responses to the
complaint can be compelling during initial negotiations. If a site owner lacks adequate resources but
has income, an agreement covering reimbursement over time can be beneficial. For example, Florida
encourages significant abatement activity through aggressive cost recovery. Nearly 9 million of the 15
million stockpiled scrap tires in Florida were abated by  site owners or responsible parties. The cost
savings were substantial, which is critical for states with limited financial resources.

Judgment Collections. Only a small percentage of judgments rendered against site owners and
operators are actually realized. Typically, offenders hide assets, declare bankruptcy, or disappear. A
judgment can be a long-term nuisance to an offender, precluding accumulation of any assets subject to
the judgment. Cost recovery's primary value is to create an incentive for landowner abatement of a site,
not to realize financial judgments against offenders without assets.

Liens. Liens can be the most effective method of cost recovery from site owners. Most states do not
foreclose on liens but hope to gain some revenue from negotiated interim payments or from sale of
the property (especially commercial property) in the future. For example, Florida files liens before
beginning abatement activities and perfects the liens once all abatement costs have been compiled.

  Factors That May Limit the Applicability of Liens

   •    Homestead: Some states allow primary residential property to be declared a homestead,
        protecting it from debt or judgments other than taxes. In such cases, liens have no practical
        value unless the property acreage exceeds homestead limits and can be separated for
        lien purposes. In some cases, excess acreage has been forfeited to the state as part of a
        negotiated settlement. In one case, a parcel was deeded to the county by the state for        ;
        conversion into a park.

   •    Prior Judgments: Prior liens or judgments placed against a property by others may exceed
        the property value and effectively negate the usefulness of the state's lien.

   •    Property Condition: Before a lien or partial settlement involving land transfer is exercised,
        it is important to carefully examine the property's condition. This examination will
        ensure that liability is not assumed for contaminated property and additional remediation
        expenses. Many properties containing scrap tire stockpiles have suffered prior abuse or
        environmental damage.  Two  properties containing large stockpiles in New England and
        Wisconsin were also high-priority Superfund sites because chemical-filled drums were
        buried among and under the tires. Assuming additional liability for contaminated land
        requires a careful cost-benefit analysis.
                                                                     Section 2: State Involvement

       SECTION  3
       Scrap tire stockpile abatement is a technical, economic,
       and political challenge. Cleanups involve elusive factors
       such as weather, stockpile contents, and underlying
       topography. Proper planning can limit adjustments
       that consume resources, thereby minimizing impacts
       on overall program performance and cost.  This section
       presents critical planning considerations for both an
       overall cleanup program and individual abatement
Stockpile identification is the first step in defining the magnitude of the scrap tire stockpile problem in
any jurisdiction. The most effective identification methods have involved all levels of government and
enforcement as well as industry groups and citizen reports.

State Government. State solid waste and public health agencies play a focal role in scrap tire stockpile
identification efforts. These agencies have a broad range of organizational structures. Centralized
agencies deploy personnel to each region of the state to work with county, city, and local officials
in identifying and characterizing sites. Other agencies either designate one person in each regional
office to identify stockpiles or distribute the responsibility to all staff based on their geographic or
industry area of expertise.  Smaller identification groups are easier to train and gain greater knowledge
through in-depth experience. However, these advantages can be offset by greater travel time, cost, and
difficulty in making regular visits to examine changing site conditions.

One effective compromise is to use a broad base of individuals to identify stockpiles in their service
areas and then task a smaller group to characterize and prioritize stockpiles. Contractors or consultants
may be useful for supplementing agency resources in the early stages of program implementation.
Finally, other state  or local  authorities can be leveraged, such as forestry, park, wildlife, natural
resource, and police agencies.  Such authorities have field personnel with extensive knowledge of rural
areas that often harbor stockpiles.

County and Local  Governments. Most effective programs have drawn heavily upon county, city,
and local governments to identify stockpiles. Police, code enforcement, mosquito control, solid waste
management, public health, park, firefighting, forestry, and game and fish personnel have all helped to
identify stockpiles encountered during their normal activities.

One state sent surveys to all county and local governments (including those for municipalities with
over 1,000 people)  during initial scoping activities. The survey asked for stockpile sites to be identified
by location, street address, and owner. Cooperation in such efforts can be enhanced by the survey
objectives and methodology and by explaining the ability of the program to help local governments
abate identified sites without consuming local resources.

Additional Identification Methods. Other creative  methods can be used to support identification
efforts, including the following approaches:

  •    A toll-free telephone number can be established to encourage residents to report stockpiles and
       illegal dumping activities. Local governments and industry organizations can be leveraged
       to disseminate information about the program. Many large stockpiles are found based  on
       information provided in citizen complaints.
  Section 3: Planning

  •    Both public service announcements and promotion of initial abatement activities encourage
       reporting of additional stockpiles.

  •    Committees consisting of representatives of tire dealers, salvage yards, and haulers can reach
       out within their respective industries to encourage stockpile identification.

Required Information.  Once a stockpile is identified, characterization is conducted to gather
information required for prioritization, stabilization, and abatement activities. The following
information should be considered, especially for larger sites:

  •    Location, including street address, city, county, and global
       positioning system (GPS) coordinates

  •    Owner or operator, including name, address, telephone
       number,  and involvement

  •    Stockpile characteristics such as dimensions, tire sizes,
       age, the presence of rims, possible compaction, existence
       of lacing  (see photo at right) or stacking, the percentage of
       whole tires and shreds, and the presence of other wastes

  •    Site characteristics such as stockpile spacing, soil
       characteristics, topography, access, and drainage channels
       as well as nearby surface water, residences, businesses,
          ,      ,.,..    ,ป T  i     11.          i    Photo courtesy of Todd Marvel, Illinois EPA
       and population densities.  (Nearby schools, airports, and
       other large public facilities should also be identified to help define environmental impacts.)

  •    Site conditions impacting fire control, such as access roadways, water resources, perimeter and
       internal fire lanes, trees, and brush

The information on site characteristics and conditions is useful for site stabilization and fire control
planning for larger sites. An example site characterization form is provided in the Appendix of
this guidebook.  For smaller sites, only the location, owner or operator, and stockpile characteristic
information is needed.

Mapping. Stockpile mapping offers political, technical, and economic benefits. It allows public
officials and citizens to understand the extent of the problem, as it graphically illustrates the broad
distribution of scrap tire sites in the state. From a technical and economic standpoint, mapping
enhances efficiency by supporting coordination of site-related activities such as inspections. In
addition, contractor efficiency can be maximized by addressing several nearby sites under a single
abatement contract if site access can be achieved concurrently.  The combined volume encourages
contractor interest, and the approach decreases mobilization and  demobilization costs. Example
stockpile maps prepared using GIS are shown on the following page.
   Mapping Tip

   Review of site background information, such as aerial photographs, topographic maps, or tax
   maps, before the scrap tire quantity is estimated can reduce the effort needed for field mapping.
   This information is often available in government or other Internet-accessible databases.
Following stockpile identification, the scrap tire quantity is estimated for prioritization, program
planning, budgeting, and contract management purposes. Stockpile estimating is relatively simple
in principle, but can be impacted by many variables.  Many early estimates were performed using
the "gazer" technique. For example, a person would stare at a stockpile and state that it "looked like
                                                                      Section 3: Planning

        Using CIS to Map Stockpile Sites
                                                             U.S. EPA Region 5 initiated a cooperative
                                                             effort to map all the remaining stockpiles
                                                             in several states.  Stockpile sites are being
                                                             identified based on GPS coordinates and other
                                                             site features in cooperation with state and
                                                             local authorities. The information collected
                                                             was entered into a database that was used to
                                                             develop GIS maps with color-coded pile size
                                                             delineations. Such maps have been created
                                                             for Alabama, Connecticut, Indiana, Michigan,
                                                             New York, Ohio, and Pennsylvania.
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Section 3: Planning

about a million tires" when in reality it could have contained between 20,000 and 20 million tires. Some
people still use this technique, resulting in estimates with extremely large margins of error.

Some basic science has been added to the "gazer" technique, resulting in significant improvements in
estimate accuracy. During initial site identification and examination, the dimensions of each stockpile
segment should be measured using one of several techniques, including a long tape, a measuring
wheel, or a calibrated pace. A 100-foot, fiberglass tape requires two people for efficient use and is
preferable for uneven terrain or in cases likely to require court testimony. A large-diameter measuring
wheel can be used on firm, level terrain but is unusable on rough or muddy ground. A calibrated
pace can be used efficiently on most terrain, but its accuracy depends on the ability of the measurer
to maintain a uniform pace. Taking measurements from the midpoint of the pile slope simplifies
subsequent calculations.  In addition, photographs should be taken during field  inspections to
document site conditions, to monitor changes in site conditions between inspections, and to serve as
legal  evidence. An example stockpile characterization form that can be used to collect data is provided
in the Appendix of this guidebook.

Estimating stockpile depth is often    ;
a challenge because the sides are        Estimating Stockpile Depth
sloped and not easily measured.
One technique (see figure at right)       _
is to have a person of known height   ;  fr*
stand as close to the pile as possible   [  L
while an observer stands back and        ^——l^"'"^ 7^™""
measures the pile depth in multiples                ^Q/
of the first person's height. The
observer should be at least 10 times
the estimated pile depth away to minimize angle distortion. A spotter's scope or compact measuring
device can also be used. A large pile should be climbed, and the top of major pile segments should be
walked to observe top contours, pile characteristics, dimensions, and firmness (which reflects density
variations associated with compaction, aging, and lacing).  Tires in stockpiles are irregularly shaped,
flexible, and unstable, so extreme care should be taken when climbing a tire pile.

Stockpiles pose other health risks that should be considered while estimators are on site. Scrap tires
can support breeding of mosquito species that are capable of serving as vectors for potentially fatal
diseases such as eastern equine encephalitis, West Nile virus, and dengue fever.  While estimators are
on site, protective clothing and mosquito spray should be used to minimize exposure. In addition,
stockpiles typically harbor rodents and snakes, so estimators should be observant and move cautiously.

For a  large stockpile, aerial photographs can be used to define its horizontal dimensions, but a scale
must  be established based on nearby objects.  To be effective, aerial photographs must be taken
vertically to avoid dimensional distortion. Depth and density estimation requires ground observation.
Detailed aerial surveys can be conducted, but the ground topography under the  pile must be known or
assumed. Aerial surveys are expensive, and their accuracy is questionable unless a pile is deep enough
to reduce the margin of error associated with surface depth irregularities. Ground surveys have also
been performed with volume-integrating software, but they can be expensive and may not offer greater
accuracy than manual measurements.

As a first step, the stockpile volume is estimated using calculations based on the  dimensions.  In some
cases, irregular shapes can be converted into rectangles,  circles, or other simple geometric shapes to
simplify calculations without impairing accuracy.  In other cases, a single irregularly shaped pile can
be measured as two or more connected rectangular segments with different dimensions. If dimensions
have been measured from the midpoint of the slope, the  volume of a rectangular pile is simply the
product of the length, width, and depth.  Although this method is not geometrically perfect, the
simplification does not significantly impact the total volume estimate.
                                                                      Section 3: Planning

     The volume of other common stockpile shapes can be calculated using the following formulas:

       •    Circle:     icr2d or
                      3.14 x circle radius x circle radius x depth

       •    Triangle:  Va Iwd or
                      l/i x length x width at base x depth (from base to peak of pile)

       •    Trapezoid: ฅ2 1 (w5 + w2) d or
                      Vz length x (width at base + width at top) x depth
     The second step in estimating the tire quantity in a stockpile is determining the pile density, or the
     quantity of scrap tires contained in each cubic yard of the pile. Volume is translated into quantity or
     weight through assignment of a density.  Because most tire stockpiles contain mixtures of various tire
     sizes, density is normally expressed in terms of the passenger tire equivalent (PTE), which is equal
     to 20 pounds by definition.  Most scrap tires have roughly equivalent densities when expressed in
     terms of PTE/cubic yard.  For instance, a medium truck tire weighs approximately 100 pounds (5 PTE)
     and occupies a volume equivalent to four to five passenger tires in a given stockpile. Because most
     abatement activities and other considerations are based on weight,  the equivalency more accurately
     reflects future tire use, processing, and disposal.

     The density of loose, shallow, whole-tire stockpiles is normally about 10 PTE /cubic yard but can
     range from 8 to 27 PTE/cubic yard. Densities below 10 PTE/cubic yard reflect rimmed tires that do not
     collapse but account for only the rubber weight under the assumption that rims will be removed before
     tire transport. Stacking or lacing increases the effective density to 12 to 15 PTE/cubic yard for passenger
     tires, and 13 to 18 PTE/cubic yard for medium truck tires. The highest density range rarely occurs
     but was encountered in a 40-year-old stockpile in a canyon that was over 100 feet deep near Modesto,
     California; the very hot climate caused the tires to be more flexible and easily compacted.  Other factors
     that impact the  density of whole-tire stockpiles are shown in the table on page 15.

     The density of shredded-tire stockpiles can range from 30 to 90 PTE/cubic yard (600 to 1,800 pounds/
     cubic yard). The lower density range represents shallow, uncompacted piles of uniformly large
     particles such as single-pass shreds.  The higher range represents deep stockpiles of finer tire-derived
     fuel (TDF) that has been heavily compacted by repeated movement of heavy equipment during
     stacking. The highest range represents compacted shreds with extensive dirt contamination.  Major
     factors that impact shredded-tire stockpile density are shown in the table on page 15.

     Once the stockpile volume and density have been estimated, the tire quantity (or weight) is calculated
     by multiplying  the volume (cubic yards) by the density (PTE/cubic yard). The result is a tire quantity
     expressed as PTE. The tire quantity can also be expressed as a weight (tons) by dividing by
Section 3: Planning

   Factors Affecting Tire Density
                     Whole Tire Stockpile
            Depth: Increases the compaction of tires in a
            pile and therefore increases density
            Age: Allows additional compaction over time and
            therefore increases density
            Heat: Increases the flexibility of tire rubber,
            thereby increasing compaction and density
                   Shredded Tire Stockpile
           Shred size: Smaller shred size generally
           increases density.
           Wire content: Wire removal decreases density.

           Depth: Depth increases overburden compaction
           and density.
           Equipment movement: Equipment movement
           on ramps or top surfaces during stacking
           significantly increases density as well as the
           probability of auto-ignition within a pile.
100 PTE/ton. A schematic of a simple stockpile site is shown in Exhibit 1 and the quantity calculation
logic is summarized in Exhibit 2.

Although the estimating methodology described above has been successfully applied to hundreds of
scrap tire stockpiles, the following factors may affect its accuracy:

  •     Topography:  The underlying topography
        can significantly affect pile volume and tire
        quantity but may not be apparent from surface
        observations.  Larger tire piles are more difficult
        to estimate because they may conceal ravines or
        pits filled with tires. Piles located on hillsides
        are also difficult to estimate because the hillsides
        may curve or become  steeper beneath the piles.

  •     Nonuniformity: A pile may appear to consist
        of loose tires on the surface, but laced tires  or
        shreds may be present in the pile, significantly
        increasing pile density and tire quantity.            Photo ctmrtesy ol Allan Lassiter/ Virglnia DEQ

  •     Contamination: Piles can be contaminated with water, soil, automobile parts, or other waste
        that may not be visible from the surface.  Water and dirt can significantly increase pile density
        and abatement costs. Also, the presence of whole vehicles or chemical-filled drums can
        complicate tire retrieval, especially if the vehicles are loaded with tires or the drums contain
        hazardous wastes.

With the understanding that resources are limited, stockpile stabilization, abatement, or both should
be initiated following a prioritized sequence based on the comparative hazards posed by various sites
(see Section 1). A prioritization system should reflect current and potential impacts on citizens and the
environment, particularly impacts on sensitive receptors such as schools, hospitals, daycare centers,
and nursing homes.

One prioritization method uses stockpile size as a multiplier because it typically magnifies the impacts
of a tire fire.  The multiplier ranges should reflect the quantities of tires in the piles being prioritized.
For example, the following size factors could be used for stockpiles with the numbers of tires indicated:
       Less than 100,000 tires
       100,000 to 250,000 tires
       250,000 to 1,000,000 tires
       More than 1,000,000 tires
                                                                          Section 3: Planning

                                       Exhibit 1. Example Stockpile Site
                              Exhibit 2. Example Tire Quantity Calculation
          Dimensions (yard)
                                  Volume (CY) or
                                    No. of Tires
No. of Tires
         CY = Cubic yards
         PTE = Passenger tire equivalent
1 Truck (T), passenger (P), off-the-road (OTR), shredded - coarse (SC), or shredded - fine (SF|
2 Loose, stacked, honzontal stacked, or laced
3 Density ranges from 8 to 27 PTE/CY, normally about 10 PTE/CY for loose, shallow, whole-tire stockpiles
4 To calculate weight, use 100 PTE per ton
Section 3: Planning

   Factors to Consider When Evaluating Impacts of Scrap Tire Stockpiles
Impact of fire plume
on residents, businesses,
and regional air quality
 Prevailing wind direction
 Stockpile characteristics
 such as height, trees and
 brush, and fire lanes
 Surrounding land use
 Sensitive receptors such as
 schools, airports, and large
 public facilities (within
 0.5- and 5-mile perimeter)
Impact of contaminants in oil
and residual ash on surface
water or groundwater
 Soil characteristics such
 as permeability
 Aquifer characteristics such
 as water table depth and
 drinking water use
 Site drainage
 Surface water proximity
 Sensitive receptors sue
  as wetlands, fisheries,
 or endangered species
 Stockpile characteristics
Impact of existing stockpile
on area residents
 Population proximity
 Mosquito species
 Identified local/regional
 mosquito-borne diseases
 Rodent/snake infestation
 Stockpile characteristics
The potential impact on the general categories of air, water, and population are evaluated
independently (based on data from the initial site evaluation) using a scale of 1 to 10 with 10 indicating
the greatest potential impact. These three ratings are added and multiplied by the size factor. Factors
to consider when evaluating the impact of a stockpile to air, water, and population density are shown
in the figure above. Stockpile size is an important consideration, but impact is the controlling issue.

Stockpile sites are then prioritized based on the resulting rating totals, with the highest rating
representing the highest priority. Sites generally fall into rating groups with numerical separations
between the groups. Within groups, rating differences are generally small, and the abatement sequence
can be based on site access, contractor availability, markets, or location.  The figure below shows an
example of the prioritization method.

Consistency is an extremely important component of any stockpile prioritization system, so the
smallest possible number of evaluators should be used.  Nevertheless, it can be beneficial to have
two or three evaluators compare their ratings so that subjective inconsistencies can be identified and
corrected.  Ratings generated by a variety of people  can be reviewed by a small, central staff to increase
the consistency of the ratings.
   Example Stockpile Prioritization
    Site  Air Impact  Water Impact  Population Impact   Size    Site Score     Prioritization
Medium Priority
Low Priority
  Stockpile Score = (Air Impact + Water Impact + Population Impact) * Stockpile Size
                                                                          Section 3: Planning

       Coordinating Scrap Tire Abatement with Landfill Remediation in Illinois

       Illinois EPA recently directed an abatement of its largest scrap tire site that was coordinated
       with a nearby state-funded landfill remediation project. The Coultas Recycling site in Danville,
       Illinois, contained about 1 million scrap tires. The inactive H&L landfill about 3 miles away posed
       environmental problems for the City of Danville and was being properly closed and capped by
       the Illinois EPA.  A gas transmission system was required below the impermeable cap to maintain
       its integrity. The stockpiled tires were shredded on the Coultas Recycling site, transported to the
       landfill site, and spread over the top of the landfill (within geotextile encapsulation) to serve as a
       gas transmission medium under the impermeable cap. The shred layer was tapped to allow gas
       removal. One million tires were processed and removed from the stockpile site in 9 months with
       no impact on existing markets and at a lower cost than that of alternatives.
     Some states use independent contractors or consultants to manage or perform stockpile prioritization
     in order to limit political influences. Using a technically sound prioritization process performed by
     unbiased evaluators also improves program effectiveness and efficiency.

     Something has to be done with the scrap tires that are removed from stockpiles. Many states have
     constructively used scrap tires removed during remediation projects in civil engineering or other
     applications. Done properly, stockpile abatement can help to develop new markets or add supply
     volumes to existing markets. Done improperly, it can negatively impact existing markets and
     processors, even driving current-generation tires into stockpiles or landfills. Markets require various
     levels of processing ranging from shredding to metal and fiber removal, thus adding expense.
     Although it is not the preferred option, scrap tires may also be landfilled if their condition is not
     suitable for available markets.                    _^__^__^^_^^__^_^^_^__^^_^^^_^^_
                                                                          - - ^ JT-
Stockpiled tires are often contaminated with
water, dirt, or other foreign materials that limit
potential markets and increase processing costs.
Some cement kilns that use whole tires and that
can accept limited water and dirt contamination
represent a market, but kiln capacity and
fuel weighing can be negatively impacted by
substantial contamination.

Because contamination can damage processing
equipment and increase maintenance expenses,
contractors try to minimize damage by producing
large tire shreds (for example, 4 inches or larger
without steel belts removed) for civil engineering applications. Examples include large highway
embankment or lightweight fill projects that can consume 500,000 to 1,500,000 tires per project.  In use
of tire shreds for aggregate replacement during landfill construction, a range of tire shred sizes may
be used, depending on the construction details of the liner and drainage system.  Examples of landfill
applications include use of tire shreds for daily cover, leachate collection layers, surface water drainage
layers, and gas collection channels.  Large chips with minimal processing requirements minimize
abatement costs if they are technically acceptable.

Proper retrieval of tires from uncontaminated stockpiles can yield clean tires that can be processed
into TDF or drain field products. In some cases, contractors choose to accept higher equipment
maintenance costs and downtime to process dirty tires under abatement contracts.  However, most
crumb rubber producers generally do not accept abatement tires because of their impact on equipment
and product quality.
Section 3: Planning

Some legislative or regulatory measures
require that all abatement tires be
constructively used. Such a requirement can
have the following impacts:

  •    Damage of processing equipment:
       Processing heavily contaminated
       or partially burned tires can cause
       equipment problems that delay
       stockpile abatement.

  •    Market distortion: Driving abatement
       tires to existing markets can displace
       products made from current-
       generation tires.  This displacement
       can create  market instability, cause
       processor attrition, and force current-
       generation tires into landfills or stockpiles.

Creating new markets for abatement tires or rewarding contractors for creation of such markets is a
critical component of an effective scrap tire program. Examples might include working with the state
Department of Transportation (DOT), landfill owners and operators, and state agencies conducting
landfill closures to identify scrap tire projects.  Creating and specifying a new market can decrease
abatement costs. At a minimum, the maximum percentage of existing markets displaced by abatement
activities should be controlled even if it means extending cleanup schedules or allowing product
storage under  monitored conditions.
Photo courtesy of Todd Thalhamer, California IWMB
Scrap tire stockpiles are generally located
on property that is owned and controlled
by one or more individuals. Before a scrap
tire remediation project begins, it is essential
to obtain either a written property access
agreement from the landowner or  a court
order granting property access for the purpose
of tire removal. At many  sites, a property
boundary survey is also necessary to ensure
that remediation work does not inadvertently
extend over onto adjacent properties. If
additional properties are involved, additional
property access agreements or court orders
will be needed.
Photo courtesy of Gavin Adams, Alabama DEM
The following issues should be considered in dealing with properties :

  •    Utilization: A property can contain buildings, other structures, and utilities that would be
       useful to a contractor during on-site activities. If any of these items are to be used, a written
       agreement establishing the usage conditions, obligations, and compensation can prevent
       subsequent misunderstandings.

  •    Damage: States have been sued for damage done by contractors acting as their agents. In
       some cases, the damage has  been done by others prior to initiation of cleanup activities. As
       a preventive measure, complete and dated sets of photographs before, during, and after site
       abatement is useful for documenting site conditions.
                                                                      Section 3: Planning

       •    Restoration: Water in tires and rain create muddy conditions in unstable soil under a stockpile.
           Heavy equipment can create deep ruts, and water runoff can erode surface soil. After tire
           retrieval, contractors are generally required to level heavily rutted land. In most cases, re-
           establishing vegetation will control erosion.

     Recognizing a property's value while obtaining and maintaining the landowner's cooperation facilitates
     abatement operations. If the property owner will not cooperate, a court order must be obtained to
     enter the property and remove  the scrap tires.  State legislation can aid this process if laws are passed to
     create an administrative process for ordering scrap tire cleanups. One example is Ohio Revised Code
     3734.85, which can be found at  http://www.ohio.gov/government.htm.
     Stockpile abatement involves many groups, including contractors, local governments, politicians, and
     the press. Informing and coordinating these groups are critical components of successful scrap tire
     programs and abatement projects.

     Contractors.  Any special abatement project requirements should be clearly defined in detailed plans
     and specifications provided to prospective contractors prior to the bidding process. Examples of items
     that should be addressed in such plans include the following:
            Site description

            Tire quantity estimate

            Tire pile length, width, and height

            Operating procedures




            Fire lanes
Pile removal sequence

Stabilized access and perimeter roadways

Control of vegetation, mosquitoes, and

Water source and distribution

Fire plan


Progress reporting
     Many contractors have developed their own abatement methods to optimize the efficiency of cleanup
     operations based on years of experience. Experienced contractors should be invited to suggest
     alternative approaches. An initial description of the project should be developed to provide a sound
     foundation for project communications and to minimize the need for discussion of pre-planned
     activities. Example pre-bid documents
     prepared by the States of Iowa and Illinois
     are available at http://www.epa.gov/reg5rcra/

     Elected Officials. Local and state elected
     officials are instrumental in creating and
     maintaining abatement programs. Providing
     updates on program implementation
     and abatement projects is important.
     Digital photographs, videotapes, or aerial
     photographs of sites before, during,  and after
     abatement can be sent to state legislators
     in the district to maintain communications
                                                 Photo courtesy of Bob Large, Ohio EPA
Section 3: Planning

and build support. Inviting elected officials to see stockpile sites before and after cleanup also creates a
good public relations opportunity.

Local Governments. Local administrators and police and fire departments can provide critical support
services at little or no cost if they are included in project communications.  Informing these groups
about project plans and associated benefits to the community enhances cooperation. Discussing
security and fire control measures with local departments before the project starts increases the
probability of a successful response if needed. A contact list that includes emergency response contacts
and procedures should be provided to all project participants.

Press. Publicity allows citizens to understand an abatement program and  the value received for
public fees. In addition, publicity allows politicians and program participants to be recognized for
accomplishing removal objectives. However, drawing attention to stockpile abatement projects can
have undesired effects. Many fires are actually started by site operators or local residents in the wake
of publicity over cleanup activities. One of the largest tire fires in Canada, which involved an estimated
10 million tires, was started by teenagers attracted to the site by local publicity. One approach is to
issue a press release highlighting the last scrap tire being thrown onto a truck by a local community
leader; the release can include site photographs taken before and during abatement.
                                                                       Section 3: Planning

    SECTION  4
The success of a scrap tire abatement program hinges
on selecting contractors that are capable of performing
required tasks cost-effectively in accordance with
procedures and schedules. In many early abatement
efforts, processors were developing field operating
experience, equipment was evolving, maintenance
requirements were being denned, limited capital
prevented use of efficient tire retrieval equipment,
and few product markets existed. These factors
contributed to project delays and failures. Although
abatement activities still pose substantial challenges,
the cumulative benefit of past experience, equipment
improvements, appropriate retrieval equipment, and      Photo courtesy of
substantial market development has greatly enhanced the probability of success. One key to success is
selection of contractors with good performance records and the ability to perform at a reasonable cost.
This section defines critical factors and alternatives for successful evaluation and selection of stockpile
abatement contractors.
                                                                     , iowa DNR
     The amount of information requested from contractors during the evaluation process varies widely.
     Some agencies request comprehensive data, while others simply request contact and pricing
     information. The optimum amount of required information depends on specific site characteristics
     such as stockpile size and project complexity as well as the agency's experience with contractors. The
     primary factors that have been used to evaluate contractors are discussed below.

     Company History. Some contractors and processors have changed their names frequently, especially
     after failed projects. Requiring a contractor to identify all of its previous names and affiliated
     companies and to provide organizational charts can help the agency understand the contractor's
     history. Also, identification of subcontractors, their roles, and the anticipated revenue apportionment
     allows the agency to evaluate the contractor's ability to execute assigned responsibilities.

     Company Financial Capabilities. Financial strength increases the probability that a contractor will
     have appropriate equipment and will be able to overcome unexpected problems. To identify the
     financial strength of contractors, some states request 2 or 3 years of financial data. Some privately held
     companies are reluctant to provide this data unless confidentiality can be maintained. An alternative
     is to require a contractor to document its ability to provide a bond or other financial assurance for an
     amount equal to the maximum required for the proposed abatement activities. This approach protects
     the agency's financial interests and avoids confidentiality concerns.

     Experience. Positive project completion experience increases the probability of future success, so it
     is critical for a contractor to document its experience on comparable  projects. Experience on small
     projects does not necessarily relate to larger projects, but it can provide a foundation if the small
     project's equipment and  removal rates were comparable to the requirements for a larger site. A
     contractor should describe its previous work in detail and should submit customer contact information
     to allow verification of performance claims.

     Equipment. Stockpile abatement involves tire retrieval, transport, and processing.  Requiring a
     contractor to list and describe the major equipment to be used facilitates the evaluation.  Retrieval
Section 4: Contractors

Photo courtesy of Mel Pins, Iowa DNR
equipment generally includes an excavator for larger sites, a front-end loader with a specially equipped
bucket system for medium-sized sites, and a tracked bobcat with an appropriate bucket for smaller
sites. Additional specialized equipment may be required for sites with unusual topography.

Transport equipment typically consists of standard 18-wheel tractors and trailers. High-volume
trailers enhance efficiency if long-distance transport of whole tires is required.  Some contractors use
subcontractors to haul tires; information on the subcontractors, such as their licensing or relevant
qualifications, should be required during the bidding process.

Tire processing can be performed on site or at a centralized processing facility.  On-site processing
is generally less efficient because of unstable ground conditions, material handling considerations,
volume inconsistency, and equipment maintenance challenges. On-site processing is most suitable for
large sites that are distant from centralized processing facilities and product markets.

Processing equipment requirements depend on product
and market specifications. A smaller product size
specification normally requires multiple size reduction
units in series or extensive recycling within a single
unit (with a proportional decrease in effective capacity).
The impact of dirt, rocks, and other contamination is
generally proportional to the processing requirements.
Large tire chips for highway embankment applications
require less processing, but soil contamination must
be removed.  Nominal 1-inch-diameter TDF has been
produced at stockpile sites, but dirt contamination
significantly increases equipment maintenance
requirements and associated downtime. It is generally
not practical to produce crumb rubber from stockpiled tires unless they are unusually clean and are
carefully retrieved.

Products and Markets. A contractor should be required to identify specific markets and the percentage
of displacement expected to be incurred from stockpiled tires.  In general, this percentage should not
exceed 15 to 25 percent of the current-generation tires. In addition, the contractor should identify
product specifications and an existing contractual basis with a  product customer. Lack of a contractual
basis increases market vulnerability and the probability of displacing products made from current-
generation tires. The proposed processing equipment must be capable of generating products that
meet the specifications.

Wastes. In some cases, contractors have received premium payments associated with product
recycling while actually recovering a very small percentage of tires as usable product. Substantial
volumes of tires have been discarded or landfilled without the  prior knowledge of the contracting
agency.  For this reason, a contractor should identify  projected  waste volumes and disposal methods
so that the contracting agency can consider recovery  percentages in its evaluation. On the other hand,
the contracting agency should not preclude landfill disposal of heavily contaminated tires or  shreds.
Attempts to recover tire material can be counterproductive by unnecessarily increasing (1) handling
requirements and (2) equipment maintenance and downtime.  Such attempts can thus be detrimental to
completing rapid, efficient, and cost-effective site abatement.

Personnel. A contractor should identify specific management personnel and their prior experience,
including the on-site personnel who will be responsible for daily operations and equipment
maintenance.  On-site operations require personnel who are capable of making sound decisions when
faced with unexpected events at remote locations. In addition, the contractor should identify qualified
support personnel who are available to assist if needed.

Availability.  Many contractors have limited equipment and may be involved with multiple sites prior
to a new contract award.  For this reason, a contractor should identify its anticipated mobilization
time requirement and proposed start date; alternatively, an early start date can be established to reveal
                Section 4: Contractors

     whether a contractor can perform according to the schedule.  It is also critical to identify the net
     removal rate that the contractor can sustain for the duration of the project so that the total amount of
     time needed to clean up the site can be estimated.

     Past Performance. A contractor should identify all comparable projects completed within the last 2 to 3
     years. In addition, the contractor should provide a detailed description of its previous project activities,
     identify any failures to comply with contract conditions, and provide customer contact information for
     each project so that the contracting agency can verify the contractor's performance.

     Cost. The contracting agency can require a
     contractor to submit a bid based on a fixed price
     to perform the total site abatement. In general,
     contractors build a substantial safety factor into
     fixed-price bids, increasing the cost per ton of
     material to be removed. Most current abatement
     activities are performed on a cost-per-ton basis to
     enhance cost-effectiveness. The risk associated
     with this approach involves additional costs
     associated with contamination such as soil or
     automotive parts. To control abuse, retrieval and
     loading operations should be closely monitored,
     and the contracting agency should reserve the
     right to adjust weights in order to control excess
     contamination. In a cost-per-ton contract, the total
     contract price is based on the estimated quantity
     of tires. To avoid change orders, associated work
     stoppages, and additional costs, it is important to
     obtain an accurate estimate up front. However, in
     the event that an accurate estimate is not possible,
     the contract can include costs based on a range of
     tonnages to reduce the need for change orders.
                                                     Photo courtesy of Brian Wright, Georgia DNR
     States have used a wide range of approaches in the contractor bidding and award process. One major
     variable has been the amount of information requested in request for proposal (RFP) documents.
     In some cases, only a fixed price was requested, and the project was awarded solely on this basis.
     One state used this approach during initial site abatement activities, and the contractors selected
     were inexperienced, were underfinanced, and offered low bids based on a misunderstanding of the
     abatement requirements. The result was a consistent pattern of failures to maintain schedules and
     complete projects.

     An alternative RFP approach for major stockpile sites is to require contractors to provide detailed
     responses to the criteria cited in the previous subsection in order to increase the factual basis for
     evaluation. Less information may be requested for smaller sites or when the contracting agency
     already has a thorough understanding of a contractor's capabilities based on previous experience.
     When detailed responses are requested, a weighted evaluation should be completed to reflect the
     importance of each criterion.  These weights should be included in the RFP. A minimum of three
     experienced individuals should evaluate and score proposals, with the total scores controlling
     contractor selection. When the scores for a given proposal differ significantly, the scores should be
     reviewed for errors or misunderstandings, and obvious errors should be  corrected prior to final
     contractor selection.

     Conducting a detailed RFP process for each site can be cumbersome and  time-consuming for all parties,
     especially if multiple sites are to be abated.  An alternative is to pre-qualify potential contractors
     through  a modified RFP or a request for qualifications (RFQ) process. In such a process, contractors
Section 4: Contractors

submit detailed qualifications once, and the top three to six contractors are selected and pre-qualified
for a 3- to 4-year period. As projects arise, the pre-qualified contractors are invited to submit cost
proposals identifying only costs, schedules, and any significant changes in capabilities and procedures
since the original RFQ response. The contractor selection is then made based primarily on cost.
Under this approach, the bidding process for a site is simple and quick, and qualified contractors are
consistently used.

The Florida Department of Environmental Protection has used a pre-qualification process successfully
since 1989.  The process is repeated every 3 to 4 years in order to allow for changes in industry
participants. Illinois conducts a similar pre-qualification process in which contractor responses
include binding cost data presented on a price per ton basis. When a site is identified for abatement,
a contractor is selected based on the site's proximity to the contractor's processing facility.  The lack of
individual  site bidding does not result in significantly higher abatement costs. Illinois has used its pre-
qualification process for over 10 years to handle a high volume of cleanup projects.

The form of an abatement contract depends on the bidding and award procedures used as well as state
contracting requirements. Such contracts generally fall into two main categories:

  •    Individual site contracts created solely to cover specified abatement activities associated with an
       individual or conjoined stockpile. These contracts typically cover awards made based on single-
       site RFP responses.

  •    Task assignment contracts created to cover general conditions associated with stockpile
       abatement activities. Such contracts are supplemented by task  assignment documents covering
       specific site conditions as awards are made.  This type of contract is generally used in cases
       where contractor pre-qualification is conducted. A general task assignment contract is executed
       with each pre-qualified contractor, and then task assignments are issued for individual sites as
       appropriate.  This process requires broader initial contracting work but expedites individual site
       assignments and the resulting abatement.

Each state has its own contracting procedures and language requirements,  so it is not possible to
provide a 'model' contract. However, example basic contract documents are available at http://www.

The primary purpose of bonding and insurance requirements is to protect the contracting agency from
financial loss as a result of contractor error or failure to perform.  A secondary purpose is to ensure that
a contractor has adequate resources and is committed to successful project completion.

Historically, contracting agencies have required bonding or other financial assurance equivalent to
50 to 100 percent of a project's estimated cost. In addition, a bond typically remains in force until
the contracting agency confirms final project completion and releases the bond. When bonds were
relatively easy and inexpensive to obtain, the  bonding requirement was not normally a hardship except
for companies with poor operating statements or balance sheets.

Recently, however,  it has become more difficult and expensive for smaller companies (including many
successful contractors) to obtain bonds. Some companies have resorted to alternative methods such
as letters of credit or cash deposits.  In some cases, large financial assurance requirements can be
burdensome for contractors, as they tie up working capital resources needed to execute contracts. In
other cases, such requirements may exclude successful contractors from competing. Iowa and Virginia
have no financial assurance requirements and have not experienced any contractor failures, but these
states have  a long history of successful contractor  performance.  Florida recently decreased its bonding
requirements from 100 percent to 50 percent of contract awards. The cost of bonds is ultimately paid
by the contracting agency, as the cost is factored into bid prices.
                                                                      Section 4: Contractors

     It is a challenge to balance actual financial assurance needs against the burden placed on prospective
     contractors.  The actual contracting agency loss incurred because of contractor failure is normally the
     expense of repeating the bidding and award process plus the difference between old and new costs. A
     financial assurance requirement of 10 to 25 percent provides adequate loss protection without placing
     an undue burden on a contractor. The lower requirement is appropriate for mature programs with
     proven contractors, and the higher requirement is appropriate for new programs with no contractor
     performance history.

     Insurance requirements typically consist of
     comprehensive general liability insurance to protect
     the contracting agency in the event of contractor error,
     worker injury, or site damage. Most states require a
     minimum of $1 million of coverage, which does not
     normally present a hardship for contractors.

     The tire processing industry and product markets have
     a finite capacity to process and use current-generation
     tires and tires from stockpile abatement. Abatement
     objectives should be determined in the context of local
     and regional capacity to avoid disrupting the market.
Photo courtesy of Jana White, South Carolina DHEC
     If economic imbalances are identified, corrective measures can be initiated. For instance, if the capacity
     of local or regional processors is limited, they can be made aware of anticipated tire volumes and may
     choose to increase their capacity.  If not, mobile processors that may not be operating at capacity can
     be solicited from a broader geographic area. If markets are limited, others can be created through
     agency cooperation or incentives. For example, the New York State DOT considers use of tire chips
     from stockpile abatement for embankment projects if the chips have a lower delivered cost than other
     aggregate alternatives.  If economic imbalances are not correctable, program objectives should be
     adjusted to reflect realistic tire volumes or to allow tire disposal in order to avoid market disruption.

     On a smaller scale, assessing a contractor's processing and marketing capability to absorb stockpiled
     tires without disrupting use of current-generation tires can be a reality check on contractor projections.
     Identification of processing capacity should be based on the historically demonstrated performance of
     similar equipment, not on equipment supplier claims.
Section 4: Contractors

Project  Management
The preceding sections provide the foundation and considerations for establishing a successful
scrap tire abatement program. However, once abatement projects are underway, a whole new set of
issues must be considered. This section discusses factors that will enhance project management and

Prior to site mobilization, a review or survey of the property boundaries should be completed to verify
that all tires and planned access routes are located on that property. Often tire piles extend across
property lines. In such cases, written property access agreements with neighboring property owners
will be needed.
Proper equipment selection depends on site conditions, and unique site conditions may require
specialized equipment or safety procedures. For instance, a tracked excavator is an efficient, high-
volume tire retrieval tool if the following conditions exist:

  •   Open-top trailers can be moved adjacent to the stockpile for direct loading, minimizing
      excavator movement.  If the ground is too unstable for truck access, a loader can cover longer
      tire transport distances more efficiently.

  •   Boom movement is not impaired by large trees or other obstacles such as power lines. Where
      obstacles prevent free boom movement from pile to trailer, a loader may be safer.

  •   The stockpile is deep, but the top is reachable. An excavator minimizes the risk of pile collapse
      onto equipment and operators, making it the safest alternative for deep piles.

  •   Contaminating metal objects are large enough to be seen and separated prior to loading. Cars
      and other large objects can be separated, but rims and smaller objects may be inadvertently

  •   The bucket is closed above ground level to minimize soil entrapment. If the bucket is dropped
      to ground level before it closes, it will trap soil and debris.
Photo courtesy of Jim Waldron, Tn-Rmse, Inc
                                                               Section 5: Project Management 27

       Scrap Tire Removal Under Unique Site Conditions in Ohio

       During 2004, over 1 million tires were removed from a strip mine site in Ohio. The tires covered
       the high wall and were submerged and compacted in the 19-foot-deep strip pit. Also in Ohio,
       buried tires and tire fire residuals were removed from a site where a major fire involving 400,000
       scrap tires had occurred. EPA emergency response contractors had extinguished the fire at this site
       by bulldozing approximately 3 feet of clay over the burning tires to form a temporary cap. The
       removal contractor had to implement procedures to minimize further soil contamination as the fire
       residuals were removed.
     In some cases, smaller equipment such as a loader or tracked bobcat can be more efficient and
     inexpensive than an excavator. For instance, an excavator loses many of its advantages if tires are
     simply being staged for loading into enclosed trailers.  A bobcat can easily place tires in the end of a
     trailer.  Most experienced contractors understand efficient use of equipment and manpower.

     Changing site conditions can alter equipment needs during a project, and contractors need latitude
     to make adjustments provided that the schedule and safety are not compromised and no increased
     contamination or site damage results. If any of these problems occur, the contracting agency should
     increase its monitoring and guidance efforts until the problems are resolved.

     In addition to normal retrieval and  hauling equipment, on-site utilities such as portable sanitary
     facilities may be required.  Electricity, telephone, and water service and an enclosed work area may also
     be desirable at sites during extended operations or inclement weather conditions.
     Registration and Permitting. Many states require processor and hauler registration. All necessary
     registrations and permits should be obtained ahead of time to avoid unnecessary delays. Contractors
     have been cited for transportation violations by the same agency that contracted with them for removal

     Weighing. Load weight can change during transport. Trapped water can drain during tire movement,
     or rain can add weight if water is trapped in exposed tire casings. In other cases, tires may be added
     to trailers in transit. If possible, trailers should be weighed at a pre-approved scale near the abatement
     site and again at the receiving site. The lesser of the two weights should be used for invoicing. Florida
     has used this approach for all sites with little inconvenience to contractors. Ohio requires submittal of
     computerized weight scale receipts providing the loaded truck weight and the empty truck weight for
     each load taken to an approved facility.

     Rims. Rims can double the transport weight
     of passenger tires. Removing rims prior to
     transport will reduce transport and processing
     charges based on weight. If rim removal is
     not feasible, a tracking and weight adjustment
     method should be established, especially for
     sites such as salvage yards that have high
     percentages of rimmed tires.  When tires are
     de-rimmed, both the scrap metal rims and the
     tire-balancing lead weights removed provide a
     source of revenue. The contract terms should
     clearly state whether  the contractor retains this
     revenue, shares the revenue with the agency,
     or submits all the revenue to the agency. The
                                                  Photo courtesy of Ethan Mayeu, Mississippi DEQ
Section 5: Project Management 28

contractor incurs additional expenses in removing and processing the rims from tires, so the contractor
should be reimbursed in some manner.

Rail Transport. Transportation of shredded tires in bottom-dump railcars can be problematic because
of chip compaction and rainwater freezing.  The chips become difficult to dump at the receiving site.
Side-dump and arm-dump railcars generally do not have this problem.  However, rain- and snow-
frozen TDF sent by rail from a southern abatement site to a northern utility prevented dumping and
forced loaded railcars to be staged until the spring thaw.

Monitoring Logs.  Good records of tare and loaded weights must be kept for all vehicles and unit
numbers must be noted on weigh slips to avoid discrepancies that can delay invoice payments.

Water. Water can create serious problems at a stockpile site.  Storm water can accumulate in low spots,
impeding equipment movement and operating efficiency.  In addition, stockpiled tires spill trapped
water during retrieval and handling, creating unstable soil at the site. These problems can be resolved
by creating drainage channels or constructing elevated paths for equipment.  Another alternative is to
rotate work areas in order to allow wet, unstable areas to dry. As unstable ground is exposed under
piles, silty runoff can drain from the property to adjacent streams, ponds, and properties. Where such
runoff occurs, silt fences commonly used at construction sites must be constructed. As a mosquito
control practice, Ohio requires that ruts and holes be filled with soil or drained so that standing water
does not remain for longer than 7 days after a rainfall; otherwise, the contractor must sample the area
and treat it with a mosquito larvicide.

Roadways. Heavy truck movement can destroy dirt roadways at sites during wet or thaw periods. If
such roadways are used by area residents, the road surface must be kept passable for normal vehicles.

Dust.  During dry conditions, equipment movement on unstable soil and roadways can generate dust
plumes. If airborne dust impacts abatement operations, on-site personnel, or adjacent properties, water
spraying can be used for dust control.

Noise. Tractor-trailers, heavy retrieval equipment, and on-site shredders are noisy. In populated areas,
abatement operations can be limited to daylight hours in order to control noise impacts on nearby
residents. Local residents are normally grateful for stockpile removal and tolerant of temporary noise
and inconvenience.
The primary objectives of site security are to prevent addition of tires to a site, prevent fires, and
protect equipment. The security measures discussed below have been effective in accomplishing these

Vehicle Access Control. The most common
approach for vehicle access control is a locked chain
extending between secure posts. The chain can be
removed for inspection or abatement activities, and
most emergency response vehicles carry lock cutters
in the event that they require access to a secured
location. A cut lock or broken chain would indicate
the need for other measures.  Ditches and earthen
berms have also been used to control vehicle access,
especially if they enhance drainage or runoff control.

Fencing. Preventing all vehicle and pedestrian
access to a site is difficult, but casual access can be
controlled by fencing.  Chain-link fencing and gates   Photo courtesy of Jana Whlte, South Carolma DHEC
                                                                      Section 5: Project Management 29

     may already be present at industrial sites. In some cases, a fence along a visible front boundary is
     enough to discourage intruders. However, a rural site often has multiple entrance points, so the entire
     perimeter should be checked for signs of unauthorized activity. A fence is most cost-effective in urban
     areas where nighttime equipment protection is critical. Fences can be rented or purchased depending
     on the duration of site operations.

     Lighting. Lighting increases the probability of observing intruders but is only effective when
     combined with security guards. Otherwise, lighting just attracts attention and facilitates vehicle access
     to the site.

     Security  Guards. Security guards can control site access and provide an early warning in the event
     that a fire occurs. To be effective, guards must have adequate lighting arid must patrol the site in spite
     of mosquitoes and adverse weather conditions. Punch clocks are commonly used to ensure adequate
     guard coverage.  An electric cart can be used to increase the patrol range on larger sites while allowing
     quiet movement. Guards have a broad range of training and capabilities. Guards with little training
     can be acceptable in low-risk cases provided that they are well prepared for actual emergencies
     by being  given detailed instructions and communications equipment.  In other cases, trained law
     enforcement officers are appropriate. In one high-risk case in Florida involving a landowner with
     multiple  felony convictions, sheriff deputies served as security guards arid arrested three people with
     outstanding felony warrants who were visiting the landowner during the first two weeks of operation.

     Additional Measures. Guard dogs can deter intruders at fenced sites, but dogs raise liability issues
     and can be injured by loose wire at processing sites. Motion detectors have been considered for
     sites, but animal movement in rural areas triggers false alarms. Cameras have been used at sites
     but generally fail to provide adequate picture quality to support the capture or arrest of an intruder.
     Smoke detectors and heat sensors have been considered for fire detection, but the associated expenses
     and logistics are problematic for abatement sites.

     Even the best security measures serve only as deterrents and will not necessarily stop a determined
     arsonist,  saboteur, or thief. Security guards were  patrolling a Hagersville, Ontario, site when its 10
     million tires were ignited by teenagers.  Equipment was sabotaged at an inner-city site in Florida in
     spite of fencing, lighting, and security guards. A security guard started a fire at a Texas processing site
     to ensure continued employment. Fires have been started by objects thrown over fences. However,
     there is no way to know how many mishaps have been prevented by appropriate security and site
     The use of heavy equipment and shredders at an abatement site poses risks for on-site personnel.
     These risks are similar to those encountered at processing facilities but are increased by the less
     structured equipment paths, outdoor conditions, and uneven or unstable terrain at a site.  Ohio requires
     abatement contractors to prepare and implement site-specific health and safety, emergency response,
     and fire prevention and response plans for
     state-funded abatement projects. One specific
     requirement is to have at least one contractor
     employee with a current American Red Cross
     or equivalent certificate of CPR and first
     aid training at the site during all operating
     hours. Additional safety considerations are
     discussed below.

     Mosquitoes. Container-breeding mosquitoes
     thrive in the warm, protected, stagnant water
     contained in tires.  In addition to being a
     nuisance, these insects serve as vectors for
     potentially fatal diseases in humans, such as
     1        J                                    Photo courtesy o( James Gathany, CDC
Section 5: Project Management 30

West Nile virus, eastern equine encephalitis, and dengue fever.  Measures should be taken to control
on-site worker exposure to mosquitoes, especially during active breeding seasons in areas prone
to these diseases.  Exposure control measures include (1) wearing long-sleeved shirts and pants to
minimize exposed skin, (2) using insect repellent, and (3) spraying sites to control adult and larvae
populations. At most scrap tire remediation sites during warm weather months, Ohio often takes
an additional step to prevent the spread of West Nile virus and  other mosquito-borne diseases. The
state requires contractors or licensed application firms to conduct thermofogging and apply granular
insecticides in order to prevent mosquito larvae in the tires from being transported to other sites. Tires
removed from cleanup sites should be processed immediately and not stored whole at another site to
minimize spreading of mosquitoes because of the presence of mosquito eggs or larvae in the tires.

Snakes and Other Wildlife. Tire stockpiles host snakes
and small mammals such as rats, opossum, skunks, and
raccoons. Although they generally flee when heavy
equipment disturbs a pile, they continue to pose a risk
to site workers and nearby residents. Some measures
that have been used to address this risk include
(1) installing screened cages on retrieval equipment
to protect operators from snakes dropping from tires
during retrieval; (2) requiring workers to wear heavy
gloves, long sleeves, pants, and boots to protect against
animal bites and scratches; (3) identifying the nearest
emergency medical facilities capable of treating bites      Photo courtesy of u s Fish and Wlld"fe Semce
and other injuries; and (4) installing  silt fences to divert escaping snakes from adjacent populated areas,
especially those containing children. The risk posed by snakes does not stop at the site.  One contractor
claims that over 50 snakes escaped from tires in trailers that were mechanically loaded at a Florida site
and transported to a processing facility.

The greatest risk associated with scrap tire stockpiles is their possible ignition.  Once ignited, stockpile
fires tend to spread rapidly, generating massive quantities of smoke, oil, and contaminated water that
cause environmental damage.  Factors associated with stockpile fire planning and prevention are
discussed below.

Owner or Operator Role.  Many stockpile fires involving arson start during enforcement proceedings
or initial abatement activities, indicating that the landowner may be seeking revenge or attempting to
avoid cost recovery associated with abatement. Unfortunately, the remediation costs and repercussions
after a fire far outweigh the abatement costs. As a general rule, it is five to ten times more expensive
to remediate a fire site than to simply remove the tires. In addition, large tire fires typically involve
federal emergency response agencies, thereby adding investigation and legal expenditures to cost
recovery efforts.  Enforcement officials should clearly communicate the personal benefits of fire
prevention to the site owner or operator.

Emergency Response Plan.  An emergency response plan should be developed for a large stockpile
site to support coordinated notification and response in the event of a tire fire. Each responding agency
should have a clear understanding of the resources available and the plan for their optimum use.
Each local fire department typically has an outline of specific subjects that should be addressed in an
emergency response plan.

Initial Site Stabilization.  Large stockpile  sites should be stabilized to decrease the possibility of a
tire fire and to increase the odds of controlling a fire. Stabilization can be initiated by a site owner as
part of a compliance agreement or by a contractor during initial abatement activities. Important site
stabilization activities include the following:
                                                                      Section 5: Project Management 31

       •     Removal of trees, brush, and grass around stockpiles to avoid fire transmission to and from
            surrounding areas, especially if the site is inactive

       •     Identification of available fire control resources and installation of supplemental fire control

       •     Creation of at least two connected access points for emergency vehicles

       •     Creation of fire lanes that are at least 50 feet wide to divide a large stockpile into isolated
            segments.  The initial lane should roughly bisect the pile, and subsequent lanes should result in
            pile segments that are no larger than 50 by 200 feet in size.  Pile sides should be tapered to avoid
            collapse during fire turbulence.

       •     Stabilization of central fire lanes to facilitate emergency response vehicle access and to
            maximize contractor efficiency during subsequent abatement activities

     Site Abatement.  During site  abatement, alternate pile segments should be sequentially removed to
     increase the separation between remaining segments. In some cases, piles near roadways or fences are
     removed early in the abatement to prevent tire ignition by thrown objects as well as to show abatement

     Shred Auto-Ignition.  Deep stockpiles of compacted
     tire shreds can undergo a progressive series of
     exothermic reactions that increase pile temperatures
     and pyrolytically generate combustible gases.  Surface
     symptoms of this phenomenon can be subtle, such as a
     slight sulfur odor, vapor steaming from isolated sections
     of the pile surface, or a slight oil sheen on adjacent
     standing water after rainfall. Auto-ignition normally
     occurs  in stockpiles that are more than 10 feet deep
     and that have been compacted by movement of heavy
     equipment during their formation. The phenomenon
     has occurred in shreds of all sizes but is more common in
     smaller shred sizes.
Photo courtesy of Todd Thalhamer, California IWMB
     The potential consequence of auto-ignition is that surface fires can ignite on a shred stockpile,
     especially as the pile is abated. As shreds are removed from the area near the hot zone, gases and
     shreds are exposed to air and ignite. The fire then spreads across the pile as though it was started on
     the surface. This has happened in more than 20 stockpiles and monofills.  A sign of this phenomenon
     is an area of melted rubber shaped like a mushroom cap within the pile. Care should be taken during
     abatement of deep, compacted shred piles, and steps should be taken to immediately control auto-
     ignited shred fires before they can spread.

     The Rubber Manufacturers Association offers "Guidelines for the Prevention and Management of Scrap
     Tire Fires" (available at http://www.rma.org), which provides a foundation for fire prevention and
     management at stockpile sites. The California Integrated Waste Management Board has also prepared
     a document titled "Tire Pile Fires: Prevention, Response, Remediation" that is available at http://osfm.
     fire.ca.gov/pdf/regulations/TPFReportFinal.pdf.   Some of the document is specific to California
     conditions and does not necessarily have universal applicability.

     Successful abatement of a stockpile site depends on good communication  between the contractor
     and contracting agency.  Both efficiency and mutual respect are acquired from experience, which is
     critical to successful tire abatement projects and programs. On-site monitoring and invoicing are also
     important elements of communication, as discussed below.
Section 5: Project Management 32

Contractor and Agency Communication.  Abatement plans and schedules are working documents that
are subject to change based on factors such as weather, equipment breakdowns, and market conditions.
Good communication between the contractor and contracting agency provides a foundation for
appropriate adjustments. The contractor can provide a weekly, biweekly, or monthly written progress
report describing tire quantities removed, adherence to the schedule, obstacles, adjustments, and
anticipated future activities; progress reports may also be made verbally at the agency's discretion.
The contractor should also report all unexpected site conditions to the agency as they are discovered,
particularly conditions such as the presence of (1) items other than tires in the piles and (2) pits and
ravines under piles that will increase the total PTE at the  site. These previously unknown conditions
need to be documented with photographs  that can serve  as a basis for possible contract changes and
cost recovery actions. In addition, contractor and agency personnel should be readily accessible for
quick resolution of on-site issues as they arise.

On-Site Monitoring. Performance monitoring is a balance of economics, need, availability, and
experience. States have used full-time monitors, facilitated daily visits by local officials, reviewed logs
kept by security or contractor personnel, and conducted unannounced site visits and record audits.
Minimum monitoring generally involves daily telephone discussions, two to five site visits per week by
local agency or law enforcement personnel, and periodic unannounced site visits.

Invoices. The contractor should submit monthly invoices with all supporting documentation. This
procedure allows problems to be identified early and limits the magnitude of invoice preparation and
review time. Delayed invoicing can increase review time and delay invoice payment.

Abatement Completion.  The issue of abatement completion is subject to interpretation when tires are
buried on a site. In general, large pockets of  tires are removed but individual tires are left in place if
less than 25 percent of the tire extends above the surface.  In cases involving tire shreds, some states
require the contractor to use a 2-inch rake harrow to gather and remove surface shreds.

Other Wastes.  Other waste materials present in tire stockpiles are normally separated and placed in
piles.  In some cases, wastes are segregated to facilitate subsequent recovery (for example, of metals)
or disposal efforts. A contractor's responsibility for other wastes should be clearly defined in the
initial scope description. The contractor should receive supplemental compensation for waste-related
activities outside the scope.
  Site Restoration Case Study: Fort Wayne, Indiana

  In Fort Wayne, Indiana, a former oil pump manufacturing and warehouse site was used to store
  600,000 scrap tires by a company that went bankrupt. While the city was working with the state
  to remove the tires, a tire fire began that burned for 3 days over Labor Day weekend of 1997 (see
  http://www.abanet.org/statelocal/lawnews/223helmke.html). After the fire, approximately 3,200
  cubic yards of soil required removal from the site because of contamination from previous site
  activities and the tire fire; charred structures and underground tanks from years of manufacturing
  also required removal. After cleanup, 20 new homes were constructed on the site and it became a
  thriving community. This case illustrates how scrap tire piles can suddenly catch fire and how the
  fire can increase the amount of work and associated costs required to restore a site. Nonetheless, it
  is possible to revitalize sites after tire fires as productive land.
                                                                     Section 5: Project Management 33

     Grading. A site can be deeply rutted by heavy
     equipment during abatement activities.  The contractor
     is generally required to restore a relatively smooth
     surface corresponding to the original site contour.

     Roadways. Public dirt roadways rutted by heavily
     laden trucks during abatement activities are generally
     graded at the completion of on-site activities. County
     road crews are often assigned to do this grading at little
     or no cost as a show of cooperation. Access roadways
     constructed to facilitate the abatement are sometimes

     Erosion Control. Seeding and drainage channels can      Photo ^^sy of MeiPmS,iowaDNR
     control erosion of unstabilized surface soil. Silt screens or similar methods are used to control site
     runoff to adjacent surface waters until vegetation is re-established.

     Documentation. Post-abatement site conditions should be thoroughly documented by means of
     photographs or video recordings of ground conditions, residual piles, buildings, and fences.  The
     documentation should be retained to aid in resolution any subsequent problems or issues.
Section 5: Project Management 34

Many states have successfully cleaned up scrap tire stockpiles and established programs to prevent
future stockpile formation. Much can be learned from the successes and failures of the wide array of
strategies used to address this serious problem. This guidebook represents the first nationwide effort
to capture and share the collective knowledge of state and industry representatives with decades of
experience in stockpile abatement (see Acknowledgements).

Many states have proven that the threats to human health and the environment posed by uncontrolled
and illegal scrap tire stockpiles can be mitigated through thoughtful application of regulatory policy
and available resources along with careful planning and execution of cleanup projects. The past
experience of state and federal authorities has also clearly demonstrated that the costs of stockpile
prevention and abatement are small fractions of the costs associated with emergency response and
remediation activities necessitated by tire fires.

This guidebook outlines all the essential elements that need to be considered when planning and
implementing abatement programs and individual cleanup projects. After decades of catastrophic tire
fires and other health-related impacts of illegal scrap tire piles, it is clear that the practices described in
this guidebook need to be followed in order to adequately protect human health and the environment.

In addition to this guidebook, many resources are available to those who are working to deal with the
scrap tire problem, including state regulator forums, workshops,  seminars, international conferences,
trade associations, and journals. See http://www.epa.gov/epaoswer/non-hw/muncpl/tires/rel_links.htrn
for links to these resources.
Photo courtesy of Todd Thalhamer, California IWMB
                                                                 Section 6: Summary

    SECTION  7
     Scrap Tires - General Information
     U.S. EPA. "Management of Scrap Tires." On-Line Address: http://www.epa.gov/epaoswer/non-hw/

     Scrap Tire Fires - Analysis of Ambient Air Data
     U.S. Environmental Protection Agency (EPA) Office of Air Quality. 1993. "Analysis of Ambient Air
         Data in the Vicinity of Open Tire Fires."  On-Line Address: http://www.epa.gov/ttn/atw/burn/

     Scrap Tire Fires - Characterization of Emissions
     DeMarini, D.M., and P.M. Lemieux. 1992.  "Mutagenicity of Emissions from the Simulated Open
         Burning of Scrap Rubber Tires." U.S. EPA Document No. EPA-600/SR-92-127. July.

     Lemieux, P.M., and J.V. Ryan. "Characterization of Air Pollutants Emitted from a Simulated Scrap Tire
         Fire." U.S. EPA Document No.  EPA/600/s2-89-054.  On-Line Address: http://nepis.epa.gov

     U.S. EPA. "Field Study to Characterize Dioxin Emissions from Uncontrolled Combustion and Non-
         Combustion Area Sources. On-Line Address: http://cfpubl.epa.gov/ncea/cfm/recordisplay.

     U.S. EPA National Risk Management Research Laboratory. 1997. "Air Emissions from Scrap Tire
         Combustion." U.S.  EPA Document No. EPA/600/SR-97/115. By Joel I. Reisman. Cincinnati,
         OH. On-Line Address: http://permanent.access.gpo.gov/websites/epagov/www.epa.gov/ORD/

     U.S. EPA Office of Research and Development. 1997." Air Emissions from Scrap Tire Combustion."
         U.S. EPA Document No. EPA-600/R-97-115. Washington DC. On-Line Address: http://www.epa.

     Scrap Tire Fires - Prevention and Management
     Rubber Manufactures Association. 2000. "The Prevention & Management of Scrap Tire Fires."
         Washington DC. On-Line Address: http://rma.org/scrap_tires/scrap_tires_and_the_environment/

     West Nile Virus
     U.S. Department of Health and Human Services. 2003. "Epidemic/Epizootic West Nile Virus in the
         United States: Guidelines for Surveillance, Prevention, and Control." On-Line Address: http://
Section 7: Resources


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Dimensions (yard)



Volume (CY) or
No. of Tires


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CY = Cubic yards
PTE = Passenger tire equivalent
1 Truck (T), passenger (P), off-the-road (OTR), shredded - coarse (SC), or shredded - fine (SF)
2 Loose, stacked, horizontal stacked, or laced
3 Density ranges from 8 to 27 PTE/CY, normally about 10 PTE/CY for loose, shallow, whole-tire stockpiles
4 To calculate weight, use 100 PTE per ton
Note evidence of recent activity; topography; soil conditions; drainage and nearby surface water; site access, security and perimeter conditions
(trees, brush, etc.); perimeter and internal fire lanes; and nearby residences, schools and other receptors.
Provide a site sketch and/or attach photos.

  This guidebook is intended for use as guidance only. The reference or use of any specific policy,
  process, procedure, trade name, commercial product, or equipment does not imply or constitute
  endorsement or recommendation by U.S. EPA or Illinois EPA. This guidebook is a summary of
  information compiled from multiple sources on the topic of scrap tire cleanup, and should be
  considered non-binding information that is open to use and interpretation by the user as they see fit,
  and at their own risk.

  Several web links provided in this document are not contained in domains created or maintained by
  U.S. EPA or Illinois EPA. These links simply provide access to additional information in accordance
  with the intended purpose of this document. Neither U.S. EPA nor Illinois EPA can attest to the
  accuracy of information or the privacy protection provided by any external web site.  Providing links
  to external web sites does not constitute an endorsement by U.S. EPA, Illinois EPA, or any of their
  employees of the site sponsors or the information or products presented on the sites.