EPA-340/1-80-017
RACT Enforceability Aspects for
Pneumatic Tire Manufacturing
by
C.M. Harvey, J.P. Paul, and J.E. Spessard
PEDCo Environmental, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-01 -4147
Task No. 122
EPA Project Officer: John R. Busik
Task Manager: Robert L King
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of General Enforcement
Division of Stationary Source Enforcement
Washington DC 20460
January 1981
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DISCLAIMER
This report was furnished to the U.S. Environmental Protec-
tion Agency by PEDCo Environmental, Inc., in fulfillment of
Contract No. 68-01-4147. The contents of this report are repro-
duced herein as received from the contractor. The opinions,
findings, and conclusions expressed are those of the author and
not necessarily those of the U.S. Environmental Protection Agency.
11
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CONTENTS
Summary
Tables
Acknowledgments
1. Introduction
Background
Purpose and scope of report
2. Inventory of the Tire Industry
Data sources
Findings
Industry trends and economics
3. Description of Industry
Processing steps
Types of tires
Emissions of volatile organic compounds
4. Control Technology and Factors Affecting Enforcement
Summary of the regulations
RACT for the pneumatic tire manufacturing
industry ,
Control strategies for volatile organic compounds
Factors affecting regulation enforcement
5. Status of State Programs
State air control agencies
6. References
Appendix Pneumatic Tire and Tread Manufacturers
Inventory
IV
vi
vii
1
1
, 3
5
8 \
11
11
17
19
22
22
26
29
31
36
36
40
A-l
ill
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SUMMARY
A total of 94 plants located in 27 states and Puerto Rico
manufacture either pneumatic tires or tread rubber. The follow-
ing table lists the number of plants in photochemical oxidant
attainment and nonattainment areas that manufacture pneumatic
tires for automobiles, trucks, and buses; pneumatic industrial
tires; or tread rubber:
Pneumatic tires for automobiles,
trucks, and buses
Pneumatic industrial tires
Tread rubber
Total
57
7
30
94
Number of plants
Attainment Nonattainment
areas areas
23
3
13
39
34
4
17
55
The model regulations only apply to those plants in photochemical
oxidant nonattainment areas.
Daily production for 1978, obtained from either the January
1979 Modern Tire Dealer or estimated on the basis of employment
figures was 1,012,700 pneumatic tires and 1,590,000 Ib of tread
rubber. However, economic conditions have caused a decline in
the tire market. Seven tire plants operated by the five major
U.S. tire companies have been closed since 1975. Seven addition-
al closings are scheduled for late 1980. These affected plants
are predominantly older bias pneumatic tire manufacturing facili-
ties . At least four smaller companies either no longer manufac-
ture automobile tires or have filed for bankruptcy.
The major processing steps in the manufacture of tires are
rubber compounding, tread rubber production, cord production,
bead production, tire building, and tire curing and finishing.
Rubber compounding is the mixing of rubber and additives under
xv
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carefully controlled conditions to produce the material from
which tires are formed. Tread rubber is produced by extruding
compounded rubber through a die. Nylon, polyester, steel, fiber-
glass, or aramid cords are woven into fabrics and coated with
rubber. These coated fabrics are used to reinforce the tire.
The tire bead serves as the rim of the tire. The bead material
is brass-plated steel wire that is rubber-coated. In the tire
building operation, all of the tire components are assembled to
produce a "green" or uncured tire. In tire curing, green tires
are loaded into presses and cured at 100° to 200°C (212° to
400°F) with steam and/or hot water under pressure.
The three general types of tires are bias ply, bias belted,
and radial. Bias ply tires have two or more plies at a bias
(angle) to the tread. Bias-belted tires have one or more belts
between the plies and the tread. The belts are also at a bias
(angle) to the tread. Radial tires have belts extending from
bead-to-bead and perpendicular to the tread.
The following processes cause major volatile organic com-
pound (VOC) emissions from a typical pneumatic tire manufacturing
plant: green tire spraying with organic-based solvents, produc-
ing 1600 kg VOC emissions/day (3520 lb/ day); undertread cement-
ing, 1506 kg/day (3300 Ib/day); and tire building, 528 kg/day
(1160 Ib/day). Processes that cause less significant VOC emis-
sions are tread-end cementing, 240 kg/day (530 Ib/day); and bead
dipping, 131 kg/day (290 Ib/day). These average emissions are
based on a model tire plant producing 16,000 passenger tires/day.
The data are taken directly from the Control Techniques Guide-
line (CTG)*.
Practical VOC control measures are carbon adsorption and use
of water-based spray for green tire spraying. Hand application
of cement for tread-end cementing may be an acceptable control
provided emissions meet some arbitrary limit. Carbon adsorption
*U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions From Manufacture of Pneumatic Rubber Tires,
EPA 450/2-78-030, December 1978.
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in
They
emissions control
or the use of the VOC exhaust stream as the air supply for the
process steam boiler could be acceptable control measures for
bead dipping in some instances although the high air volumes
prevent application. No practical control measure has been found
for the emissions from tire building, which has a dilute, high-
volume exhaust stream.
PEDCo contacted representatives from air quality control
agencies having tire arid tread rubber manufacturing plants
their jurisdictions to verify our list of manufacturers
also helped to determine the status of state
programs for the pneumatic tire industry and to identify poten-
tial enforcement problems.
The potential enforcement problems appear to be determining
the capture efficiency of the VOC collection device, determining
compliance, applying the bubble concept, and meeting compliance
schedules. Capture efficiency can only be determined by a
material balance; thus, the inspector cannot determine the
capture efficiency of the collection device in the field.
tire industry maintains records of total solvent purchases but
does not keep records of solvent consumption by operation.
Because records are not now kept, there will be resistance
industry to record individual process solvent usage. Compliance
determination based on company records is not legally enforceable
in some states; therefore, other compliance determining methods
must be established. Applying the bubble concept in a pneumatic
tire manufacturing plant will allow the tire industry to
trol and undercontrol processes based on economics. To success-
fully apply the bubble concept the "up to" clause in the model
regulation must be clarified. The tire industry may also have
some problems in meeting compliance schedules when a formulation
change is the preferred choice of controlling VOC emissions.
Because of product liability problems, process changes are usual-
ly evaluated in the laboratory, and then the tire is road tested
under controlled conditions. Testing may require as long
twelve months. Compliance schedules may need to be lengthened
The
from
overcon-
as
in
these cases,
VI
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TABLES
Number page
1 Distribution and Capacity of Tire and Tread
Rubber Manufacturing Plants by EPA Region 6
2 Distribution of Tire and Tread Rubber Manufac-
turing Plants by State 7
3 " Parameters for a Typical Plant Manufacturing
16,000 Tires/Day 21
4 Threshold and Explosive Limit Values of
Solvents Used in the Tire Industry 28
5 Status of State Regulation of Status of Volatile
Organic Compound Emissions from Tire and Tread
Rubber Plants 39
VI1
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ACKNOWLEDGMENTS
This report was prepared for the Division of Stationary
Source Enforcement, U.S. Environmental Protection Agency.
Mr. John R. Busik served as the Project Officer, and
Mr. Robert L. King served as the Task Manager.
Mr. Thomas C. Ponder served as PEDCo's Project Director and
Ms. Cynthia M. Harvey as the Project Manager. The principal
authors of this report were Ms. Harvey, Mr. John P. Paul, and
Dr. John E. Spessard.
Vlll
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SECTION 1
INTRODUCTION
1.1 BACKGROUND
Emissions of volatile organic compounds (VOC) from the
entire rubber industry were estimated to be 1.4 x 108 kilograms
in 1976. Emissions from the-tire industry segment accounted for
63 percent of that total, or 0.6 percent of total national organ-
ic emissions from stationary sources. The average tire plant is
estimated to release 4000 kilograms of VOC per day. The emitted
VOCs are predominantly white gasoline and petroleum naphtha.
Other emissions include toluene, xylene, benzene, isopropanol,
ketones, and esters. .
1.2 PURPOSE AND SCOPE OF REPORT
Regulations appearing in the Federal Register on August 28,
1977, require states to submit revised State Implementation
Plan (SIP) revisions by July 1, 1980, reflecting VOC regulations
for the pneumatic tire manufacturing industry. The Control
Techniques Guideline (CTG), published in December 1978 by the
U.S. Environmental Protection Agency (EPA), identifies VOC emis-
sion reduction systems for undertread and tread-end cementing,
bead wire dipping, and green tire spraying.1 The rubber tire
industry believes that some VOC emission controls are too costly
and consume substantial amounts of energy.
This report will aid the Division of Stationary Source
Enforcement and state and local agencies by providing the follow-
ing information:
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An inventory of operating pneumatic rubber tire and tread
rubber plants, with an identification of those that are
subject to regulation because they are in nonattainment
areas.
A brief review of the industry's ability to install and
implement control measures, and of probable industry re-
sponse to the regulations. Plant visits to 4 pneumatic tire
manufacturing plants were used to gather this information.
A summary of pneumatic tire and tread rubber manufacturing
processes, control equipment, and capture methodology. This
information can be used to determine reasonable compliance
schedules and potential problems in design of control equip-
ment.
Plans by state air quality control agencies .for regulation
and enforcement.
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SECTION 2
INVENTORY OF THE TIRE INDUSTRY
In order to determine the plants that might be potentially
subject to the model regulations, it was necessary to compile a
list of all the pneumatic tire and tread manufacturing plants in
the United States. PEDCo used available data sources that con-
tain lists of pneumatic tire and tread rubber manufacturing
plants, contacted individual plants by telephone to resolve any
discrepancies, and contacted the 10 EPA regional offices and 27
state air quality control agencies to verify the number plants
located within their jurisdictions.
DATA SOURCES
PEDCo used the following eight data sources to compile this
inventory of pneumatic tire manufacturing plants and tread rubber
plants:
1. 1978 Rubber Red Book, 30th Edition, published by Pal-
merston Publishing Company, Inc., Atlanta, Georgia.
2. 1979 Rubber Red Book, 31st Edition, published by Pal-
merston Publishing Company, Inc., Atlanta, Georgia.
3. List of tire manufacturers published in the January
1978 issue of Modern Tire Dealer.
4. List of tire manufacturers published in the January
1979 issue of Modern Tire Dealer, with an update fur-
nished by Mr. Chuck Slaybaugh, Editorial Director.
5. 10-K Reports submitted to the Securities and Exchange
Commission by rubber manufacturers with publicly held
stock.
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6. Indices of Manufacturers from all 50 states and the
District of Columbia as compiled by the Dallas Public
Library.
7. Quick Look Report compiled by the EPA Compliance Data
System.
8. List of tire manufacturers contained in the EPA Control
Technology Guidelines. (The primary reference used in
this source was a list of tire manufacturers published
by Rubber World in its February 1978 issue. Rubber
World's list had been taken from the January 1978 issue
of Modern Tire Dealer, Source 3 of this list.)
All companies indicated as manufacturers of pneumatic tires or
tread rubber were contacted by telephone. Plant closings, busi-
ness reorganizations, and mergers were noted. Misinformation was
corrected.
The sources provided a method for estimating and checking
production rates and other information. For instance, the list
published in Modern Tire Dealer included production estimates for
each plant. The Rubber Red Book and Indices of Manufacturers
frequently estimated the number of employees at particular
plants. When the number of employees at individual plants was
compared with production estimates, it was possible to make a
correlation between the two. One tread manufacturer voluntarily
disclosed the production rate at his plant. His employment level
was given in the Rubber Red Book. Employment levels could then
be used to estimate tread rubber production capacity at other
plants.
The "States Attainment Status of National Ambient Air Qua-
lity Standards," published in the Federal Register on March 3,
1978, was used to determine which plants are in photochemical
oxidant attainment or nonattainment areas. In the appendix we
have listed the counties and Air Quality Control Regions (AQCR)
in which the plants are located. Changes in attainment status
were reported in the Federal Register on September 11,
September 12, and October 5, 1978; this report incorporates those
changes. In January 1979, approval of new National Ambient Air
-------
Quality Standards (NAAQS) for photochemical oxidants also af-
fected the attainment status of several areas, and this report
reflects those changes.
FINDINGS
The inventory identified 94 plants in 27 states and Puerto
Rico. The plants are grouped into three categories: 1) pneumat-
ic passenger tire plants; 2) pneumatic industrial tire plants;
and 3) tread rubber plants. The plants are grouped by EPA region
in Table 1 and by state in Table 2. Individual plants and esti-
mated capacities are presented in the appendix on a regional and
state-by-state basis.
Pneumatic passenger tire manufacturers primarily make auto-r
mobile, truck, and bus tires. This category includes 57 plants
operated by 16 companies; 23 of the plants are in attainment
areas and 34 are in nonattainment areas.
Industrial pneumatic tire plants make tires for forklifts,
electric cars, and other vehicles for industrial use employing
standard pneumatic tire-making equipment. They do not make
automobile, truck, bus, or airplane tires. This category in-
cludes seven plants operated by seven companies; three of the
plants are in attainment areas and four are in nonattainment
areas.
Tread rubber manufacturers make tire tread for recapping
worn tires. This category includes 30 plants operated by 19
companies; 13 of the plants are in attainment areas and 17 are in
nonattainment areas.
Some listed industrial tire and tread manufacturing plants
may be exempt from proposed VOC regulations for one of the fol-
lowing reasons:
1. They manufacture small volumes of speciality tires.
2. They manufacture tires in short production runs, but
tires are only a minor part of their operation. Most
of their products are not subject to the proposed VOC
regulations. Guidance to states in determining exemp-
tions is contained in the CTG.
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TABLE 2. DISTRIBUTION OF TIRE AND TREAD
RUBBER MANUFACTURING PLANTS BY STATE.
State
Alabama
Arkansas
Cal i form' a
Connecticut
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Maine
Maryland
Massachusetts
Michigan
Mississippi
New Jersey
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Virginia
Wisconsin
Puerto Rico
TOTALS
Number of plants
Attainment areas
Car/truck
tires
4
1
0
0
1
2
0
0
1
1
0
1
0
0
1
0
0
2
0
3
0
0
2
1
1
1 •
1
0
23
Industrial
tires
1
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
3
Tread
rubber
3
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
3
0
0
0
0
1
0
2
0
0
T
13
Nonattainment areas
Car/truck
tires
1
0
3
1
0
2
1
2
0
0
0
0
1
2
0
1
1
1
8
1
0
4
0
3
1
1
0
0
34
Industrial
tires
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
4
Tread
rubber
0
0
4
0
2
0
0
1
0
0
0
0
0
0
0
1
0
1
3
0
1
1
0
0
2
1
0
0
17
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3. They manufacture small volumes of tread rubber. For
example, some of the tread rubber manufacturers in
California may be exempt from the VOC regulations
because California's proposed regulations exempt
sources emitting less than 200 pounds of VOC per day.
4. Tread manufacturers may not have undertread cement
operations.
5. Tread rubber is manufactured at some recapping plants
operated by major rubber companies. These plants, some
of which use undertread cement, are not included in the
survey.
All plants that are potentially subject to regulation have
been listed because the proposed regulations might be revised;
also, some states might adopt regulations more stringent than
called for by Federal standards.
INDUSTRY TRENDS AND ECONOMICS
Economic conditions over the last few years and the popular-
ity of the longer-lasting radial tire have caused a decline in
the pneumatic passenger tire market. Seven tire plants have
closed since 1975 and seven additional closings are scheduled for
late 1980. Several of the smaller tire manufacturers no longer
make pneumatic passenger tires.
Automobile and Truck Tires
The five major domestic manufacturers of automobile and
truck tires are Firestone, Goodyear, Goodrich, General, and Uni-
royal. English-owned Dunlop and French-owned Michelin also have
significant manufacturing operations in the United States. Three
small manufacturers that produce 11 percent of the domestic tires
are Armstrong, Cooper, and Mohawk.
These three smaller manufacturers have survived primarily
because each has at least one major customer. Armstrong makes
tires for Sears. Cooper makes tires for Hercules Tire and Rub-
ber, a wholesale buying group that sells to independent tire
dealers. Even so, Cooper describes its tire operations as "strug-
gling" to remain profitable. Mohawk sells tires to K-Mart and
8
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Montgomery Ward. Armstrong and Cooper have other profitable
operations to offset marginal tire profits.
McCreary Tire and Denman Rubber Manufacturing Company have
abandoned the automobile tire market but continue to make other
pneumatic tires. Super Tire Engineering Company makes pneumatic
tires other than automobile tires, and Universal Tire Company
manufactures tires for antique cars. IRI, Inc. and Mansfield
Tire and Rubber Company, subsidiary of Inland Rubber, filed for
bankruptcy in 1979. They no longer make pneumatic tires.
The passenger tire market is shrinking. The popular radial
tire lasts longer than tire companies had anticipated, and light-
erweight cars reduce tire wear. Because of market weakness,
gasoline shortages, rising gasoline prices, and falling auto
sales, Goodyear predicted that automobile tire shipments would
drop 11 percent from 1978 levels. They also predicted an 8
percent drop for truck tire shipments. Goodyear has indicated a
loss for the third quarter of 1979. Uniroyal lost $10 million in
the third quarter of 1979 and projects a loss of about $20 mil-
lion for the entire year.
The five major rubber companies have closed seven passenger
tire manufacturing facilities since 1975. Firestone closed
plants in Akron, Ohio, and in Los Angeles. Goodyear, Goodrich,
and Uniroyal closed plants in Los Angeles. Goodyear closed a
plant in Akron and its Lee Tire and Rubber subsidiary in Consho-
hocken, Pennsylvania. Mohawk Rubber Company closed two of its
three plants. Uniroyal will close plants in Detroit and Chico-
pee, Massachusetts, in late 1980. Passenger tires are no longer
manufactured in Akron or Los Angeles; previously these cities
were principal locations for passenger tire production. Some
companies have relocated their operations into Southern states
primarily to take advantage of lower labor costs.
Industry representatives indicate that high costs to meet
potential VOC control regulations may lead to the closing of
additional plants. Whether or not this is true, the industry is
not healthy.
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Industrial Tires
Industrial tires are used on off-the-road vehicles such as
forklift trucks. Most of the tires are solid rubber, but seven
manufacturers produce pneumatic tires for these vehicles. Pneu-
matic tires appear to be a minor part of the production of these
seven companies. For comparison, a typical automobile or truck
tire plant employs a thousand or more people, but an industrial
tire plant employs a few hundred. Hence, industrial pneumatic
tire manufacturing is comparatively minor.
Tread Rubber Manufacturing
Nineteen companies in the United States and Puerto Rico
operate thirty tread rubber manufacturing plants. They produce
rubber for retreading automobile, truck, and bus tires. Tread
rubber plants are relatively small. The larger of these plants
employs about 100 people. Some of the plants produce other goods
at the same site. These other production processes are not
subject to the proposed VOC regulations. National employment by
tread rubber manufacturers is about 3000 people; or only twice
the employment of an average- automobile tire manufacturing plant.
10
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SECTION 3
DESCRIPTION OF INDUSTRY
PROCESSING STEPS • •, • •
Pneumatic rubber tires are produced through a number of
different processing steps. These~steps include rubber compound-
ing; tread rubber, cord, and bead production; tire building;
green tire spraying; and tire curing and finishing. Figure 1 is
a flow diagram of this sequence of operations necessary to pro-
duce a finished pneumatic tire.
Rubber Compounding
Only 60 to 70 percent of the weight of a tire is rubber.
Several different rubber compounds are used in passenger car
tires. The most common rubber compounds are styrene-butadiene,
natural rubber, polyisoprene (to replace natural rubber), and
polybutadiene. All rubber compounds are prepared in basically
the same manner. Breakdown is the first step in rubber process-
ing. The purpose is to soften and work rubber so that other
ingredients can be blended in to make a uniform product. A Ban-
bury mixer is commonly used for working and blending rubber. The
Banbury mixer customarily operates at 275.8 to 551.6 kPa (40 to
80 psia) and at 150°C (300°F).
After breakdown, the rubber and additives are blended to a
uniform dispersion. Generally the order of addition to the
Banbury is (1) rubber, (2) plasticizers and softeners, (3) re-
inforcing agents and fillers, (4) sulfur or other curing agents,
and (5) accelerators.
After mixing, the rubber compound is usually dipped in a
cooling bath and stored in a cool room.
11
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Tread Rubber Production
Rubber compound is extruded to form tread. If the rubber
has been stored and cooled, it is run through a warming mill
before being fed into the extruder. Most extruders are of the
screw type in which the screw forces rubber through a die. Fol-
lowing extrusion, the continuous stream of uncured tread is bevel
cut to a predetermined length, weighed, cooled, and cemented.
The feed into an extruder must be clean. Dirt and agglomerates
are removed by straining through a screen. Operating conditions
are closely controlled. Tire sidewalls and bead wire coating are
also extruded. .
The tire tread is cemented to the body or carcass of the
tire. If the cement is. properly applied, the tread-to-carcass
bond is stronger than the body of the tire. Evaporated solvent
from the tread cementing operation is a major source of VOC
emissions. A typical tire plant emits about 1520 kg VOC/day ;
(3350 Ib/day) in an 11.2-m3/s airstream (23,600 cfm) containing
1.57 g VOC/m3 (385 ppm).
After the tread is cemented to the tire, the tread ends are
cemented together. For a typical tire plant, VOC emissions as a
result of tread-end cementing are estimated at 240 kg/day: (530
Ib/day) in an airstream of 15.6 m3/s (32,800 cfm) containing
0.18 g VOC/m3 (44 ppm).
Various adhesives are used in the tire manufacturing pro-
cess. It is a difficult task to bond tire cord, steel, and the
other components of a tire together. Adhesive solvents are
significant VOC sources; factors in the selection of adhesives
are discussed below.
Molecular, chemical, and mechanical bonds affect the
strength of an adhesive. Molecular bonding is achieved through
(1) the adsorption of adhesive ingredient chemicals on the fiber
surface, (2) diffusion of other adhesive components (including
solvents) into the fiber polymer and the rubber compound, and
(3) physiochemical activity. Chemical bonding results from
13
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chemical reactions between the adhesive, fabric, and rubber. The
type and number of functional groups and the mobility of the
various molecules in the bond are important. Mechanical bonding
occurs when the adhesive fills the space between the materials to
be bonded.
Important properties in adhesive bonding are reactivity and
surface and finish characteristics. Each material has a differ-
ent reactivity. For example, rayon has many reactive hydroxyl
groups; nylon is less reactive but has highly polar amide link-
ages. Polyester is quite inert. The adhesive bond also depends
upon the degree of contact between the two surfaces. Rough and
soft surfaces would be preferable to smooth and hard surfaces.
Because the adhesive must bond to rubber, the type and
nature of the rubber is important and must be considered. Natur-
al and synthetic rubbers have different chemical properties which
may dictate the choice of adhesive. The other ingredients in the
compounded rubber also are factors in this choice.
A good adhesive system has the following characteristics:
Rapid adhesion
Compatibility with other materials
No adverse effects on tire properties
Good heat resistance
Good aging resistance
Good tack
Mechanical stability
The adhesive bond must remain strong through years of ser-
vice under a wide range of conditions. The consequences of
failure can be very serious. A rubber company may be reluctant
to change a proven adhesive formula.
The industry manufactures significant amounts of rubber for
retreading sound tire carcasses. Truck, aircraft, and bus tires
are routinely retreaded. Retreaded automobiles tires are lower
in cost but generally wear faster than a new tire.
Tread rubber produced in retread plants is much the same as
that produced in a tire plant. The rubber compound is extruded
to produce the tire tread. Retreaders can either purchase or mix
14
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their own rubber compounds. After extrusion, some manufacturers
coat the undertread with an adhesive cement and use a polyethy-
lene liner to keep treads from sticking together during handling
and shipping. Other tread manufacturers do not apply cement
before shipping. Rather, the retreader applies the cement prior
to bonding the tread to the tire carcass.
The VOC emissions from tread rubber plants have not been
estimated or measured, but emissions from plants that apply
undertread adhesive are probably similar to emissions from under-
tread cement operations in a tire manufacturing plant. Retread
rubber plants are smaller than tire manufacturing plants, so
total VOC emissions are less.
Cord Production
Rubber-coated tire cord makes up a significant part of the
body of a tire. The cord reinforces rubber much as steel re-
inforces concrete. Tire cord also provides fatigue resistance
and gives the tire shape, size stability, bruise resistance, and
load-carrying capacity. Materials that have been found suitable
for use as tire cord are nylon, polyester, steel, fiberglass, and
aramids. Nylon and polyester are primarily used in the body or
carcass of the tire. Steel, aramid, and fiberglass are primarily
used in the belts between the carcass and the tread.
Cord production consists of twisting yarn on itself and then
twisting two or more yarns together. Cords are then woven to-
gether to form fabric. None of the operations in cord production
are a major VOC source.
An adhesive is then applied to the fabric to bond rubber to
it. Adhesive must be applied under controlled conditions of
time, temperature, and fabric tension. Bonding rubber to nylon
is a particular problem. Fabric treatment operations are con-
trolled and monitored by computers. The tire cord is coated by
immersion in adhesive and removal of excess adhesive by vacuum or
compressed air. The adhesive is generally waterbased.
15
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Rubber compounds are applied to the fabric by a process
called calendering. A calender is a machine equipped with three
or more heavy rollers that rotate in opposite directions to those
in direct contact with them. Rollers are heated by the circula-
tion of water or steam through them. Gears permit the rollers to
operate at varying speed ratios. One roller may move at the same
speed or faster or slower than the rollers adjacent to it. The
amount of rubber deposited onto the fabric is determined by the
distance between rollers.
Rubber compounds for calendering should have little or no
shrinkage, be tacky enough for tire-building operations, and
exhibit good fabric adhesion. Warmup mills maintain uniform
feedstock working properties so that a uniform layer of rubber
can be applied to the fabric.
Usual practice is to coat fabric at the textile mill rather
than at the tire plant. A coating operation supplying only one
tire plant requires a disproportionate amount of capital, and one
unit can produce enough coated fabric for several tire plants.
Further, on a weight basis the shipping costs for coated and
uncoated fabric are nearly the same.
Bead Production
The tire bead is made of rubber-coated steel that is formed
into a hoop. The bead serves as the rim of the tire, holding the
tire on the rim of the wheel and anchoring the plies. Extruded
rubber is used to coat high-tensile-strength, brass-plated steel
wire. Several layers of coated wire are formed into a hoop, and
cement is applied to the bead by dipping, wiping, or spraying.
Rubber-coated fabric may be wrapped around the bead; the assembly
is sometimes dipped in adhesive to achieve a good bond between
the bead and the sidewall.
The bead-cementing process, if performed by the tire manu-
facturer, is a source of emissions in a tire plant. Bead cement
solvents include gasoline, hexane, isopropanol, naphtha, and
toluene. Estimated VOC emissions from bead dipping in a typical
16
-------
tire plant are 130 kg/day (290 Ib/day), This emission is for an
airstream of 5.4 m3/s (11,400 cfm) containing 0^28 g VOC.m3 (69
ppm).
Tire Building
Tire components are assembled in the tire-building operation
to produce a "green" or uncured tire. Bias-ply and bias-belted
tires are built on drums in a single-stage process. Radial tires
are built in two or three stages. All tire building starts with
a thin layer of special rubber called the inner liner being
placed on the drum. The inner liner retains the air in a tire.
Next, the plies are placed on top of the inner liner one ply at a
time. The beads are then set in place and the plies are turned
up around the beads. Belts, if any, are applied next. Finally
the sidewalls and tread are added. The drum is collapsed and the
green barrel-shaped tire is removed.
In radial tire building the green tire is generally expanded
from a cylindrical (barrel) shape to a toroidal (doughnut) shape
before adding the belts and treads. The belts and treads are
then added to produce a green tire that resembles a distorted
doughnut.
Tire building is a significant source of VOC emissions. in
a typical tire plant, emissions from tire building have been
estimated to be 500 kg/day (1100 Ib/day). These emissions are : ,
from an airstream .of 283 ms/s (600,000 cfm) containing O."o2 g
VOC/m3 (5 ppm). The volume of this stream coupled with the low
VOC concentration makes control of VOC emissions expensive and
difficult.
Green Tire Spraying
Before molding and curing, green tires are sprayed with
release agents. The spray removes air from the tire during
curing and prevents the tire from sticking to the mold after '
curing. Sprays also aid in rubber flow during curing, cover tire
blemishes, and add a shiny finish to the cured rubber. Either
organic-based or water-based sprays can be used. If water-based
17
-------
sprays are used, this operation is not a significant source of
emissions. If an organic-based spray is used, emissions from
this operation at a typical tire plant have been estimated at
1600 kg/day (3530 Ib/day). Emissions are from an airstream of 23
m3/s (48,400 cfm) containing 0.81 g VOC/m3 (200 ppm).
Tire Curing and Finishing
Green tires are loaded into presses and cured (vulcanized)
at temperatures of 100° to 200°C (212° to 400°F). In press
curing, the tire is clamped into the mold and inflated with an
air bladder. The rubber flows into the shape of the mold to form
the desired tread pattern and wall thickness. Good flow depends
on the plasticity of the uncured rubber. Flow must be complete
before curing begins or the tire will be distorted. Proper flow
is accomplished by adding fillers to control rubber plasticity,
utilizing plasticizers, and controlling curing conditions. After
curing, the mold is deflated and the tire is removed. The tire
is then inflated and allowed to cool, and excess rubber is ground
off. A final buffing and grinding of the tire insures balance.
A blue or green water-based coating is applied to the white
sidewalls to minimize scuffing during shipment and mounting on
rims. Decals or other markings are sometimes applied with sol-
vent-based inks, paints, or sprays.
TYPES OF TIRES
General Classes
The three kinds of pneumatic tires produced are bias ply,
bias belted, and radial. Materials of construction and proces-
sing steps are similar for these tires. There are two differ-
ences, however, in the way the tires are built: (1) the angle or
bias the plies make with the tread, and (2) the presence or
absence of belts between the plies and the tread.
The bias-ply tire is the original pneumatic tire. The
reinforcing cords or plies extend diagonally across the tire from
18
-------
bead to bead at an angle of 30° to 40°. Each ply runs in an
opposite direction to the plies above and below it.
The bias-belted tire represents an intermediate step between
the bias-ply tire and the radial tire. It can be made on conven-
tional tire-building equipment. Radial tires are built in a two-
or three-step process and require special equipment. Tire manu-
facturers in the United States have produced large numbers of
bias-belted tires as replacement equipment. Like the bias-ply
tire, the reinforcing cords or plies extend diagonally across the
tire from bead to bead. The angle is generally 25° to 40°. Be-
tween the plies and the tread are belts that are also at an angle
to the tread. This angle is between 20° to 30°, with the belt
angle being at least 5° less than the cord angle. Each belt runs
in a different direction from the belts above and below it.
The radial tire has the carcass plies running parallel to
the axis of the tire. As in the bias-belted tire, there are
belts between the plies and the tread. These belts are nearly
perpendicular to the carcass plies and serve to reinforce the
carcass plies and to provide stability under stress such as in a
sharp turn.
Passenger and Truck Tires
A passenger tire is typically assembled in 5 minutes or less
by one worker. Much of the operation is automated in plants that
manufacture new car tires. Long production runs on one tire size
are usually scheduled. Those plants manufacturing replacement
tires are usually less automated because they make several sizes
of tires on a short-run basis.
Large tires (such as truck tires) require more time for
assembly. A team of workers may be needed to manufacture the
larger tires. A truck tire usually has more natural rubber than
a passenger tire. Because natural rubber has a higher green
strength than synthetic rubber, it is much harder to break down.
It also usually requires more solvent to render it tacky enough
to work. The VOC emissions from truck tire manufacturing are
19
-------
probably greater per tire than from passenger tire manufacturing.
Natural rubber is more puncture-resistant than synthetic rubber.
Industrial and Other Tires
Major tire manufacturers also produce industrial tires.
These tires are used on forklift trucks and other industrial
vehicles. A number of small manufacturers produce industrial
tires. Only seven of them make pneumatic tires. Pneumatic tires
appear to be a minor part of their manufacturing effort.
VOC EMISSIONS OF VOLATILE ORGANIC COMPOUNDS
According to the CTG, the four VOC emission .processes that
have been identified for control are undertread cementing, tread-
end cementing, bead dipping, and green tire spraying. No practi-
cal control technology exists for tire building. Table 3 lists
parameters and estimated VOC emissions from a model tire plant
producing 16,000 passenger tires per day. All emissions are at
temperatures ranging from 18° to 27°C (65° to 80°F).
Undertread Cementing
The model tire plant has four undertread cementing units.
Estimated VOC emissions from each unit are 380 kg/day (840
Ib/day) in an airstream of 2.8 ms/s (5900 cfm). The VOC content
is 1.57 g/m3 (385 ppm). Total estimated emissions for this
processing step are 1520 kg/day (3350 Ib/day) in an airstream of
11.2 ma/s (23,600 cfm).
Tread-end Cementing
The model tire plant has four tread-end cementing units.
Estimated VOC emissions from each unit are 60 kg/day (130 Ib/day)
in an airstream of 3.9 ms/s (8260 cfm). The VOC content is 0.18
g/m3 (44 ppm). Total estimated emissions for this processing
step are 240 kg/day (530 Ib/day) in an airstream of 15.6 m3/s
(32,080 cfm).
20
-------
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Bead Dipping
Tire plants using a bead-dipping process usually have two
units. Estimated VOC emissions from each unit are 65 kg/day (140
Ib/day) in an airstream of 3.7 ms/s (5700 cfm). The VOC content
is 0.28 g/m3 (69 ppm). Total estimated VOC emissions for this
processing step are 130 kg/day (290 Ib/day) in an airstream of
5.4 m3/s (11,400 cfm).
Tire Building
The model tire plant has 50 processing units. Estimated VOC
emissions from each unit are 10 kg/day (20 Ib/day) in an air-
stream of 5.7 ms/s (12,100 cfm). The VOC content is 0.02 g/m3 (5
ppm). Total estimated emissions for this processing step are 500
kg/day (1100 Ib/day) in an airstream of 285 ms/s (600,000 cfm).
Because of the large air volume and low VOC content of this
processing stream, no economically acceptable control measures
have been suggested; VOC emissions from this stream will probably.
not be controlled.
Green Tire Spraying
The model tire plant has five green-tire-spraying units.
Estimated VOC emissions from each unit are 320 kg/day (700 lb/
day) in an airstream of 4.6 ms/s (9700 cfm). The VOC content is
0.81 g/m3 (200 ppm). Total estimated emissions for this process-
ing step are 1600 kg/day (3530 Ib/day) in an airstream of 23 m3/s
(48,400 cfm).
22
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SECTION 4
CONTROL TECHNOLOGY AND FACTORS AFFECTING ENFORCEMENT
In December 1978, the EPA Office of Air Quality Planning and
Standards (OAQPS) issued a CTG that specified means of control-
ling VOC emissions from the manufacture of pneumatic rubber
tires. Model regulations based on reasonably available control
technology (RACT) have been formulated for this industry. This
section briefly describes RACT and the factors affecting enforce-
ment.
SUMMARY OF THE REGULATIONS
On the basis of the control technology recommended in the
CTG document, regulations affecting existing VOC sources of
emission will be developed by the States for pneumatic tire
manufacturers.
The regulations apply to undertread cementing, tread-end
cementing, bead dipping, and green tire spraying. The regula-
tions do not apply to specialty tire production for antique or
other vehicles when produced on an irregular or short-run basis
and when using equipment separate from normal production lines.
The regulation guidelines call for the owner or operator of
an undertread cementing, tread-end cementing, or bead-dipping
operation to reduce VOC emissions by:
Installing and operating a capture system designed to cap-
ture up to 85 percent by weight of VOC emitted from all
undertread cementing, tread-end cementing, and bead-dipping
operations, and
Installing and operating a control device that meets the
requirements of one of the following:
23
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A carbon adsorption system designed and operated to
achieve a 95 percent removal of VOC from the gases
ducted to the control device, or
An incineration system that oxidizes at least 90 per-
cent of the nonmethane VOC's (measured as total combus-
tible carbon) which enter the incinerator to carbon
dioxide and water, or
An alternative VOC emission reduction system certified
by the owner or operator to have at least a 90 percent
reduction efficiency, measured across the control
system, and which has been approved by the EPA.
For green-tire spraying operations, the owner or operator shall
reduce VOC emissions by:
Substituting water-based sprays for the normal solvent-based
mold release compounds; or,
Installing a capture system designed and operated in a
manner that will capture and transfer at least 90 percent of
the VOC emitted by the green-tire spraying operation to a
control device, and in addition, install and operate a
control device that meets the requirements of one of the
following:
A carbon adsorption system designed and operated to
achieve a 95 percent removal of VOC from the gases
ducted to the control device, or
An incineration system that oxidizes at least 90 per-
cent of the nonmethane VOC's to carbon dioxide and
water, or
An alternative VOC emissions reduction system certified
to have at least a 90 percent reduction efficiency,
measured across the control device, and which has been
approved by the EPA.
For the carbon systems, maximum reasonable capture should be
consistent with the following guides:
American Conference of Governmental Industrial Hygienists.
Industrial Ventilation, A Manual of Recommended Practices.
15th ed., 1978.
U.S. Department of Health, Education, and Welfare. National
Institute of Occupational Safety and Health. Recommended
Industrial Ventilation Guidelines. NIOSH 76-162, 1976.
24
-------
If the regulations are promulgated by July 1, 1980, then the
owner or operator of an undertread cementing, tread-end cement-
ing, bead-dipping, or green-tire spraying operation subject to
this regulation may, instead of implementing the measures re-
quired above, submit a petition for alternative controls before
September 15, 1980. The alternative control plan is not effec-
tive until it is submitted and approved by the EPA Administrator
as a State Implementation Plan revision.
Typical compliance schedules should call for the owner or
operator of a pneumatic rubber tire manufacturing plant to meet
the following increments of progress: (Note: Item dates assume
promulgation by July 1, 1980, and should be adjusted to reflect
the actual date of promulgation.)
For process equipment changes, low'solvent technology, and
add-on control devices, including incineration with heat
recovery:
Submit final plans for the emission control system
before October 15, 1980;
Award contracts or purchase orders for the emission
control system before December 15, 1980;
Initiate onsite construction or installation of the
emission control device before May 1, 1981;
Complete onsite construction or installation of the
emission control device before May 1, 1982; and,
Achieve .final compliance before July 1> 1982.
For incineration without heat recovery and substitution of
water-based spray in the green-tire spraying operation, a
typical compliance schedule might be:
Submit final plans before September 15, 1980;
Award all contracts or purchase orders before Novem-
ber 15, 1980;
Initiate onsite construction or installation before
January 15, 1980;
25
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Complete onsite construction or installation before
May 15, 1981; and,
Achieve final compliance before July 1, 1981.
The owner or operator of a pneumatic rubber tire manufactur-
ing plant may submit a proposed alternative compliance
schedule provided:
The proposed alternative compliance schedule is sub-
mitted before September 15, 1980;
The owner or operator provides information showing the
need for an alternative schedule;
The alternative compliance schedule contains increments
of progress;
Sufficient documentation and certification from appro-
priate suppliers, contractors, manufacturers, or fabri-
cators is submitted by the owner or operator of the
volatile organic compound source to justify the dates
proposed for the increments of progress; and,
Final compliance is achieved as expeditiously as possi-
ble and before the photochemical oxidant attainment
date.
A 2-year schedule is recommended for add-on control equip-
ment and process changes requiring the purchase of equipment,
except for incineration systems without heat recovery. A 1-year
schedule is recommended for installation of incineration systems
without heat recovery, or process modifications not requiring the
purchase of equipment. The compliance schedules presented here
assume that July 1, 1980, is the effective date of the regula-
tion.
The owner or operator of a VOC source shall demonstrate com-
pliance by the methods outlined below, or by an alternative EPA
approved method.
U.S. Environmental Protection Agency. Measurement of Vola-
tile Organic Compounds. Guideline Series document.
EPA-450/2-78-041, 1978.
U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions from Existing Stationary Sources. Volume
26
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II: Surface Coating of Cans, Coils, Paper, Fabrics, Auto-
mobiles, and Light-Duty Trucks. Appendix A.
EPA-450/2-77-008, 1977.
The EPA may accept, instead of green-tire spray analysis, a
certification by the manufacturer of the green tire spray, if
supported by actual batch formulation records.
If add-on control equipment is used, the following para-
meters shall be monitored continuously.
Exhaust gas temperatures of incinerators
Temperature rise across a catalytic incinerator bed
Breakthrough of VOC on a carbon adsorption unit
Any other continuous monitoring or recording device required
by the U.S. Environmental Protection Agency.
RACT FOR THE PNEUMATIC TIRE MANUFACTURING INDUSTRY
The following information is needed to determine the control
methods that can be used on any or all of the emission streams
found in a tire plant.
Treated air volumes
Airflow rates
Controlled VOC quantities
VOC process stream concentrations
Process airstream VOC definition
Permissible worker VOC exposure concentrations
VOC explosive limits
Table 3 (in Section 3) shows the estimates of VOC emissions
and concentrations as well as the process airstream quantities
and flow rates given in the CTG. Table 4 shows the threshold
limit values (as established by the American Conference of Gov-
ernmental Industrial Hygienists, or ACGIH), and the VOC explosive
limits.
27
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TABLE 4. THRESHOLD AND EXPLOSIVE LIMIT VALUES
OF SOLVENTS USED IN THE TIRE INDUSTRY.
Solvent
Benzene
Gasoline
Hexane
Isopropanol
Naphtha
Toluene
Threshold limit values
for continuous exposure
ppm
10
b
100
400
100C
100
mg/m3 air
30
b
360
980
400
375
Explosive limit
Lower limit, %
1.3
1.4
1.2
2.0
Flash point -
1.27
Upper limit, %
7.1
7.6
7.5
12.0
100°F (38°C)
7.0
As established by the American Conference of Governmental Industrial
Hygienists.
Depends on aromatic content.
Permissible workplace level as established by the Occupational Safety and
Health Administration.
28
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Proposed Control Measures
Thermal Incineration—
In thermal incineration, fuel is combined with air and the
VOC stream, and the mixture is burned in an incinerator. If
primary heat recovery is used to reduce fuel consumption, the
exit temperature of the flue gas is reduced to about 800°F. This
low-temperature flue gas has little use except for heating makeup
air for the facility ventilation system. The quantity of heat
produced by the afterburners greatly exceeds the needs of the
average tire plant.
Catalytic Incineration— - ' , ..
Catalytic incineration burns the captured VOC in the pre-
sence of a catalyst. The' catalyst enhances combustion so that
less fuel is needed than for conventional incineration. Catalyt-
ic combustion temperatures are lower [425° to 625°C (800° to
1200°F)] than conventional incineration temperatures [about 800°C
(1400°F)]. Rubber compounding ingredients such as sulfur and
metal-organic compounds may contaminate the catalyst surface, and
consequently the catalyst must be regenerated. This adds to the
operating and maintenance cost of the system. Also, fuel to
operate the incinerator is in short supply, and costs are high.
As with thermal incinerators the heat recovered from catalytic
incinerators is difficult to use in tire-making plants.
Carbon Adsorption--
The most suitable alternative for VOC control appears to be
carbon adsorption, especially for the undertread cementing opera-
tion. Carbon adsorption controls VOC emissions by removing them
from the exhaust stream. When the bed is saturated, the organic
solvent is recovered by heating the bed. Steam is usually passed
through the bed to vaporize the adsorbed solvent. The steam/VOC
mixture is condensed and separated in a decanter. The solvent is
transferred to a storage tank to be reused.
29
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Other Control Techniques—
A study of other industries2'3 has been conducted to find
methods for controlling VOC emissions that might be applied to
the pneumatic tire industry. A control method was considered if
it has been used successfully and if a detailed description of it
has been published. Two possible VOC control strategies were
found:
Use of a process boiler as an afterburner
Cleanup and recirculation of process airstreams to the plant
area, thus reducing heating and cooling costs
Process boiler afterburner—The VOC airstream is fed to the
process steam boiler. The VOC's are recovered as fuel and need
not be removed from the atmosphere. Afterburner boilers have
been successfully used in meat smokehouses, rendering cookers,
and oil refineries.
Several conditions must be met before using a process steam
boiler as an after-burner.
1. Air contaminants must be combustible. Inorganic dusts
and fumes foul heat transfer surfaces and result in
reduce boiler efficiency.
2. The volume of contaminated gases cannot exceed boiler
air requirements. If it does, combustion will be
incomplete.
3. An adequate flame must be maintained in the boiler
firebox to avoid explosive conditions.
The use of a process boiler to control VOC emissions has
several advantages: (1) low capital investment (2) use of the
boiler as the control device, and (3) fuel savings (if the VOC
stream has heating value).
Several disadvantages are also present: (1) need for a
standby boiler, (2) distance from the source to the boiler,
requiring excess ductwork, and (3) problems from boiler tube and
burner fouling. Caution also must be exercised to avoid explo-
sive conditions.
30
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Cleanup and recirculation of process airstreams—Process
airstreams can be returned to the plant area to save heating or
cooling costs if VOC's can be removed. This control method is
most likely to be appropriate for a high volume airstream with a
Jow VOC concentration because the product desired is the heated
or cooled air. The economic consideration is whether or not
reduced heating or cooling costs will offset the cost of removing
the VOC's.
VOC CONTROL STRATEGIES FOR VOLATILE ORGANIC COMPOUNDS
Undertread Cementing
The model regulation indicates that either incineration or
carbon adsorption can be used to control VOC emissions from
undertread cementing. Two companies use carbon adsorption con-
trols on the undertread cement line. With rising fuel costs and
fuel shortages, carbon adsorption appears to be the most suitable
control measure for undertread cementing. The costs and avail-
ability of fuel for incineration in all probability may make this
option prohibitive.
Bead Cementing
Of the processes used in bead cementing, the model regula-
tion only considers controlling VOC emissions from bead-dipping.
Only 35 percent of the plants use this particular process. The
regulation does not mention bead spraying or bead wiping. At
some plants, bead cementing is not even used. The RACT for this
process can be either incineration or carbon adsorption.
Before controls can be developed for bead dipping, the
operation at each plant must be evaluated for VOC emissions.
Some operations may emit insignificant VOC amounts and thus not
require control measures. According to tire manufacturers, bead
dipping for each day's production is completed in 3 to 4 hours.
Simply covering the dip tanks when they are not in use would
reduce VOC emissions.
31
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Tread-End Cementing
The model regulation shows incineration and carbon adsorp-
tion to be effective VOC control measures for tread-end cement-
ing. Spray application of tread-end cement accounts for about 6
percent of the VOC emissions, or 66 tons/yr from a tire plant.
Hand application is done in 65 percent of the plants and is
believed to reduce emissions up to 75 percent.4 Further study is
needed to assess VOC emissions from each operation and to gather
data comparing VOC emissions during hand application and spray
application of cement.
Green Tire Spraying
In green-tire spraying operations, solvent-based sprays are
being replaced by water-based sprays because of the cost of
organic solvents, the availability of the solvents, and the need
to reduce VOC emissions. Solvent-based sprays are estimated to
account for 38 percent of the organic solvent emissions from tire
plants. Currently 32 percent of the plants use water-based
sprays, which are considered RACT for this process.
FACTORS AFFECTING REGULATION ENFORCEMENT
Enforcement and compliance will follow the adoption of
guideline regulations for the pneumatic tire industry. Problems
will be encountered in determining applicability, required con-
trol efficiency, and compliance; in applying the "bubble con-
cept"; and in meeting compliance schedules.
Determining Applicability
Although PEDCo has had several meetings with industry and
EPA representatives about the sources covered by this regula-
tion, some confusion still exists. We met with representatives
of the Rubber Manufacturers Association (RMA) on March 10, 1980.
At that time they believed that the regulations only applied to
truck and automobile pneumatic tire plants. They did not believe
that the regulations applied to small industrial pneumatic tire
32
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manufacturers. The representatives had just discovered the dis-
cussion on tread rubber manufacturers in the model regulations,
and agreed that this segment of the industry appeared to be
covered. They said that the model regulations were the first
indications that the tread rubber group would be regulated. The
RMA representatives, in .several meetings and discussions with EPA
staff, had never discussed regulation of the tread industry.
We had met previously, on November 20, 1979, with a repre-
sentative of EPA's Office of Air Quality Planning and Standards.
He indicated that pneumatic bicycle tires are not covered by the
regulations even though they qualify by size and by definition of
passenger tires.
The regulations currently cover 94 plants. If the regula-
tions were limited to automobile and small truck tire manufactu-
rers, decisions about applicability would be greatly simplified.
The industrial pneumatic tire plants might be exempt in light of
the clause excluding "irregular basis and short production runs";
however, the state must decide.
Various problems also arise in applying the regulations to
tread rubber manufacturers. Tread rubber is made by two pro-
cesses; cold cap and Orbitread. Only the cold cap process uses
undertread cement at central manufacturing facilities. '
Some large retread plants produce their own tread rubber and
use undertread cementing. These plants were not included in the
PEDCo survey. Although recapping operations are excluded in the
regulations, the undertread cement operations in retread plants
are included.
Determining Required Control Efficiency
When PEDCo first examined the regulations, we were perplexed
at the "up to" capture clauses. Although a goal of 85 percent
capture efficiency is admirable, it is unenforceable in practical
terms. After visiting several plants, we were able to clarify
the capture problems. Each rubber tire plant is so different .
that a uniform capture efficiency cannot be set. In practice,
33
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the capture efficiency for each system will be negotiated on a
case-by-case basis.
Although the "up to" clause was intended to allow individual
variations, the states have not interpreted it as such. Offi-
cials in one state, for example, deciding that the "up to" clause
was unenforceable, specified a 90 percent capture efficiency in
their preliminary regulation. This state regulation is thus even
more stringent than the model regulation because it uses the New
Source Performance Standard (NSPS) capture efficiency (90 per-
cent) rather than the CTG efficiency (up to 85 percent). We
believe that EPA should clarify the policy by stating that cap-
ture efficiency should be determined on a case-by-case basis.
Representatives from RMA indicated that the model regula-
tions for undertread cementing are based on flow rates at the
Goodyear plant in Lawton, Oklahoma. At this new plant, collec-
tion hooding and control equipment were installed with the under-
tread cementing line. Exhaust flow rates are low in comparison
with rates from the various systems that will be.required in
other plants. Therefore, the control costs shown in the CTG are
understated. Another problem in the CTG is the annual operating
period that is used as a basis for calculating cost. Tire plants
operate 250 days per year, not 365. When 365 days is used as the
basis, the RMA believes control costs are understated for each of
the four affected processes.
The RMA representatives emphasized the impact of these model
regulations on older plants. If each plant is evaluated on a
case-by-case basis, however, this problem will be eliminated.
Many older plants are also being closed as sales decline and
radial tires replace conventional tires.
Determining Compliance
Capture Efficiency—
VOC capture efficiency can only be determined by a material
balance. No devices are available for the continuous measurement
of fugitive emissions, waste, cleanup solvents, and the solvents
34
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that are retained in the product. Thus, an inspector cannot
determine the VOC capture efficiency of collection systems in the
field. Initial compliance should be determined via a material
balance in conjunction with a permit application or permit renew-
al. At this stage, the company and the control agency can agree
on estimates of solvent retained in the product and on rate of
solvent evaporation. They can also establish recordkeeping
requirements for solvent usage, recovered solvent, production,
and waste or surplus solvent disposal.
The tire industry maintains records of total solvent pur-
chases. None of the plants that we visited, however, keeps
records of solvent consumption by operation. Because records are
not now being kept, the industry will probably resist a require-
ment to record solvent usage by process application.
Some states cannot use company records to show noncompli-
ance. In California, for example, purchase records are required.
Rubber tire plants buy their solvent in bulk, however, for use in
all operations.
Control Efficiency/Compliance Monitoring—
The efficiency of control equipment can be determined by
measuring the inlet and outlet VOC concentrations during stack
tests. Breakthrough indicators continuously monitor compliance on
carbon adsorbers. The cost ($20,000) of this instrument is
reasonable when compared with the total cost of a large carbon
adsorption system ($250,000). Inlet and outlet temperature
indicators continuously monitor compliance on incinerators.
Although temperature indicators monitor the proper operation of
an incinerator, they are not as effective as the breakthrough
indicator that is required on the carbon adsorber.
The Bubble Concept
In the bubble concept, compliance is based on emissions from
the plant as a whole. Because the regulations cover emissions
from several tire plant operations, the bubble concept will help
35
-------
•the industry to comply. Before the concept can be applied, how-
ever; -the "up to" clause must be clarified. The clause makes it
difficult to allow one source to be overcontrolled so that an-
other can be undercontrolled.
The industry will shift to water-based coatings for use in
green tire spraying. With an incentive, such as these regula-
tions, the industry will also control undertread cementing. For
economic reasons, however, the industry will resist controlling
tread-end cementing and bead dipping. Many tire manufacturers do
not have automatic tread-end cementing or bead dipping opera-
tions. The model tire plant used as a guide in this report is
atypical in many respects. Of the production lines surveyed,
only 35 percent used spraying for tread-end cementing, and 35
percent use bead dipping. When tread-end cementing is performed
manually rather than by spraying, VOC emissions are reduced up to
75 percent.
As a result this technique should be included
within the bubble concept. Bead wiping also reduces VOC emissions
when compared with bead dipping, and should be allowed. After
taking into account these process variations, the application of
the bubble concept to pneumatic tire making.
Compliance Schedules
The rubber tire industry's primary problem in meeting com-
pliance schedules is reformulating the green tire spray. The
longer schedule proposed for heat recovery may be unnecessary.
Formulation Changes—
Tire manufacturers have more product liability problems than
most industries, because tire failures can result in huge person-
al injury lawsuits. This risk causes manufacturers to hesitate
to change processing techniques. Process changes are usually
evaluated in the laboratory and then by road testing under con-
trolled conditions. Testing may take as long as a year.
Tire companies have taken up to 4 years to convert from
solvent-based green tire sprays to water-based sprays. Some
companies have just started the process. The companies may not
36
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complete the process changes, including product testing, within
the 2 years proposed in the model regulations. The EPA should
provide guidance for situations where compliance will be delayed
by formulation changes and product testing. A standard method of
obtaining extensions for formulation changes should be estab-
lished. Partial compliance is also possible when plants are able
to use water-based sprays to a limited extent. Guidelines should
be established for situations where partial compliance is possi-
ble.
Heat Recovery—
The addition of 12 months to the compliance schedule for
incinerators with heat recovery is excessive. The compliance
schedule for incinerators without heat recovery is too short; 18
months is more appropriate. The savings in energy costs will
encourage the use of heat recovery by the few, if any, companies
that choose this option; thus a compliance schedule incentive is
not needed.
37
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SECTION 5
STATUS OF STATE PROGRAMS
STATE AIR CONTROL AGENCIES
PEDCo contacted air quality control agencies in 27 states
and Puerto Rico by telephone. These agencies all have pneumatic
tire and/or tread rubber manufacturing plants within their juris-
dictions. The purpose of the contacts was to determine the
status of state programs for VOC control, to supplement our list
of manufacturers, and to determine potential enforcement prob-
lems .
The agency responses can be grouped into five categories:
A. They have proposed or are proposing specific regula-
tions for the manufacturing of pneumatic tires.
B. They have existing regulations regarding VOC emissions.
C. They-will follow the Federal lead when the situation is
clarified.
D. They are not affected because plants are located in
attainment areas.
E. They have a regulation covering the entire rubber
industry.
Table 5 lists the states that are included in each category. The
categories are not mutually exclusive; two states (North Caroline
and Virginia) appear twice.
California is proposing the following regulations:
1. Undertread cementing and bead dipping would be control-
led by carbon adsorption. Any undertread-cementing
operation emitting less than 200 Ib/day for the entire
facility is exempt. Any bead-dipping operation emit-
ting less than 100 Ib/day for the entire facility is
exempt.
38
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TABLE 5. STATUS OF STATE REGULATION OF VOLATILE ORGANIC
COMPOUND EMISSIONS FROM TIRE AND TREAD RUBBER PLANTS.
Have proposed or are proposing regulations covering the manufacturing of
pneumatic tires:
A.
B.
C.
D.
E.
Illinois
North Carolina
California
Pennsylvania
Ohio .-
Wisconsin
Have regulations covering VOC emission:
Indiana Kentucky North Carolina Virginia
Have no regulations, but will follow the Federal lead:
Alabama Massachusetts South Carolina
Connecticut Michigan Tennessee
Georgia New York Texas
Iowa Oklahoma,
Are not affected because plants are in attainment areas:
Arkansas Maryland Oregon
Kansas "' ' '
Maine
Puerto Rico
Mississippi
Virginia
Has a regulation covering the entire rubber industry:
New Jersey
39
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2. Tread-end cementing would be controlled by hand appli-
cation of cement, with an emissions limit of 200 lb/
day. This limit is equivalent to about 5 grams of VOC
per tire compared, with emissions of about 20 grams per
tire when cement is applied by spray. Any tread-end
cementing operation emitting less than 200 Ib/day for
the entire facility is exempt.
3. Green tire spraying would be controlled by using a
water-based spray that cannot contain more than 3
percent VOC.
4. No controls would be required for the tire-building
process.
5. Sources emitting less than 200 Ib/day would be exempt.
This exemption would apply to all tread rubber plants
in California.
Efforts in other states have been more modest. Pennsylvania
and Ohio have conducted discussions with the tire industry in an
effort to establish workable controls and to have the benefit of
input from the industry, but neither state has yet published
proposed regulations.
Some state air control agencies believe that the pneumatic
tire industry can be controlled under existing VOC regulations. A
blanket regulation requiring 85 percent VOC control meets the
requirements of the CTG. Success in controlling 85 percent of
the VOC emissions depends heavily on the capture efficiency of
the system.
Several state air control agencies with tire plants in
attainment areas feel they do not need VOC regulations for tire
manufacturers. Other state air control agencies will not act
until NSPS regulations become effective and until pending VOC
control lawsuits are settled.
New Jersey regulations cover the entire rubber industry.
The State does not list .any pneumatic tire manufacturing facil-
ities. PEDCo found that the Super Tire Engineering Company
manufactures pneumatic tires, but the company has only 350 em-
ployees as compared with 1000 to 1200 employees for an average
tire plant. Their primary product is solid rubber tires, and
40
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consequently the pneumatic tire production may be low enough to
exempt the company from any proposed regulation. Another com-
pany, the Oliver Tire and Rubber Company, manufactures tread
rubber. That plant may be subject to regulation.
REFERENCES
1. U.S. Environmental Protection Agency. Control of Volatile
Organic Emissions From Manufacture of Pneumatic Rubber
Tires. EPA-450/2-78-030. December 1978.
2. U.S. Department of Health, Education, and Welfare. A Recom-
mended Approach to Recirculation of Exhaust Air. DHEW
(NIOSH) Publication No. 78-124. January 1978.
3. U.S. Environmental Protection Agency. Air Pollution Engi-
neering Manual, Second Edition. AP-40, Chapter 5. May
1973.
4. State of California Air Resources Board. Consideration of a
Control Strategy for Volatile Organic Compound Emissions
from the Manufacture of Pneumatic Rubber Tires. October
1979.
41
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APPENDIX
PNEUMATIC TIRE AND TREAD MANUFACTURERS INVENTORY
The following tables present an inventory of pneumatic tire
and tread rubber plants by EPA region and within each state or
territory. For the reader's convenience, regions, states, and
territories that do not have such plants have been deleted from
the tables.
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TECHNICAL REPORT DATA
(Please read lastruclions on the reverie before completing!
EPA-340/1-80-017
2.
3. RECIPIENT'S ACCESSfOIV NO.
4 TITLE ANDSUBTITLE
RACT Enforceability Aspects for
Pneumatic Tire Manufacturing
6. REPORT DATE
January J98L
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
C. M. Harvey, J. P. Paul,
J. E. Spessard
8. PERFORMING ORGANIZATION REPORT NO.
PN 3570-3-E
9 PERFORMING ORGANIZATION NAME AND ADDRESS
PEDCo Environmental, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-4147
Task No. 122
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Project Officer: John R. Busik
Task Manager: Robert L. King
Pneumatic rubber tires or tread rubber is manufactured by 94 plants located in
the United States and Puerto Rico. Reasonably available control technology (RACT) re-
quirements for the pneumatic rubber tire and tread rubber manufacturers apply to 55
plants located in photochemical oxidant nonattainment areas. The major processing steps
in tire manufacturing are rubber compounding, tread rubber production, cord production,
bead production, tire building, and tire curing and finishing. The following processes
cause volatile organic compound (VOC) emissions from a typical pneumatic tire manufac-
turing plant: green tire spraying with organic-based solvents, undertread cementing,
tire building, tread-end cementing, and bead dipping. Practical VOC control measures
are carbon adsorption and use of water-based spray for green tire spraying. Hand appli-
cation of cement for tread-end cementing may be an acceptable control provided emissions
neet some arbitrary limit. No practical control measure has been found for the emis-
sions from tire building. The potential enforcement problems appear to be determining
the capture efficiency of the VOC collection device, determining compliance, applying
the bubble concept, and meeting compliance schedules. This report provides an inventory
af the pneumatic rubber tire and tread rubber manufacturing plants, an industry process
description, a review of the RACT requirements, and an evaluation of the model regula-
ions to identify enforceability problems.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
COSATI Field/Group
Air Pollution
Rubber Industry
Organic Compounds
RACT
Tires
VOC emissions
13B
11J, 13F
07C
13. DISTRIBUTION STATEMENT
19. SECURITY CLASS {ThisReport;
Unclassified
21. NO. OF PAGES
89
Unlimited
20. SECURITY CLASS (Thispage/
Unclassified
22. PRICE
EPA Form 2220-1 (1-73)
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