EXECUTIVE SUMMARY
TIRE FLOW STUDY
IN THE
TEXAS-MEXICO BORDER
REGION
Produced for
United States Environmental Protection Agency, Region 6
&
North American Development Bank
By
Integrated Environmental Management Services, S.A. de C.V.
Matamoros No. 1443 Poniente, Colonia Maria Luisa,
Monterrey, Nuevo Leon, Mexico. 64040
October 2012

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Disclaimer
Integrated Environmental Management Services, S. A. de C.V.
(IEMS) was retained by the North American Development Bank (NADB)
to conduct the project titled "Tire Flow Study in the Texas-Mexico Border
Region" with the financial support of the United States Environmental
Protection Agency, Region 6 (EPA).
Although this document has been reviewed by NADB and EPA,
assertions and conclusions here contained are from IEMS and do not
necessarily represent NADB's or EPA's policy; they should not be cited
as official NADB or EPA's assertions. Trade names, equipment and
products presented herein do not constitute endorsements from IEMS,
NADB or EPA.

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Tire Flow Study in the Texas-Mexico Border Region
Index
Table of Contents
introduction
1.	Scope of Work
2.	Tire Flow Estimation
3.	Waste Tires Ultimate Disposal Locations
4.	Environmental and Economic Impacts of the Waste Tire Flow From
Texas into Mexico
5.	Comparison between Texan And Mexican Tire Tracking Systems
6.	Waste Tire Management Regulatory Framework
7.	Recommendations Regarding Changes to the Current Texas and
Mexico Waste Tire Policies, Laws, Regulations and Procedures
8.	Recommendations Regarding Potential Markets for Tire-Derived
Products in Mexico
9.	Waste Tires Appropriate Disposal Alternatives
1
9
23
27
47
53
57
67
99
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Tire Flow Study in the Texas-Mexico Border Region
Index
Attachments Index
Attachment	Title
1	Ultimate disposal locations of waste tires that are being transported from
Texas into Mexico.
2	Operation and management procedures of each waste tires accumulation
site of the Mexican side of the Texas-Mexico border area.
3	Ultimate disposal locations map of waste tires being transported from Texas
into Mexico.
4	Waste tire sites display map per Mexican city.
5	Crackdown on Illegal Dumping - Handbook for Local Government.
6	Display map of appropriate tire disposal alternatives identified in the Texas
side of the Texas-Mexico Border Area.
7	Display map of appropriate tire disposal alternatives identified in the Mexican
side of the Texas-Mexico Border Area.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Introduction
Throughout the Texas-Mexico Border Region, a significant number of
scrap tire piles exist containing millions of scrap tires. Scrap tire piles pose
significant environmental and health risks. For instance, if tire piles catch fire, they
can burn for weeks, even months, causing serious air quality problems from dense
smoke and noxious fumes. Also, when this occurs, large amounts of liquid waste
are generated, which can contaminate the soil, as well as ground and surface
waters. Further, these sites are ideal breeding grounds for mosquitoes, rodents, and
other vectors of disease; and increase risks of malaria, dengue fever, West Nile
Virus, and encephalitis. The health risks are especially of concern because of the
proximity of tire piles to communities.
To address this problem, the U.S. and Mexico officials have collaborated
through programs such as the Border 2012 Environmental Program, adopted in
2007. This bi-national program aims to protect public health and the environment in
the U.S.-Mexico border region within 100-kilometer on each side of the international
border. One of the program's key goals is for the two countries to reduce land
contamination along their shared border, including tire piles. The Border 2012
program has helped communities on both sides of the U.S.-Mexico border analyze
environmental problems, such as waste tires, and evaluate potential solutions.
The primary purpose of this study was to conduct a used and waste tire
flow study in the Texas-Mexico Border Region. The study assessed in a
comprehensive manner the current situation of scrap tires in the Texas-Mexico
Border Region and suggests actions to address and attenuate the problem. The
NADB hired Integrated Environmental Management Services S.A. de C.V. (IEMS)
to perform the tasks outlined below to provide the NADB and the EPA with the
information necessary to better understand the nature and logistics of how and
where used and waste tires are being transported and stored along the Texas-
Mexico Border Region.
IEMS developed a methodology to obtain and report information on the
number of used and waste tires that have been transported between Texas and
Mexico from 2005 to date. Data was also collected about locations of existing tire
piles and estimates of the number of the tires that are being sold, reused, and
disposed of in the Texas-Mexico Border Region.
Another component of this study addresses the economic and
environmental aspects of tire flow into the Texas-Mexico Border Region. The
economic considerations include the costs to transport the tires, revenue from the
sale of the tires, costs of disposal of the tires, costs to remediate disposal sites, and
the costs resulting from possible waste tire pile fires.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
An evaluation of the existing regulatory structure used by Texas and
Mexico to manage used tires along the Texas-Mexico Border Region was necessary
to understand the current waste tire management systems.
This included investigating and providing an evaluation of current waste tire
policies, laws, regulations and procedures along the Texas-Mexico Border Region
and making suggestions, if appropriate, for considerations by policy makers.
This Executive Summary includes key information of the study. A full
description of the information here described can be found in the study Full report
and its attachments, including copies of relevant documents, description of
estimations made, and reference data, figures, and images.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Section 1.
Scope of Work
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
1 Scope of Work
The Texas-Mexico border comprises 1,241 miles along the Rio Grande
River and 31 established crossings; 26 of them for vehicles and 5 rail lines.
According to the August 1983 La Paz Agreement on Cooperation for the Protection
and Improvement of the Environment in the Border Area, the "border area" was
defined as a "the area situated 100 kilometers (62.5 miles) on either side of the
inland and maritime boundaries between the Parties".
For this study, I EMS has chosen a different definition of the border area
based on political/administrative divisions (counties on the US side and
municipalities on the Mexican one) rather than distance, to facilitate a clear
boundary and avoid jurisdiction issues between counties or municipalities. Only
those counties and municipalities that make-up the border were chosen as a study
area. There are a total of nineteen (19) counties and twenty-two (22) municipalities
that form the Texas-Mexico border.
This study chose to focus on urban areas because one of the magnets for
used and waste tire flow are population centers due to their potential large
consumption markets, and because the impacts of the tires may be more severe
around larger population centers.
Using the definition of urban area both for the U.S. and Mexico, a total of
fifty two (52) urban areas were located in the bordering counties/municipalities. Of
these, thirty (30) are located around the 26 international crossings, and thus, these
were selected for the study.
In summary a total of thirty (30) urban areas were chosen, 13 on the U.S.
side and 17 on Mexico. The cities chosen depicted in Figure 1.1.
1.1 Methodology
I EMS' methods are divided as follows: 1) desktop work and 2) field work.
Both methods are aimed at acquiring both quantitative and qualitative information;
however, desktop work also includes the analysis of information as required by
NADB's terms of reference (TOR).
Data to be collected includes quantitative and qualitative information; some
of which was estimated based on observations and interviews. There is a clear
distinction on the type of data used so any user can support his assumptions and
projections stated in this project.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Figure 1.1.
Cities Identified in the Texas-Mexico Tire Flow Study
Texas
1.	El Paso
2.	Fabens
3.	Presidio
4.	Del Rio
5.	Eagle Pass
6.	Laredo
7.	Roma
8.	Rio Grande City
9.	La Joya
10.	McAllen
11.	Pharr
12.	Progreso
13.	Brownsville
Mexican States Bordering Texas:
Chihuahua	Coahuila	Nuevo Leori
Tamaulipas
17.	Cd. Acuiia
18.	Piedras
Negras
19.	Nava
20.	Venustiano
Carranza
21. Anahuac
14.	Cd. Juarez
15.	Guadalupe
16.	Ojinaga
22.	Nuevo Laredo
23.	Nueva Cd.
Guerrero
24.	Cd. Miguel
Aleman
25.	Cd. Camargo
26.	Cd. Gustavo
Diaz Ordaz
27.	Reynosa
28.	Cd. Rio Bravo
29.	Nuevo
Progreso
30.	Matamoros
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
	1.2 Desktop Activities	
I EMS envisioned that the use of both desktop-based research and field
data would result in a well-rounded study that offers its users a solid platform that
reflects the day to day reality of the tire issues along the Texas-Mexico border
region.
Desktop-based research consists of the review of available literature
sources, electronic correspondence and/or teleconferencing with key stakeholders
and design of field-research methodology and procedures.
This was done primarily through telephone calls with Mexican municipal
authorities, data base preparation and analysis, consulting written material found in
U.S. and Mexican governmental information sources, recognized industry
associations, public Geographical Information Systems (GIS), news sources, and
related studies in similar regions, among others.
1.2.1 General Information Sources
The general information search dealt with the border region and social,
economical and environmental characteristics including information about new, used
and waste tires and their uses. This information was obtained from U.S. and
Mexican governmental sources, industrial associations from both countries and
complemented by news articles, academic thesis, and information obtained from
telephonic interviews with tire related stakeholders.
1.2.1.1 Historical Research
Historical research focused on tracing the flow of waste tires across the
Texas-Mexico border and with other parts of the world. Sources for this information
include telephone interviews, documents by industrial associations and previous
related studies of the Texas-Mexico border and of regions similar to the study area.
The U.S.-Mexico border area has been in the past the focus of several
environmental studies on the tire movement along and across the border.
These studies were given a careful consideration to generate a
standardized and defensible method for estimating the waste and used tire
generation and demand in order to perform the tasks presented above.
Consulted previous tire flow studies and publications about the Texas-
Mexico border include those of Border 2012, and other conducted researches.
Consultation of previous tire flow related studies and publications about regions
similar to the Texas-Mexico border area covered:
S	California-Mexico border.
S	California.
S	New Mexico.
S	Mexico Federal District.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
S Puerto Rico.
S Continental United States of America.
S The Americas
1.2.1.2 Survey Design and Analysis
Survey design and analysis were done to gather quantitative and semi-
quantitative information regarding used and waste tire management and cross-
border flow, as well as its trends/behaviors. Surveys were designed for the following:
Key stakeholders in Texas
Key stakeholders in Mexico
~
Texas Commission on
~
Ministry of Economy (Secretaria

Environmental Quality

de Economia or SE)
~
Texas State Health Department
~
Federal Institute of Access to
~
Councils of governments.

Information (Instituto Federal de
~
City waste management

Acceso a la Informacion or I FA I)

authorities
~
Tax Administration Service
~
City vector control authorities

(Servicio de Administracion
~
City code enforcement authorities

Tributaria or SAT)
~
Fire department
~
State of Nuevo Leon
~
New tire dealers

Environmental Ministry
~
Used tire dealers
~
Customs administrators
~
Tire haulers
~
Municipal waste management
~
Collection stations

authorities
~
Storage facilities
~
Municipal civil guard authorities
~
Landfill managers
~
Landfill managers
~
Industry associations
~
Processing and recycling facilities
~
Processing and recycling facilities.
~
Industry associations


~
Non-Government Organizations.
These questionnaires were sent via email to all Mexican authorities and
stakeholders in the contact directory and were applied individually during U.S.
fieldwork.
1.2.1.3 Interview Planning
The content and style of the interviews (semi-structured) was developed by
the team leader with the objective to gather all the information required by the
designed surveys and record details that arise during a conversation style approach.
This style was useful during face to face interviews, especially with public
officials. Nevertheless, a structured question-answer approach was implemented
when time-availability was an issue for the interviewee which was generally the case
for business owners and managers as well as for officials interviewed via telephone.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
1.3 Fieldwork Activities
Field-based research consisted of site visits to the thirteen (13) selected
Texas cities plus Austin and Houston as well as a visit to Mexico Federal District for
interviews with industrial association representatives. The information obtained was
both quantitative and qualitative and even though the location of tire piles was
requested, the research focused more on obtaining an estimation of the tire flow
from Texas to Mexico as well as the state of the market in the study area. Also
during one day face to face quotations were obtained from used tire dealers in the
cities of Ciudad Juarez, Reynosa and Matamoros.
1.3.1 Road Reconnaissance
Road reconnaissance trips to the thirteen border cities along the
international crossings with population greater than 2,500 were performed on the
Texas side of the border.
The visits purpose was to identify the location of waste tire piles, reach
relevant stakeholders, and assess the relationships and activities these
stakeholders have with waste tires. The trips were of limited utility in identifying
larger tire piles as required by the TOR, since most of these are located outside the
cities in county back-roads and information on known locations was restricted due to
administrative and legal procedures against dumpsite owners. However the
remaining goals were fulfilled with these visits. Due to security reasons no fieldwork
was performed on the Mexican side of the border.
	1.3.2 Interviews with Key Stakeholders	
On the Texas side of the border 122 (one hundred and twenty two) face to
face interviews were performed to gather the necessary data required to perform the
tasks described above as well as to obtain quantitative and semi-quantitative
information and trends/behaviors regarding used and waste tire management and
cross-border flow. Emphasis was set for medium and small used tire dealers which
represent more than 40% of the interviews.
The largest new and used tire dealers in each of the cities were sought to
obtain estimated numbers from the bigger sellers and decrease the uncertainty gap
of not interviewing a 100% of the dealers. All the U.S. cities identified in this study
had at least one used tire dealer and was interviewed.
Face to face interviews in Mexico were conducted to:
S Waste management authorities of Ciudad Juarez and Matamoros
S Landfill representative of Ciudad Juarez
S ANDELLAC and CNIH representatives.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
During one day face to face used tire price requests were performed in the
Mexican cities of Juarez, Reynosa and Matamoros, yet for security reasons other
cities and further field data in the Mexican side of the Texas-Mexico border was not
requested.
The safety of all the personnel involved with the project was of outmost
importance, especially those conducting field work activities. Following
recommendations by the U.S. Department of State, minimum fieldwork was
conducted on the Mexican side of the border.
Most interviews were sent via e-mail with a formal letter explaining the
purpose of the project and the organizations involved. This because releasing any
type of information represents a potential security threat to the Mexican officials.
Private landfill managers requested an additional letter from the NADB
project's commissioner assuring that I EMS was hired to gather and perform the
present study. It was provided to I EMS from NADB representatives on September
15, 2011 in both English and Spanish.
	1.5 Key Stakeholders	
In order to assess the actual inflow of used and waste tires into Mexico
from Texas a variety of stakeholders was interviewed as detailed in Section 1.2.3.
Authorities and industry associations provided general estimations on the
flow of these tires into Mexico. Tire dealers and haulers provided other details on the
overall tire flow from Texas to Mexico.
All the stakeholders interviewed were asked to sign a permission letter to
be quoted on this project; these letters are kept by I EMS as hard-copy and are
available upon request.
Other stakeholders that have been identified are junkyard owners,
community environmental leaders, and used tire customers.
1.4 Safety
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Section 2.
Tire Flow
Estimation
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
2 Tire Flow Estimation
The movement of tires is presented using a simple diagram depicted on
Figure 2.1., displaying the origin and destiny of tires used in Texas.
Between 2005 and 2011 the tire flow in the U.S.-Mexico border area, or
part of it, had already been mapped in two previous studies. Both studies display
very similar flows to that presented by I EMS with the exception of the addition of the
classification between waste tires and used tires. This classifying process happens
inside the tire merchant and tire transportation facilities (i.e., waste tire generators
and transporters).
Figure 2.1.
Tire flow in the State of Texas
Waste tire generators
Tire merchants
Tire transportation
Large new tire
retailers.
Legal tire haulers
New tire
Small and
medium new and
used tire retailers
	.1
Used tires
retailers
Rogue tire haulers
Used tire users
Recycling and
collection
stations
Retailers classifying
process
. = Used tires
Shredding
or cutting
edded or
cut tires
tdf=Tire
= legal and illegal
used tire flow
Illegal waste tire
dumps.
LRP = Und
Reclamation Projects
Waste tires final disposal
Mexico
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
2.1 Methodology to Estimate Tire Flows
There are primarily three distinct tire flows/movements:
1.	Texas-Mexico.
2.	U.S. -Texas international border.
3.	Third country-Texas international border.
The first flow requires different levels of detailing:
a.	Legal vs. illegal flow
b.	Reuse vs. recycling vs. processing
c.	Proper disposal vs. illegal disposal
2.1.1 Texas-Mexico
2.1.1.1 Legal Used Tire Flow
Used Tires to be Commercialized
The Ministry of Economy (Secretaria de Economia or SE) is in charge of
issuing importation permits for three regions in the U.S. - Mexico border. These
permits are granted annually according to a global used tire import quota to people
or companies dedicated to commercialization of used tires in these areas. The
regions where used tire importation has been authorized and controlled by the SE
are:
1.	The State of Baja California;
2.	The State of Sonora State; and,
3.	Ciudad Juarez, Chihuahua.
Every year the number of authorized used tires for import or used tire
import quota is established by the SE and divided between each of the three
regions. For the purpose of this study the number of used tires legally imported was
based on the quota established at the ports of entry in the region of Ciudad Juarez,
Chihuahua, Mexico.
This is defined as Ciudad Juarez annual used tire import quota. Note that
there is no legal import quota assigned to the rest of the Texas-Mexico border.
Formula 1.
Annual legal
used tire flow
Used tires to be
commercialized -|-
flow
Used tires in	Commercial used tires
annual legal car -|- import from Texas for
imports flow	re-treading
re-treading
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Formula 2.
Used tires to be	__	Ciudad Juarez annual
commercialized flow	~~	used tire import quota.
Used Tire Flow for Legal Annual Car Imports
Formula 3.
Used tires in annual _ Annual legal car	y- Average number
legal car imports flow	imports flow	j\ of tires per car
Commercial Used Tires Import for Retreading
There are a different set of authorizations issued by the SE for the
importation of commercial tires for the sole purpose of retreading in a Mexican
facility. Only registered tire renovation facilities are assigned a used tires import
quota for renovating purposes. Retreading passenger tires although possible is not
economically viable (ANDELLAC, 2011). Without this tire renovating industry the
commercial carriers in Mexico would go bankrupt given the cost of new tires. (CNIH,
Rubber Industry National Chamber, 2011).
Used tires for retreading can be imported into Mexico through any legal port
of entry following the used tire legal import requirements for retreading purposes.
For this purpose the following formula will be applied:
Formula 4.
„	. , ,Used tires imported under legal import
Commercial used tires import for	. . .¦
...	i t	— requirements for retreading purposes
retreading purposes entering from	__ M	_ .. .r . . ,
Texas	through any legal Texas-Mexico point of
entry.
According to what was reported previously used tires to be commercialized
may only be imported from the United States through the Ciudad Juarez, a portion
of Sonora and Baja California border.
Because of this, all used tires legally imported through any point of entry in
the Texas-Mexico border, excepting Ciudad Juarez, will be assumed to be destined
to retreading purposes. Except for the year 2005 when importing used tires for
commercialization was not allowed, this year all used tires imported through the
Texas-Mexico border are assumed to be for retreading purposes.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
2.1.1.2 Illegal Used Tire Flow
The illegal flow of used and waste tires from Texas is a much more
complex issue to estimate. This flow consists of very different streams and each
must be estimated separately to determine the overall illegal flow.
This study is based on information obtained from interviews on both sides
of the border, data from the Tax Administration System (SAT), National Institute of
Geography and Statistics (INEGI), Non Government Organizations, environmental
studies and Mexican states public information, among others.
Information obtained from interviews includes tire-flow estimations from
Mexican industry representatives and final destinations.
It has been assumed that commercialization for profit is the driving force for
the flow of tires. Therefore to estimate the tire flow from Texas into the Texas-
Mexico border area it was assumed that:
Formula 5.
Used tire flow
Formula 6.
Legal used tire flow -|- Illegal used tire flow
Used tire flow is greater than or equal to the theoretical Mexico border
area used tire demand.
Formula 7.
Theoretical
Mexico
border area
used tire
demand
_(
Theoretical Mexico
border area tire demand
Estimate of new tires sold in
Mexico border area
)
Percentage of useful life remaining on a Type 3 used tire
Used tires are classified as follows:
>	Special. Semi new;
>	Type 1. Not toasted or cracked, evenly worn and have 60% of tread
remaining;
>	Type 2. One side is more worn than the other, have 20 to 40% of
remaining tread;
>	Type 3. May be toasted or cracked, have less than 20% of
remaining tread;
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Formula 8.
Estimate of new
tires sold in Mexico
border area
New tires sold
per vehicle in
the state
X
Vehicles in
each
municipality
Formula 9.
New tires sold per
vehicle in the state
New tires sold in the
state
Vehicles in the state
Formula 10 a.
Theoretical
Mexico border
area tire
demand
or
Formula 10 b.
Vehicles in
each
municipality
X
Tires
per car
X
Average annual
mileage per tire
Average endurance of a new tire sold in Mexico
Theoretical Mexico
border area tire
demand
Vehicles in each
municipality
Tires per car
5 years
The reason two different formulas may be applied to estimate the
theoretical Mexico border area tire demand is that tires may degrade more over time
from elements exposure than from tread wear due to friction with the road surface.
Basing tire demand only on degradation due to exposure to the ambient elements
does not consider tires may be discarded earlier than when they are 5 years old, but
neither after this time, yet it provides an estimated number with which stakeholders
may work and compare with other estimations.
Formula 11
Illegal used
tire flow
Theoretical Mexico
border area used
tire demand
Legal used
tire flow
Formula 12.
Vehicles in each
municipality
vehicles
vehicles
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Tire Flow Study in the Texas-Mexico Border Region
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To estimate the number of illegal and American vehicles in the Mexican
border area two different formulas were applied.
Formula 13.
Each car imported into Mexico through any point of entry in the Texas-
Mexico border has at least 4 tires that presumably will eventually be disposed on the
Mexican side of the border. For this reason every imported car through the bridges
in Chihuahua, Coahuila, Nuevo Leon and Tamaulipas will be considered as four
tires.
Based on information from interviews with Mexican industrial associations
most tires do not remain within the border area. The largest markets are the bigger
cities such as Mexico City, Guadalajara, Monterrey, Puebla among others. One of
the industrial associations interviewed estimated that at least 50% of tires that flow
from the US into Mexico leave the border region to be sold further inland.
2.1.1.3 Reuse, Recycling, Raw Material and Energy
After their initial intended use, tires can have a variety of destinations:
reused in vehicles, recycled into alternative uses, processed for use as raw material
for other products, burned to extract energy or disposed on the land.
Literature has some estimation on the proportion of tires that follow these
different paths, and calculations were made using field data.
For the U.S. data are more centrally controlled by the Texas Commission
on Environmental Quality (TCEQ) and those numbers were taken. For Mexico,
some municipalities had information on the amount of tires diverted to landfills and
cement companies supplied data for the energy stream.
The proportion of tires destined for recycling was estimated based on
interviews and news sources; the reused fraction for Mexico is reported by industrial
associations to be minimal. Finally the reused fraction in the Texas side of the
border was requested through interviews with the tire recyclers and processors in
the state.
2.1.1.4 Proper and Illegal Disposal
Proper disposal in the U.S. side of the border is well documented by the
TCEQ although in the City of Presidio there is no option for proper disposal of tires.
Illegal disposal was documented during interviews to local code
enforcement authorities and through the interviews with used and new tire dealers.
Unregistered
vehicles
vehicles
Illegal
+
American
vehicles
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Data on proper/legal disposal in Mexico were obtained from the local
environmental authorities of each municipality. Although not all Mexican
municipalities possess adequate disposal facilities and management procedures,
their storage sites for waste tires for the purposes of this study will be considered
the proper disposal option for those specific regions.
Attachments 1 and 2 display the proper disposal facilities, the approximate
number of waste tires accumulated, location and management procedures in each
of the Mexican municipalities.
2.1.2 Tires from Other U.S. States
The origin of used tires in Texas was obtained through interviews with local
used tire dealers. There are no tire manufacturing facilities within Texas (interview e-
mail with RMA) so all new tires sold or entering the study's scope area is assumed
to originate from one of the other 49 states, Canada, or another foreign country.
The origin of used tires that are being transported through Texas from other
states, which are considered to have the greatest environmental or economic effect
on the Texas-Mexico border based on information obtained through fieldwork on
the Texan side of the border are:
Alabama
California
Denver, Colorado
Atlanta, Georgia
Illinois
Louisiana
Michigan
Minnesota
Missouri
Las Vegas, Nevada
Las Cruces, New Mexico
New York
Cincinnati and Fostoria, Ohio
Pennsylvania
Figure 2.2 represents the states from which used tire dealers obtain their
used tires for commercialization on the U.S. side of the Texas-Mexico border area. It
is assumed that 74% of the used tire dealers on said area acquire their used tires on
Texan cities.
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Figure 2.2.
Used Tires Origin Presented by Used Tire Dealer Interviews
Alabama
1%
California
1%
Colorado
1%
Georgia
1%
Louisiana
1%
Illinois
Missouri
3%
Ohio
3%
Minnesota
1%
Michigan
1%
New Mexico
1%
Nevada
1%
Pennsylvania
1%
A used tire dealer that obtains used tires from Texas may also acquire used
tires from other states. The number of used tires brought to Texas from other parts
of the U.S. is yet to be assessed.
No data regarding the number of used tires arriving to the Texas-Mexico
border region from other American states was obtained during fieldwork or desktop
interviews and activities reason for which it was not possible for I EMS to estimate
the number of tires that are being transported through Texas from other states,
which may have either an environmental or economic effect on the Texas-Mexico
Border.
2.1.3 Third Country-Texas-Texas Border
Information on out-of-U.S. origins of used tires was obtained during the
Texas interviews. The only third country mentioned, by only 1 of the interviewees,
was Canada.
No data regarding the number of used tires arriving to the Texas-Mexico
border region from other countries was obtained during fieldwork or desktop
interviews and activities. Because of this, it was not possible for I EMS to estimate
the number of tires that are being transported to the Texas-Mexico Border Region
from countries outside the United States.
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Tire Flow Study in the Texas-Mexico Border Region
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2.2 Estimations and Results
The following includes the results of the use of information obtained from
different stakeholders across Texas and Mexico and the application of the
previously described formulas and criteria.
2.2.1 Legal Used Tires Flow
2.2.1.1 Ciudad Juarez Annual Used Tire Import Quota
The following table was created by applying Formula 2, employing data
obtained from the Economy Ministry through IFAI.
Table 2.1
Ciudad Juarez, Chihuahua
Annual Used Tire Import Quota
Year
Used tires legally imported per year
2005
0
2006
340,000
2007
340,000
2008
340,000
2009
340,000
2010
191,100
2011
198,400
Total
1,749,500
2.2.1.2 Used Tires in Annual Legal Car Imports Flow
Table 2.2 presents the results from applying Formula 3 employing data
obtained from the Tax Administration System (SAT) commercial imports balance
report.
2.2.1.3 Commercial Used Tire Import for Retreading
Table 2.3 presents the results from applying Formula 4 employing data
obtained from the Tributary Administration System (SAT) commercial imports
balance report.


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Tire Flow Study in the Texas-Mexico Border Region
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Table 2.2.
Used Tires Flow for Annual Lec
al Car Imports
Imported vehicles each year per scope state (Vehicles)
Annual
legal car
imports
flow (cars)
Average
number of
tires per car
(used
tires/car)
Used tires in
car imports flow
(used tires)
Year
Chihuahua
Coahuila
Nuevo
Leon
Tamaulipas
2005
58,482
16,074
26,183
144,701
245.440
4
981,760
2006
202,076
46,702
101,275
521,855
871.908
4
3,487,632
2007
132,624
28,375
14,351
628,889
804,239
4
3,216,956
2008
73,993
15,254
532
422,761
512,540
4
2,050,160
2009
42,805
10,338
1,346
163,496
217,985
4
871,940
2010
91,073
10,665
1,976
205,615
309,329
4
1,237,316
2011*
68,543
8,965
9,960
151,056
238,524
4
1,602,692
Total
669,596
136,373
155,623
2,238,373
3.199.965
4
13.448.456
Information obtained until August 2011. Used tires in car imports flow data for year 2011 was linearly extrapolated
from imports on years 2009 and 2010.
Table 2.3.
Import for retreading flow entering from Texas
Year
Used tires import for retreading
20051
168,457
2006
219,399
2007
274,036
2008
276,619
2009
299,073
20102
343,052
20112
374,898
Total2
1,955,534
Estimated by adding all used tire legal imports through the Texas-
Mexico border including the Ciudad Juarez border since no legal import
quota existed in 2005 for this area.
2From June 2010 to December 2011 import data was obtained through
a linear extrapolation with a R2 of 0.901
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Tire Flow Study in the Texas-Mexico Border Region
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From the information presented on Tables 2.1 thru 2.3, the legal flow of
used tires from 2005 to 2011 is estimated on:
17,153,490 tires units
Figure 2.3 depicts the distribution of this flow. Used tires mounted on
imported vehicles represent almost 80% of the legal used tires import flow.
Figure 2.3
Legal used tire import flows through the Texas-Mexico border
~	Ciudad Juarez annual used tire import quota
~	Used tires in annual legal car imports flow
~	Commercial used tires import for retreading entering from Texas.
2.2.2 Illegal Used Tire Flow
The results of applying the formulas to estimate the illegal flow of used tires
resulted on a negative value. This value should not be interpreted as a negative flow
of used tires back into Texas; it should be interpreted as a sign that the current used
tire imports could theoretically supply the Mexican scope border region used tire
demand.
Actually the legal used tire flow could theoretically supply more than two
times the estimated used tire demand of the Texas-Mexico border region as the
table above displays.
Assessing the reason for this surplus in used tire offer crossing the Texas-
Mexico border is not part of this study scope and will not be further addressed. Yet it
is important to note that the National Rubber Industry Chamber (Camara Nacional
de la Industria Hulera or CNIH) associates have detected used tire shipments in
large Mexican cities further south of the border such as Guadalajara and the Federal
District.
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Based on the fact that both fieldwork and desktop interviews with key
stakeholders report the existence of an illegal flow of used tires from Texas into
Mexico it would be safe to imply that a demand larger than the one of the border
area is being supplied by both legal and illegal used tire flows.
As a general conclusion the results obtained from estimating the illegal
used tire flow from Texas into Mexico based only on the Mexican border region
demand greatly underestimates the actual illegal used tire flow.
2.2.3 Theoretical Mexico Border Area Used Tire Demand
From the application of Formula 7, the theoretical Mexico Border Area
used tired demand resulted in the information presented in Table 2.4.
Table 2.4.
Theoretical Mexico border area used tire demand
Year
Theoretical Mexico border area
used tire demand
(used tires)
2005
913,904
2006
1,431,049
2007
847,033
2008
997,133
2009
1,227,711
2010
1,396,641
2011
1,576,431
TOTAL
8,389,903
Additional results and estimations made during the study are presented in
the study Full Report.
	2.2.4 Reuse, Recycling & Processing	
No relevant information regarding tires sold for reuse, recycling or for other
tire derived products in the Texas-Mexico border region was reported or provided by
any interviewed stakeholder. For this reason no estimations regarding this subject
were made in this report.
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2.2.5 Proper Disposal vs. Illegal Disposal
2.2.5.1 Proper Disposal
Attachments 1 and 2 display the proper disposal facilities, the approximate
number of waste tires accumulated, location and management procedures in each
of the Mexican scope municipalities.
2.2.5.2 Illegally Disposed
No conclusive data regarding illegal waste tire disposal was obtained from
the interviewed Mexican stakeholders. Attachment 3 presents a map with potential
illegal tire disposal locations on the Mexican side of the Texas-Mexico border region.
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23
Section 3.
Waste Tires
Ultimate Disposal
Locations
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	3 Waste Tires Ultimate Disposal Locations	
I EMS created a geo-referenced directory and display map of known
ultimate disposal locations of waste tires that are being transported from Texas into
Mexico. Their operation, who is responsible for them, their management procedures,
number of waste tires accumulated and display maps.
Also I EMS presents the Mexican cities of the Region geo referenced list of
possible waste tire generators, possible illegal tire piles and a display map for each
city.
	3.1 Disposal Locations	
I EMS envisioned that the use of both desktop-based research and field
data would result in a well-rounded study that offers its users a solid platform that
reflects the day to day reality of the tire issues along the Texas-Mexico border
region.
Desktop-based research consisted on the review of available literature
sources, online regional periodic publications, electronic correspondence and/or
teleconferencing with key stakeholders.
This was done primarily through telephone calls with Mexican municipal
authorities and key stakeholders, data base preparation and analysis, consulting
written material found in U.S. and Mexican governmental information sources,
recognized industry associations, public Geographical Information Systems, news
sources, and related studies in the region, among others.
Location of waste tire dumps sites was assessed through directions
obtained from stakeholders interviewed, the border tire network tire pile database
and online periodic news sources that described the location settings and/or
surroundings.
The areas geographical coordinates were obtained using public
Geographical Information Systems (GIS), primarily the Google™ Earth software, by
visually searching the sites following the directions given by the sources mentioned
on the paragraph above.
No fieldwork was performed on the Mexican side of the Region due to
security reasons. No confirmation visits, using Geographical Positioning Systems
(GPS) devices or what was observed through GIS were performed in order to verify
the accuracy of the data obtained from the sources. Nevertheless only sites that
were visually consistent to what was described by the Mexican stakeholders were
selected as dump sites.
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Instead a visual search of junkyards and used vehicle lots in the Mexican
cities using public GIS was performed in order to assess the possible location of
waste tire generators and potential tire pile sites; this methodology is further
explained in this document.
I EMS employed desktop-based research which consisted on the review of
available literature sources, online regional periodic publications and electronic
correspondence and/or teleconferencing with key stakeholders. The location of
waste tires piles along the Texas-Mexico region had been the focus of the following
publications:
>	Border 2012: U.S.-Mexico Border Scrap Tire Inventory Summary
Report. (United States Environmental Protection Agency (EPA),
2007)
>	Border Tire Network, Tire Pile Information (Border 2012, 2011)
The tire pile sites reported in above mentioned documents were used as a
base for which the report objectives were constructed.
I EMS also performed a visual search of junkyards of all sizes and used car
lots on the Mexican cities of the Region to assess the potential final destination of
the used and waste tires mounted on imported vehicles from Texas into Mexico.
From all the information gathered, display maps with the identified locations
of possible junkyards, possible illegal tire piles, and the piles, were prepared and are
presented for each of the Mexican cities under the scope of the study in
Attachment 4.
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27
Section 4.
Environmental and
Economic Impacts
of the Waste
Flow from Texas
into Mexico
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
4 Environmental and Economic Impacts of the Waste
Tire Flow from Texas into Mexico	
For the estimation of environmental an economic impacts related to the
scope of work, several considerations and assumption were made. These
considerations are described in full in Chapter 4 of the study Full report.
	4.1 Revenue from the Sale of Used Tires to Mexico
I EMS estimated a revenue range, rather than a single number, of what the
revenues may have been in any determined period of time between January 2005
and April 2012. As presented on Figure 4.1.
Figure 4.1
Lowest (blue) and Highest (red) estimated revenue per tire


Range In which the revenue per tire per year is
located



(US dollars / used tire)






200* 2005 2006 200? 20
S35J90 	
530 00 Q V
06 200$
2010
l!0ll
2012 2015
'B
k—
s
T3
m
*
3
525 00
520 00










c











m
O
CO
3
S15 00
$1Q IX)











55 00










S0.00
-0--3*est

iSi







Table 4.1.
Highest revenue per tire per year
(US dollars / used tire)
Rim size
R 13
R 14
R 15
R 16
Highest net revenue
(US dollars / used tire)
Remaining
tread / year
20%-40%
20%-40%
20%-40%
20%-40%
2005
$2.95
$10.86
$12.15
$3.25
$29.21
2006
$2.95
$10.84
$12.12
$3.24
$29.15
2007
$2.88
$10.60
$11.86
$3.17
$28.52
iJOL) (Aj <9
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Table 4.1.
Highest revenue per tire per year
(US dollars / used tire)
Rim size
R 13
R 14
R 15
R 16
Highest net revenue
(US dollars / used tire)
Remaining
tread / year
20%-40%
20%-40%
20%-40%
20%-40%
2008
$3.10
$11.40
$12.75
$3.41
$30.66
2009
$2.44
$8.98
$10.04
$2.69
$24.14
2010
$2.53
$9.30
$10.40
$2.78
$25.01
2011
$2.67
$9.83
$10.99
$2.94
$26.44
2012
$2.43
$8.95
$10.01
$2.68
$24.08
Table 4.2.
Lowest revenue per tire per year
(US dollars / used tire)
Rim size
R 13
R 14
R 15
R 16
Lowest revenue (US
dollars / used tire)
Remaining tread /
year
0-20%
0-20%
0-20%
0-20%
2005
$0.86
$3.13
$3.58
$0.98
$8.55
2006
$0.86
$3.11
$3.56
$0.97
$8.49
2007
$0.87
$3.17
$3.62
$0.99
$8.66
2008
$0.71
$2.57
$2.93
$0.80
$7.01
2009
$0.64
$2.33
$2.66
$0.72
$6.35
2010
$0.75
$2.71
$3.10
$0.84
$7.40
2011
$0.69
$2.51
$2.87
$0.78
$6.85
2012
$0.71
$2.56
$2.93
$0.80
$7.00
Table 4.3.
Mexican's specific rim size preference when buying used
tires (percentage)
Rim size /
municipality
Rim 13
Rim 14
Rim 15
Rim 16
Juarez
17%
44%
33%
6%
Reynosa
10%
30%
40%
20%
Matamoros
8%
42%
42%
8%
Geometric
mean
11%
38%
38%
10%
error	3%
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Table 4.4.
Highest mean revenue per rim size of used tire in the
2005-2012 period in representative Mexican scope cities
(US dollars / used tire)
Rim size
R 13
R 14
R 15
R 16
Remaining tread /
year
20%-40%
20%-40%
20%-40%
20%-40%
2005
$26.45
$28.47
$31.84
$33.34
2006
$26.40
$28.41
$31.77
$33.28
2007
$25.82
$27.79
$31.08
$32.55
2008
$27.76
$29.88
$33.41
$35.00
2009
$21.86
$23.53
$26.31
$27.55
2010
$22.65
$24.38
$27.26
$28.55
2011
$23.94
$25.77
$28.81
$30.18
2012
$21.80
$23.46
$26.24
$27.48
Table 4.5.
Lowest mean revenue per rim size of used tire in the
2005-2012 period in representative Mexican scope cities
(US dollars / used tire)
Rim size
R 13
R 14
R 15
R 16
Remaining tread
/ year
0-20%
0-20%
0-20%
0-20%
2005
$7.74
$8.21
$9.38
$10.01
2006
$ 7.68
$ 8.16
$ 9.32
$ 9.94
2007
$ 7.83
$ 8.31
$ 9.50
$ 10.13
2008
$ 6.34
$ 6.73
$ 7.69
$ 8.20
2009
$ 5.74
$ 6.09
$6.96
$ 7.43
2010
$ 6.69
$ 7.10
$ 8.12
$ 8.66
2011
$ 6.19
$ 6.57
$ 7.51
$ 8.02
2012
$ 6.33
$ 6.72
$ 7.68
$ 8.19
Table 4.6.
Minimum mean revenue per tire in a specific Mexican city
(Mexican pesos / used tire)
Rim size
R 13
R 14
R 15
R 16
R 17
Remaining tread /municipality
0-20%
0-20%
0-20%
0-20%
0-20%
Juarez
$123
$130
$141
$196
$205
Reynosa
$77
$77
$85
$85
$98
Matamoros
$72
$82
$102
$89
$92
Lowest mean revenue per tire in Mexican
scope cities i (Mexican pesos / used tire)
$88
$94
$107
$114
$123
I EHS
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Table 4.7.
Highest mean revenue per tire in Mexican scope cities
(Mexican pesos / used tire)
Rim size
Rim 13
Rim 14
Rim 15
Rim 16
No.
Remaining tread
/ Municipality
20%-40%
20%-40%
20%-40%
20%-40%
1
Juarez
$355
$346
$382
$452
2
Reynosa
$248
$265
$279
$297
3
Matamoros
$237
$284
$342
$312
Highest mean revenue per tire in
Mexican scope cities
(Mexican pesos /used tire)
$275.33
$296.36
$331.40
$347.10
Table 4.8.
Mean retail price in Mexican representative scope
(Mexican pesos / used tire)
Rim size
R 13
R 14
R 15
R 16
R 17
No.
Remaining
tread
/Municipality
1 0s
O O
CM
20%-
40%
1 0s
o o
CM
20%-
40%
1 0s
o o
CM
20%-
40%
1 0s
o o
CM
20%-
40%
1 0s
O O
CM
20%-
40%
1
Juarez
$203
$355
$215
$346
$233
$382
$325
$452
$339
$466
2
Reynosa
$111
$248
$111
$265
$122
$279
$122
$297
$141
$339
3
Matamoros
$96
$237
$108
$284
$135
$342
$118
$312
$122
$331
Mean retail price in
Mexican representative
scope cities1
(Mexican pesos / used
tire)
$129
$275
$137
$296
$157
$331
$167
$347
$180
$374
4.2 Disposal Cost per Tire in Texas and Mexico
Border Region	
Contrary to the Mexican side of the border in Texas private disposal
companies as well as local authorities are the ones in charge of the collection and
disposal of waste tires. The price charged to a waste tire generator depends on
confidential agreements between each waste tire management company and each
generator. Prices charged by public landfills and collection centers are fixed. Large
new tire retailers have corporate agreements with a single authorized hauler which
provides the waste tire collection service in all of their stores and information
regarding the cost per tire is kept confidential by both parties.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Although private companies are seldom involved, in the Mexican side of the
border Municipal authorities are the ones in charge of the waste tire storage and
disposal sites, specifically the Ecology and/or municipal services departments. Only
Ciudad Juarez declares a disposal cost for waste tires.
4.3 Potential Cost to Clean up Significant Tire Piles
in the Texas-Mexico Border Region	
Activities such as fire prevention, fumigation and volume diminishing should
be addressed by each stakeholder depending on his own criteria.
The transportation costs to the closest appropriate disposal sites are
presented on Table 4.9 based on quotations obtained from trucking companies:
Table 4.9
Estimated transportation costs to closest appropriate disposal sites
Id
#
Destination1
Accumulated
waste tires
(tires)
Equip.
State of
tire
Estimated
number
of travels
Cost
per
travel
Total
Transportation
Cost (USD)
Disposal
Site
City
1
CEMEX
Plant
Monterrey,
NL.
2,500,000
Truck
Whole
1667
$ 829.07
$ 1,382,067.86
Train
Whole
1008
$1,480.00
$ 1,491,840.00
Truck
Cut/Shred
1042
$ 829.07
$ 863,896.05
Train
Shred
323
$1,480.00
$ 478,040.00
35
GCC Plant
Samalayuca
Chih
2,500,000
Truck
Whole
—
—
$ 0.00
Train
Whole
—
—
$ 0.00
Truck
Cut/Shred
—
—
$ 0.00
Train
Shred
—
—
$ 0.00
3
CEMEX
Plant
Monterrey,
NL.
550,000
Truck
Whole
367
$ 350.00
$ 128,450.00
Train
Whole
222
$1,272.92
$ 282,587.50
Truck
Cut/Shred
230
$ 350.00
$ 80,500.00
Train
Shred
71
$1,272.92
$ 90,377.08
36
CEMEX
Plant
Monterrey,
NL.
400,000
Truck
Whole
267
$ 829.07
$ 221,363.00
Train
Whole
162
$1,480.00
$ 239,760.00
Truck
Cut/Shred
167
$ 829.07
$ 138,455.51
Train
Shred
52
$1,480.00
$ 76,960.00
31
Landfill2
Acuna,
Coah.
200,000
Truck
Whole
—
—
$ 0.00
Train
Whole
—
—
$ 0.00
Truck
Cut/Shred
—
—
$ 0.00
Train
Shred
—
—
$ 0.00
32
Landfill2
Piedras
Negras,
Coah
115,500
Truck
Whole
—
—
$ 0.00
Train
Whole
—
—
$ 0.00
Truck
Cut/Shred
—
—
$ 0.00
Train
Shred
—
—
$ 0.00
8
CEMEX
Plant
Monterrey,
NL.
100,000
Truck
Whole
67
$ 350.00
$ 23,450.00
Train
Whole
41
$1,272.92
$ 52,189.58
Truck
Cut/Shred
42
$ 350.00
$ 14,700.00
Train
Shred
13
$1,272.92
$ 16,547.92
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33
Table 4.9
Estimated transportation costs to closest appropriate disposal sites
Id
#
Destination1
Accumulated
waste tires
(tires)
Equip.
State of
tire
Estimated
number
of travels
Cost
per
travel
Total
Transportation
Cost (USD)
Disposal
Site
City
4
CEMEX
Plant
Monterrey,
NL.
50,000
Truck
Whole
34
$ 350.00
$ 11,900.00
Train
Whole
21
$1,272.92
$ 26,731.25
Truck
Cut/Shred
21
$ 350.00
$ 7,350.00
Train
Shred
7
$1,272.92
$ 8,910.42
34
APASCO
Plant
Ramos
Arizpe,
Coah.
50,000
Truck
Whole
34
$1,959.63
$ 66,627.47
Train
Whole
—
—
—
Truck
Cut/Shred
21
$1,959.63
$ 41,152.26
Train
Shred
—
—
—
2
CEMEX
Plant
Monterrey,
NL.
32,000
Truck
Whole
22
—
—
Train
Whole
13
$1,329.33
$ 17,281.23
Truck
Cut/Shred
—
—
—
Train
Shred
5
$1,329.33
$ 6,646.63
15
CEMEX
Plant
Monterrey,
NL.
13,000
Truck
Whole
9
—
—
Train
Whole
6
$1,160.13
$ 6,960.80
Truck
Cut/Shred
—
—
—
Train
Shred
2
$1,160.13
$ 2,320.27
12
CEMEX
Plant
Monterrey,
NL.
3,000
Truck
Whole
2
—
—
Train
Whole
2
$1,115.02
$ 2,230.03
Truck
Cut/Shred
2
—
—
Train
Shred
1
$1,115.02
$ 1,115.02
7
CEMEX
Plant
Monterrey,
NL.
1,000
Truck
Whole
1
$ 350.00
$ 350.00
Train
Whole
1
$1,272.92
$ 1,272.92
Truck
Cut/Shred
1
$ 350.00
$ 350.00
Train
Shred
1
$1,272.92
$ 1,272.92
33
APASCO
Plant
Ramos
Arizpe,
Coah.
1,000
Truck
Whole
1
$ 565.28
$ 565.28
Train
Whole
1
$6,757.26
$ 6,757.26
Truck
Cut/Shred
1
$ 565.28
$ 565.28
Train
Shred
1
$6,757.26
$ 6,757.26
11
CEMEX
Plant
Monterrey,
NL.
800
Truck
Whole
1
—
—
Train
Whole
1
$1,115.02
$ 1,115.02
Truck
Cut/Shred
1
—
—
Train
Shred
1
$1,115.02
$ 1,115.02
* Means data was not confirmed with a key stakeholder, it is presented as it was obtained from previous tire pile inventories.
Tire sites 16 to 30 are not located within the study's selected search area but are located within 100km from the Texas-Mexico border.
The information presented on this Table was obtained through remote interviews with the key stakeholders.
Nuevo Laredo tire pile was cleaned up during the writeup of this Report according to the remote interview applied to the municipal
Environment and Climate Change Coordinator on April 20, 2012.
Prices in red are subject to KCSM FSC
Prices in blue are subject to negotiations with Ferromex
Prices don't include VAT.
1 Disposal sites selected according to cheaper transportation cost.
2 Transportation costs for Acuna, Juarez and Piedras Negras are not considered due to landfill being in the same city.
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Tire Flow Study in the Texas-Mexico Border Region
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4.4 Current Potential Cost to Extinguish Fires and
Remediate Environmental, Public Health, and Economic
Impacts Should Any of the Major Tire Piles in the Region
Set Ablaze	
	4.4.1 Cost to Extinguish Fires in the Texas-Mexico Border Area
The Table 4.10. represents an abstract of the responses given for Mexican
civil guard; the personnel cost was obtained considering Mexican minimum wage as
$4.77 (US dollars) for 8 hours, the salary per hour is about $0.59 USD.
Table 4.10.
Summary of Resources to extinguish fires given by Mexican civil guard
City
State
Number of
tire fires
attended
since 2005
Resources to extinguish fires
Time
Personnel
Personnel
Cost
(USDf
Extinguishing
agents
Ojinaga
Chihuahua
....
1.5 to 2 h
....
....
Water / Foam
Nava
Coahuila
90
1 to 3 h
5
$3-9
Water / Foam
Acuna
Coahuila
210
20 min to
1 h
....
....
Water / Foam
Piedras
Negras
Coahuila
....
1 to 2 h
3
$1.8-3.6
Water / Foam
Anahuac
Nuevo
Leon
Rarely
0.5 to 1 h
3
GO
i
Water / Foam
Nuevo Laredo
Tamaulipas
Rarely
....
....
....
Water / Foam
Guerrero
Tamaulipas
72
12 to 24
h
6
$43- 85.8
Water / Foam
Gustavo Diaz
Ordaz
Tamaulipas
300
....
6
....
Water / Foam
Rio Bravo
Tamaulipas
Frequently
20 to 30
min
3
$1
Water / Foam
h Personnel cost was estimated as follow: Number of personnel x salary per hour x Time
According to interviewees, the estimate personnel cost is considered $35
USD per hour per person and $75 USD per hour to estimate de extinguishing
agents cost; although a global cost was given.


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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Table 4.11.
Summary of Resources to extinguish fires given by Texas firefighting agency
City
Number
of tire
fires
attende
d since
2005
Resources to extinguish fires
Time
Number
of
Personn
el
Personn
el Cost
(USD)
Extinguishing
agents
Extinguishin
g agents
cost (USD)
Brownsville
6
6 to 8 h
18
$4000 to
$5000
4 Engines and 3000
gall of water
$450 to 600
Laredo
30
45 min
to 1 h
4
$90 to 140 +
Water / Foam
$50 to 75 *
Mc Allen
18
—
—
—
Water / Foam
$2,500 to 6,000
Rio Grande
72
—
15
—
90 gall of foam and 700
gall of water
$10,000 to
12,000
Del Rio
One in the
landfill
—
—
—
Water / Foam
$6,000 to 7,000
Eagle Pass
120
20 min
to 2 h
6
$70 to 420 +
15 gall of foam and 2
engines
$25 to 150*
+ Personnel cost was estimated as follow:
" Extinguishing agents cost was estimated
Number of personnel x salary per hour x Time
as follow: Cost for extinguishing agents per hour x Time
4.4.2 Public Health Impacts Remediation Costs
4.4.2.1 Pyrolytic Oil and Ash
In order to identify the best remediation techniques and their estimated
costs I EMS consulted the US Federal Remediation Technologies Roundtable
(FRTR) Table 3-2 Remediation Technologies Screening Matrix and Reference
Guide and selected the following remediation options:
In Situ Biological Treatment: Phytoremediation
"Phytoremediation is a process that uses plants to remove, transfer,
stabilize, and destroy contaminants in soil and sediment. Contaminants may be
either organic or inorganic." (FRTR)
Table 4.12.



FRTR reported remediation costs estimates for Phytoremediation
(US dollars)



RACER PARAMETERS
Small site
Large site
Easy
Difficult
Easy
Difficult
Cost per cubic foot
$18
$66
$4
$14
Cost per cubic meter
$626
$2,322
$147
$483
RACER means Remedial Action Cost Engineering Requirements
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Tire Flow Study in the Texas-Mexico Border Region
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Ex situ Physical/Chemical Treatment (assuming excavation):
Chemical Oxidation
"Reduction/oxidation chemically converts hazardous contaminants to non-
hazardous or less toxic compounds that are more stable, less mobile, and/or inert.
The oxidizing agents most commonly used are ozone, hydrogen peroxide,
hypochlorites, chlorine, and chlorine dioxide." (FRTR)
"Estimated costs range from $190 to $660 per cubic meter ($150 to $500
per cubic yard)." (FRTR)
Excavation, Retrieval & Offsite disposal
"Contaminated material is removed and transported to permitted off-site
treatment and disposal facilities. Pretreatment may be required." (FRTR)
Cost estimates for excavation and disposal range from $300 to $510 per
metric ton ($270 to $460 per ton) depending on the nature of hazardous materials
and methods of excavation. These estimates include excavation/removal,
transportation, and disposal at a permitted facility. Additional cost of treatment at
disposal facility may also be required. (FRTR)
4.5 History of Known Environmental Health Hazards
Associated with past or Current Waste Tire Piles Located in
Regions with Ecosystems Similar to the Texas-Mexico
Border Region	
Over the past decade American used vehicles imports, explosive
population growth and a steady demand for used American tires in Mexico have
contributed to the proliferation of scrap tires on the Texas-Mexico border.
Most of the major border cities host piles containing from tens of thousands
to millions of tires, and a few of the largest cities are home to piles ten times as
large. Tire piles, legal or illegal, pose at least two health threats: pests and fire.
Tire piles easily accumulate rain and organic matter transported by wind
and, therefore, become ideal incubators for mosquito larvae. As leaf litter decays,
the microorganisms that grow on it serve as food for the mosquito larvae.
Furthermore, tires absorb heat, which helps accelerate the larval growth.
Tire piles have also been identified as breeding ground for vermin (rodents
and other pests) due to the combined presence of water, heat, and shade.
(Secretaria de Medio Ambiente, 2002).
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Tire Flow Study in the Texas-Mexico Border Region
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Mosquito-borne diseases include Dengue, encephalitis, malaria, and yellow
fever. (Moore & Mitchell, 1997). Globally, Dengue is currently the most important of
all vector-borne viral diseases in terms of human morbidity and mortality, with Aedes
aegypti and Aedes albopictus, the mosquito vector for the Dengue viruses, found in
more than 100 tropical countries (Cortez Florez, 2001). In areas where Ae. aegypti
is abundant, this species might be expected to play a far more important role in
Dengue transmission than Ae. albopictus (Moore & Mitchell, 1997).
Dengue can produce a spectrum of clinical illness, ranging from a
nonspecific viral syndrome to severe and fatal hemorrhagic disease. Although
Dengue fever is not usually fatal, Dengue hemorrhagic fever (DHF) and Dengue
shock syndrome can be. On average, 5% of hospitalized cases result in death. The
majority of fatalities occur among children younger than 15 years (Lloyd, 2003).
In 2002, the Department of Health Services' Vector-Borne Disease Section
identified five discarded truck tires, one of which yielded seven Aedes albopictus
larvae after being tested. The Aedes albopictus, was initially detected in 2001 in
Los Angeles and Long Beach, according to a 2003 Department of Health Services
report. The most immediate concern in California, however, is the potential role of
waste tires in the spread of the West Nile Virus. According to the Department of
Health Services, this mosquito-borne disease reached the United States in 1999
and has since spread to 48 states.
In 2004, it had been detected in 56 of California's 58 counties with nearly
600 identified cases of persons afflicted by the disease. In 2008, 35 cases of West
Nile Virus were reported for San Diego County alone. Fortunately, the arid
conditions of California lower the risk of adequate mosquito habitat in tire piles in the
region.
However, a year with more precipitation or development of tire piles in
locations where they would trap water from stormwater runoff would be a matter of
concern (Reyes Tomassini, 2009).
Tire piles are typically high-priority targets of efforts to prevent or slow
outbreaks of mosquito-borne diseases. Unfortunately, treating them with insecticides
is problematic. It is difficult to penetrate tire piles to the depths where mosquitoes
breed.
Also, mosquitoes are developing resistance to many widely used
insecticides. Finally, insecticides used to suppress adult mosquitoes are
environmentally hazardous, and those used to suppress larvae are costly. Thus,
mitigating mosquito-borne diseases may require completely removing tire piles
(Blackman & Palma, 2002).
Tire piles also pose a major environmental threat given their risk of burning.
Tire piles burn intensely due to their high per-pound heat output.

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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
For example, the energy content of tires is 14,000-15,000 British thermal
units (BTUs) per pound, as compared to 8,000-12,000 per pound of coal (California
Integrated Waste Managment Board, 2009).
The environmental impact of tire fires ranges from moderate to severe
effects on air, water, and soil pollution. Tires do not combust completely and, as a
result, produce both conventional air pollutants and hazardous air pollutants; along
with solid and liquid waste.
Tire fire smoke contains irritating chemicals, particulate matter, and
carcinogens. A 1997 USEPA report indicated that tire fire emissions are significantly
more toxic than emissions from coal-fired utilities with pollution controls.
Identified health effects from exposure to such compounds include irritation
of mucous membranes (eye, nose, and throat), exacerbation of asthma symptoms
and respiratory conditions, and potential exacerbation of preexisting heart disease
(California Integrated Waste Managment Board, 2009).
Tire fires also cause water and land contamination. A standard automobile
tire generates about two gallons of oil when burning and liquefying.
The burning of large tire piles, then, could potentially result in the leaching
of large amounts of toxic oil into the soil and possibly into the aquifers.
If soil becomes contaminated with oil, its microbiological quality is reduced
and plant growth is depressed, diminishing the health and productive capacity of the
land.
Remediation is generally difficult, and the sites of many tire fires have been
designated as hazardous waste cleanup sites (Blackman & Palma, 2002).
An example of the potential extent of a tire fire is the one which engulfed
the S.F. Royster Tire Disposal Facility in Tracy, California, in San Joaquin County.
The facility stored an estimated 7 million tires that burned for more than two years.
Local, state, and federal authorities worked together to conduct emergency
response activities. They determined that the best course of action was to let the fire
burn itself out.
The decision was based primarily on concerns that water hosing the fire
might produce excessive amounts of hazardous wastewater. In December 2001,
state and local agencies completely extinguished the fire and remediation efforts
followed.
The Board estimated that the fire contaminated an area of some 564,000
ft2, or 13 acres (California Integrated Waste Managment Board, 2009).
3*°	^
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
To address the long-term economic impacts of a tire fire, the highly toxic
emissions of the smoke plume must be considered significant ozone pollution
contributors in the wider air basin.
Ground-level ozone, or "bad" ozone, is formed when volatile organic
compounds—such as benzene and butadiene, which are components of tire fire
smoke—react with sunlight and nitrogen oxide in the earth's lower atmosphere. High
ozone concentrations reduce crop yield and result in losses to consumer and
producer welfare (California Integrated Waste Managment Board, 2009).
In summary, known environmental health hazards associated with past or
current waste tire piles located in regions with ecosystems similar to the Texas-
Mexico Border Region are the following:
•	Mosquito transmitted diseases such as Dengue fever and West Nile
Virus.
•	Carcinogenic compound emissions when tires are burned.
•	Increase in ground level ozone when tires are burned.
•	Soil and water contamination with toxic oil which leaches when tires
Identified health effects from exposure to emissions from tire fires include
irritation of mucous membranes (eye, nose, and throat), exacerbation of asthma
symptoms and respiratory conditions, and potential exacerbation of preexisting heart
disease.
4.6 Potential Cost to Remediate the Environmental
Health Threats Associated with Disease Carrying Vectors
Located in Tire Piles Along the Texas-Mexico Border
Region	
To obtain information related to health threats remediation costs associated
with Dengue and West Nile Virus, the following key stakeholders in the Mexico were
consulted:
•	Tamaulipas Health Secretariat
•	Nuevo Leon Health Secretariat
•	Coahuila Health Secretariat
•	Chihuahua Health Secretariat
These key departments were asked to deliver information regarding
Dengue and West Nile Virus recorded cases from 2005 to this day within the study's
scope regions, and the treatment costs for said diseases.
are burned.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
4.6.1 Dengue
State of Tamaulipas
Mr. Juan Francisco Castanon Barron, Chief of the Vector State Department
of Tamaulipas Health Secretariat delivered data from all municipalities in the State
of Tamaulipas regarding Dengue Fever and Dengue Hemorrhagic Fever from 2005
to half 2011, which was the most recent available data. No West Nile Virus data was
provided. The following tables contain detected dengue fever and dengue
hemorrhagic fever cases in study's scope regions in the State of Tamaulipas.
Table
Detected dengue fever and dengue hemorrha
the State of Tamau
4.13.
gic fever cases in study's scope regions in
ipas. (2005-2007)
Municipality
2005
2006
2007
DF
DHF
TOTAL
DF
DHF
TOTAL
DF
DHF
TOTAL
Camargo
0
1
1
0
0
0
9
3
12
Diaz Ordaz
0
0
0
0
0
0
1
4
5
Mata moras
1160
438
1598
14
10
24
46
21
67
Miguel Aleman
0
1
1
0
0
0
8
2
10
Nuevo Laredo
1
2
3
1
0
1
360
142
502
Reynosa
143
62
205
27
9
36
448
198
646
Rio Bravo
2
3
5
1
3
4
9
2
11
Guerrero
0
0
0
0
0
0
0
0
0
Total
5069
1832
6901
151
46
197
1406
516
1922
Table 4.14.
Detected dengue fever and dengue hemorrhagic fever
State of Tamaulipas. (200
cases in study's scope regions in the
8-2011)
Municipality
2008
2009
2010
2011
DF
DHF
TOTAL
DF
DHF
TOTAL
DF
DHF
TOTAL
DF
DHF
TOTAL
Camargo
0
0
0
0
0
0
0
0
0
0
0
0
Diaz Ordaz
0
0
0
0
0
0
0
1
1
0
0
0
Mata moras
257
231
488
46
29
75
23
3
26
2
0
2
Miguel Aleman
0
0
0
0
0
0
0
0
0
0
0
0
Nuevo Laredo
4
3
7
9
0
9
2
1
3
0
0
0
Reynosa
284
105
389
81
35
116
29
14
43
15
0
15
Rio Bravo
4
2
6
5
1
6
107
99
206
0
1
1
Guerrero
0
0
0
0
0
0
0
0
0
0
0
0
Total
1014
522
1536
696
215
911
409
168
577
78
15
93
DF = Dengue Fever Cases
DHF = Hemorrhagic Fever Cases
Mr. Juan Francisco Castanon Barron also provided information on length of
hospitalization times and its corresponding costs. On average it is known that
Dengue Hemorrhagic Fever patients need between 4-7 days to recover from illness
which translates into $5,000 - $8,000 pesos for hospitalization costs.
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There are no specific antiviral medicines for dengue, doctors prescribe
medicine to counteract disease symptoms such as painkillers and antipyretics,
Parecetamol is highly recommended as it fulfills both functions, as well as electrolyte
drinks.
For cost estimation, treatment cost (TrC) of $130 pesos and hospitalization
cost (HC) of $5,000 pesos will be used per patient. Costs can be higher according to
patient critical condition.
The following tables contain detected dengue fever and dengue
hemorrhagic fever costs in study's scope regions in the State of Tamaulipas.
Table 4.15.
Dengue fever and dengue hemorrhagic fever costs in study's scope
regions in the State of Tamaulipas (2005-2006)
Municipality
2005
2006
TrC
HC
TC
TrC
HC
TC
Camargo
$130
$5,000
$5,130
$0
$0
$0
Diaz Ordaz
$0
$0
$0
$0
$0
$0
Mata moras
$207,740
$2,190,000
$2,397,740
$3,120
$50,000
$53,120
Miguel Aleman
$130
$5,000
$5,130
$0
$0
$0
Nuevo Laredo
$390
$10,000
$10,390
$130
$0
$130
Reynosa
$26,650
$310,000
$336,650
$4,680
$45,000
$49,680
Rio Bravo
$650
$15,000
$15,650
$520
$15,000
$15,520
Guerrero
$0
$0
$0
$0
$0
$0
Total
$235,690
$2,535,000
$2,770,690
$8,450
$110,000
$118,450
Table 4.16.
Dengue fever and dengue hemorrhagic fever costs in study's scope regions in
the State of Tamaulipas (2007-2008)
Municipality
2007
2008
TrC
HC
TC
TrC
HC
TC
Camargo
$1,560
$15,000
$16,560
$0
$0
$0
Diaz Ordaz
$650
$20,000
$20,650
$0
$0
$0
Mata moras
$8,710
$105,000
$113,710
$63,440
$1,155,000
$1,218,440
Miguel Aleman
$1,300
$10,000
$11,300
$0
$0
$0
Nuevo Laredo
$65,260
$710,000
$775,260
$910
$15,000
$15,910
Reynosa
$83,980
$990,000
$1,073,980
$50,570
$525,000
$575,570
Rio Bravo
$1,430
$10,000
$11,430
$780
$10,000
$10,780
Guerrero
$0
$0
$0
$0
$0
$0
Total
$162,890
$1,860,000
$2,022,890
$115,700
$1,705,000
$1,820,700
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Table 4.17.




Dengue fever and dengue hemorrhagic fever costs in study's scope regions in the State of
Tamaulipas (2009-2011)
Municipality
2009
2010
2011
TrC
HC
TC
TrC
HC
TC
TrC
HC
TC
Carmargo
$0
$0
$0
$0
$0
$0
$0
$0
$0
Diaz Ordaz
$0
$0
$0
$130
$5,000
$5,130
$0
$0
$0
Matamoros
$9,750
$145,000
$154,750
$3,380
$15,000
$18,380
$260
$0
$260
Miguel Aleman
$0
$0
$0
$0
$0
$0
$0
$0
$0
Nuevo Laredo
$1,170
$0
$1,170
$390
$5,000
$5,390
$0
$0
$0
Reynosa
$15,080
$175,000
$190,080
$5,590
$70,000
$75,590
$1,950
$0
$1,950
Rio Bravo
$780
$5,000
$5,780
$26,780
$495,000
$521,780
$130
$5,000
$5,130
Guerrero
$0
$0
$0
$0
$0
$0
$0
$0
$0
Total
$26,780
$325,000
$351,780
$36,270
$590,000
$626,270
$2,340
$5,000
$7,340
Notes:
TrC = Treatment Cost ($130 pesos per patient)
HC = Hospitalization Cost ($5,000 per patient)
TC = Total Cost
Costs can be higher according to patient critical condition.
No written or specific data was provided during the preparation of this
report for the States of Nuevo Leon, Coahuila or Chihuahua.
4.6.2 West Nile Virus
The results of the estimations of the number of WNV cases in Mexican
border municipalities are presented only for border counties which presented at
least one WNV case from 2005 to 2011.
Table 4.18.
Estimated West Nile Virus cases in Matamoros

Mexican Border
US Border
Year
Municipality of Matamoros
Cameron County
Population
(Inhabitants)
Estimated WNV
Ocurrence
Population
(Inhabitants)
WNV
Cases
WNV/
Inhabitant
2005
462157
0
370735
0
0
2006
467564
4
376882
3
7.96E-06
2007
472971
5
382703
4
1.05E-05
2008
478379
0
389164
0
0
2010
489193
0
406220
0
0
Total WNV Ocurrence
9
7
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Table 4.19.
Estimated West Nile Virus cases in Rio Bravo
Year
Mexican Border
Municipality of Rio Bravo
US Border
Hidalgo County
Population
(Inhabitants)
Estimated WNV
Ocurrence
Population
(Inhabitants)
WNV
Cases
WNV/
Inhabitant
2005
106842
0
665475
0
0
2006
109125
1
683719
2
2.93E-06
2007
111409
1
701862
3
4.27E-06
2008
113692
0
721275
0
0
2010
118259
0
774769
0
0
Total WNV Ocurrence 2
5
Table 4.20.
Estimated West Nile Virus cases in Reynosa
Year
Mexican Border
Municipality of Reynosa
US Border
Hidalgo County
Population
(Inhabitants)
Estimated WNV
Ocurrence
Population
(Inhabitants)
WNV
Cases
WNV/
Inhabitant
2005
526888
0
665475
0
0
2006
543289
2
683719
2
2.93E-06
2007
559689
3
701862
3
4.27E-06
2008
576090
0
721275
0
0
2010
608891
0
774769
0
0
Total WNV Ocurrence 5
5
Table 4.21.
Estimated West Nile Virus cases in Gustavo Diaz Ordaz

Mexican Border
US Border

Municipality of Gustavo Diaz



Year
Ordaz
Hidalgo County

Population
Estimated WNV
Population
WNV
WNV/

(Inhabitants)
Ocurrence
(Inhabitants)
Cases
Inhabitant
2005
15028
0
665475
0
0
2006
15177
1
683719
2
2.93E-06
2007
15327
1
701862
3
4.27E-06
2008
15476
0
721275
0
0
2010
15775
0
774769
0
0
Total WNV Ocurrence
2
5
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Table 4.22.
Estimated West Nile Virus cases in Miguel Aleman

Mexican Border
US Border
Year
Municipality of Miguel Aleman
Webb County
Population
(Inhabitants)
Estimated WNV
Ocurrence
Population
(Inhabitants)
WNV
Cases
WNV/
Inhabitant
2005
24020
0
220968
0
0
2006
24619
0
225985
0
0.00E+00
2007
25218
1
230848
1
4.33E-06
2008
25817
1
235937
1
4.23842E-06
2010
27015
1
250304
1
3.99514E-06
Total WNV Ocurrence
3
3
Table 4.23.
Estimated West Nile Virus cases in Nuevo Laredo

Mexican Border
US Border
Year
Municipality of Nuevo Laredo
Webb County
Population
(Inhabitants)
Estimated WNV
Ocurrence
Population
(Inhabitants)
WNV
Cases
WNV/
Inhabitant
2005
355827
0
220968
0
0
2006
361468
0
225985
0
0.00E+00
2007
367109
2
230848
1
4.33E-06
2008
372751
2
235937
1
4.23842E-06
2010
384033
2
250304
1
3.99514E-06
Total WNV Ocurrence
6
3
Table 4.24.
Estimated West Nile Virus cases in Juarez

Mexican Border
US Border
Year
Municipality of Juarez
El Paso County
Population
(Inhabitants)
Estimated WNV
Ocurrence
Population
(Inhabitants)
WNV
Cases
WNV/
Inhabitant
2005
1313338
21
708683
11
1.55217E-05
2006
1317097
28
720756
15
2.08E-05
2007
1320855
68
727828
37
5.08E-05
2008
1324614
0
738416
0
0
2010
1332131
0
800647
0
0
Total WNV Ocurrence
117
63
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Although symptoms and general treatments for WNV are publicly available
all cases require different levels of medical care and costs can be very high
depending on complications. Also WNV time of recovery varies greatly on a case by
case basis.
For the reasons above stated; standard treatment costs and time for
recovery of WNV cases are not available on public literature and are were not
provided by health stakeholders on neither side of the border.
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47
Section 5.
Comparison
between Texan and
Mexican Tire
Tracking Systems
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5 Comparison Between Texan And Mexican Tire
Tracking Systems	
To obtain the information required, I EMS performed the following activities:
S Face to face interviews with industry key stakeholders.
S Face to face interviews with Texas local environmental authorities in
the scope's selected fieldwork cities
S Remote interviews with the Mexican municipal's environmental
authorities.
S Consulted previous studies focused on tracing the flow of waste tires
across the Texas-Mexico Border and similar regions in both countries
and the regulatory framework described by them.
S Reviewed the existing regulatory structure used by Texas and Mexico
to manage used tires along the Texas-Mexico Border Region.
The last one includes an investigation of current waste tire policies, laws,
regulations and procedures along the Texas-Mexico Border Region in international,
federal, state and local levels applying to it described in detail on the Chapter 6 of
the Full Report.
	5.1 Tracking Systems	
In this section the tracking systems employed in Texas and Mexico are
examined and later on compared.
In the study area, tires sold, imported and exported can be classified as:
•	New
•	Used
Although waste tires are likely to be sold, imported or exported if mixed with
used tires, special handling waste tracking systems for them are later on presented
in detail on the Chapter 6 of the Full Report.
5.1.1 Texas Tracking Systems
5.1.1.1 New Tires Sales Tracking Systems
Tire sale tracking systems are regulated at federal level by the National
Traffic and Motor Vehicle Safety Act section 30117
5.1.1.2 Used Tires Sales Tracking Systems
No used tire tacking systems were reported to be used by the used tire
dealers interviewed during fieldwork activities in the Texas scope cities.
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5.1.1.3 New and Used Tires Import and Export Tracking Systems
"The Harmonized Commodity Description and Coding System", generally
referred to as "Harmonized System" or simply "HS", is a multipurpose international
product nomenclature developed by the World Customs Organization (WCO). It
comprises about 5,000 commodity groups; each identified by a six digit code,
arranged in a legal and logical structure and is supported by well-defined rules to
achieve uniform classification. The system is used by more than 200 countries and
economies as a basis for their Customs tariffs and for the collection of international
trade statistics. Over 98 % of the merchandise in international trade is classified in
terms of the HS.
The HS contributes to the harmonization of Customs and trade procedures,
and the non-documentary trade data interchange in connection with such
procedures, thus reducing the costs related to international trade. It is also
extensively used by governments, international organizations and the private sector
for many other purposes such as internal taxes, trade policies, monitoring of
controlled goods, rules of origin, freight tariffs, transport statistics, price monitoring,
quota controls, compilation of national accounts, and economic research and
analysis. The HS is thus a universal economic language and code for goods, and an
indispensable tool for international trade." (World Customs Organization (WCO))
New and used tires are classified in chapter 40, "Rubber and articles
thereof", and their tariff schedules or codes start with the four numbers, or heading:
New tires 4011 (United States International Trade Commission, 2012)
Used tires -M012 (United States International Trade Commission, 2012)
5.1.2 Mexico's Tire Tracking Systems
5.1.2.1	Sales Tracking Systems
No new or used tires tracking systems are applied neither by the industry
nor any level of government.
5.1.2.2	New and Used Tires Import and Export Tracking Systems
The same Harmonized system described developed by the World Customs
Organization is applied by Mexico's federal government Tributary Administration
System (Sistema de Administracion Tributaria, SAT) to track the import and export
of used and new tires.
An additional used tire tracking system is employed by the Secretary of
Economy to ensure the proper disposal of used tires legally imported through the El
Paso-Ciudad Juarez border.
The Secretary of Economy (Secretaria de Economia or SE) is in charge of
issuing importation permits for three regions in the U.S. - Mexico border.
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These permits are granted annually according to a global used tire import
quota to people or companies dedicated to commercialization of used tires in these
areas. The used tire import quota also determined by the SE is based on:
a)	The volume of used tires imported the previous year and
b)	Compliance with final disposal legislation.
The regions were used tire importation has been authorized and controlled
by the SE are:
1.	The state of Baja California.
2.	Sonora State.
3.	Ciudad Juarez, Chihuahua.
Every year the number of authorized used tires for import or used tire
import quota is established by the SE and divided between each of the three
regions. For the purpose of this study the number of used tires legally imported was
based on the quota established at the ports of entry in the region of Ciudad Juarez,
Chihuahua, Mexico. This is defined as Ciudad Juarez annual used tire import
quota.
5.1.2.3 Used Tire Legal Import Requirements for Commercialization
According to the Colombia international bridge customs administrator A.
Diaz (personal communication, June, 28, 2011) there are several conditions that
must be met to legally introduce used tires into Mexico. The legal import
requirements are:
I.	The used tire importer must be registered, as such, in the used tires
importers record kept by the Central Administration of Accounting and
Explanation (Administracion Central de Contabilidad y Glosa or ACCG)
of the SAT.
II.	Retain a share of the authorized used tire import quota set by the
Mexican Secretary of Economy (Secretaria de Economia or SE) for the
year during which the import is performed. The used tire import quota is
the maximum number of used tires that can enter through a portion of
the U.S.-Mexico border in a particular year. It is specific for the type or
origin of the used tires and is valid only for a particular year.
III.	Legal submission of an import petition to the customs authority of the
point of entry through which the tires will enter Mexico. This has to be
made by a customs agent and comply with the requirements set in the
Annex 22 of the General Character Rules Regarding Exterior Commerce
(Anexo 22 de las reglas de caracter general en materia de comercio
exterior).
Purposes
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Note: in order for the customs agent to submit an import petition other
legal requirements must be met.
IV. Pay the import tariff (schedule) for each used tire entering Mexico. This
varies depending on the year and it is defined in the Import and Export
General Tax Law (Ley de los impuestos generates de importation y de
exportation) valid during importation.
Each item legally crossing the Mexican border has a numeric code or tariff
item(schedule) assigned to it depending on how it is classified by the Import and
Export General Tax Law (Ley de los Impuestos Generates de Importation y
Exportation or LIGIE).
5.1.2.4	Commercial Used Tires Import for Retreading
There are a different set of authorizations issued by the SE for the
importation of commercial tires for the sole purpose of retreading in a Mexican
facility. Only registered tire renovation facilities are assigned a used tires import
quota for renovating purposes. Retreading passenger tires although possible is not
economically viable. Without this tire renovating industry the commercial carriers in
Mexico would go bankrupt given the cost of new tires.
Used tires for retreading can be imported into Mexico through any legal port
of entry following the used tire legal import requirements for retreading purposes.
5.1.2.5	Used Tire Legal Import Requirements for Retreading
In addition to the four legal import requirements described, the import of
used commercial tires for retreading is exclusive for natural and legal
persons/entities dedicated to tire retreading.
The authorizations are annual, unchangeable, and defined according to
formulas.
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53
Section 6.
Waste Tire
Management
Regulatory
Framework
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	6 Waste Tire Management Regulatory Framework
I EMS conducted a thorough review of U.S. and Mexican legislations,
regulations and standards, at all Federal, State, and Local levels, in order to identify
all applicable to waste tire management. The review included International treaties.
In addition, the enforcement agencies related to the identified applicable
requirements were also identified and listed.
The following list summarizes the laws and regulations related to the
management and disposal of tires in both countries. A full list of applicable articles is
included in Chapter 6 of the study Full report.
6.1 International Treaties	
~ NAFTA
S North American Agreement on Environmental Cooperation
S Agreement on Cooperation for the Protection and Improvement of the
Environment in the Border Area
S Basel Convention about Control of Transboundary Movements of
Hazardous Wastes and their Disposal
S Customs Convention for the Temporary Importation of Private Road
Vehicles.
S Convention on Combating Bribery of Foreign Public Officials in
International Business Transactions
S World Health Regulations
S Guidance Manual for the Control of Transboundary Movements of
Recoverable Wastes
S United Nations Convention on the Law of the Sea
6.2 American Regulatory Framework	
S Federal Law
o US Disposal of Solid Waste Code - Section 6002 - 101
S State of Texas
o Texas Health and Safety Code 361.112 - Storage, Transportation,
and Disposal of Used or Scrap Tires
S Local Law
o City of El Paso
¦	Chapter 9.04 - Solid Waste Management
o City of Del Rio
¦	CHAPTER 24 - Solid Waste
o City of Eagle Pass
¦	CHAPTER 14 - Municipal Solid Waste [26]
o City of Laredo
¦	ARTICLE IV. - Tire Business Registration Program
¦	ARTICLE V. - Dengue Fever Prevention [45]
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o City of McAllen
¦	CHAPTER 90 - Solid Waste
o City of Pharr
¦	ORDINANCE NO. 0-2010-33
o City of Brownsville
¦	CHAPTER 82 - Solid Waste
6.3 Mexican Regulatory Framework	
S Federal laws
o General Law for the Prevention and Integrated Management of
Wastes
S State and local laws
o Chihuahua
¦	Law of Ecological Equilibrium and Environmental Protection of the
State of Chihuahua
¦	Municipal Regulation of Ecology and Environmental Protection of
the Municipality of Juarez, Chih.
¦	Regulation of the public cleaning service for the municipality of
Ojinaga
o Coahuila
¦	Law of Ecological Equilibrium and Environmental Protection of the
State of Coahuila
¦	Law for the Prevention and Integrated Management of Wastes of
the State of Coahuila
¦	Regulation of the Ecological Balance and Environmental
Protection Law of the State of Coahuila de Zaragoza on matter of
Environmental Impact
¦	Regulation of the Ecological Balance and Environmental
Protection Law of the State of Coahuila de Zaragoza on matter of
Contaminants Emissions and Transfer Registry
¦	Regulation of Ecology of the Municipality of City of Acuna,
Coahuila.
¦	Regulation of Ecology and Environmental Protection of the
Municipality of Piedras Negras, Coahuila.
o Nuevo Leon
¦	Environmental Law of the State of Nuevo Leon
¦	Law of the Environment and Natural Resources Protection Agency
¦	Regulation of the Environmental Law of the State of Nuevo Leon
¦	Civil Guard Rulebook of Anahuac, Nuevo Leon
o Tamaulipas
¦	Environmental Protection Law for the sustainable development of
the State of Tamaulipas.
¦	Law of Ecological Equilibrium and Environmental Protection of the
State of Tamaulipas
¦	Code for Sustainable Development of the State of Tamaulipas
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¦	Regulations for the Ecological Equilibrium and Environmental
Protection in the Municipality of Nuevo Laredo, Tamaulipas
¦	Regulation for the Ecological Equilibrium and Environmental
Protection in the Municipality of Reynosa, Tamaulipas
¦	Regulation for the Ecological Equilibrium and Environmental
Protection in the Municipality of Rio Bravo, Tamaulipas
¦	Regulation for the Equilibrium and Environmental Protection in the
Municipality of Matamoros, Tamaulipas
	6.4 Enforcement Agencies	
Two different levels of authority are involved in the main enforcement of
applicable requirements for the management of scrap tires in the U.S. territory:
S The Federal authority is the Environmental Protection Agency.
S Environmental Authority at State level in Texas is the Texas Commission
on Environmental Quality.
Three different levels of authority are involved in the main enforcement of
applicable requirements for the management of scrap tires in the Mexican territory:
S The Federal authority is the Mexican Secretary for the Environmental
and Natural Resources (Secretaria del Medio Ambiente y Recursos
Naturales, SEMARNAT). The prosecutor agency at the service of
SEMARNAT for the supervision of the applicably of federal regulations is
the PROFEPA (Procuraduria Federal de Proteccion al Ambiente).
S Four Mexican States are involved in the Texas-Mexico border area as
previously identified. Each State with an environmental office, identified
as follows:
o State of Coahuila Environmental Office (Secretaria del Medio
Ambiente de Coahuila, SEMAC).
o State of Chihuahua Urban Development and Ecology Office
(Secretaria de Desarrollo Urbano y Ecologia, SEDUE).
o State of Nuevo Leon Environment Protection and Natural Resources
Agency (Subsecretaria de Proteccion al Medio Ambiente y Recursos
Naturales, SPMARN).
o State of Tamaulipas Urban Development and Environment Office
(Secretaria de Desarrollo Urbano y Medio Ambiente, SEDUMA).
S Municipal Ecology and public Works departments are in charge of tire
management enforcement in a municipal level when waste tires are
generated as municipal solid waste.
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57
Section 7.
Recommendations
regarding changes
to the current
Texas and Mexico
Waste Tire Policies,
Laws, Regulations
and Procedures
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7 Recommendations Regarding Changes to the
Current Texas and Mexico Waste Tire Policies, Laws,
Regulations and Procedures
7.1 Recommendations
Table 7.1 shows the Recommendations regarding changes to the current
Texas and Mexico waste tire policies, laws, regulations and procedures in order to
improve waste tire management in the Texas-Mexico Border Region.
Table 7.1.
Recommended changes to the current Texas and Mexico waste tire policies,
laws, regulations and procedures
No.
Impact
Cause(s)
Recommendations for each impact
1
Tire fires
>	Trash fires
>	Tire burning for
metal extraction
>	Grass fires
S CPR dead tires campaign
S Tire fire prevention measures
S Tire ordinance-passing-training-
enforcement
2
Mosquitoes
> Water
accumulation
inside whole
tires
S CPR dead tires campaign
S Tire ordinance-passing-training-
enforcement
3
Blocked water
ways
> Illegal dumping
of whole tires
S CPR dead tires campaign
S Tire ordinance-passing-training-
enforcement
S Make access difficult to sensitive
spots
4
Bad image,
Hives, Vermin
and poisonous
animals
> Whole tire
dumping or
improper storage
S CPR dead tires campaign
S Tire ordinance-passing-training-
enforcement
5
Used tires lack
of tracking
> No manifest
given when
reinserted into
the market
S Include the number of resold used
tires in their annual report to the
TCEQ scrap tire program.
7
Tire piles
>	High disposal
costs.
>	No available
recycling
markets.
S CPR dead tires campaign
S Market recommendations of Section
8.
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	7.2 CPR Dead Tires Campaign	
CPR stands for Cut-Pack-Recycle which are basic steps I EMS identified in
order to facilitate waste tire handling.
Dead tires is the name given by Texas used tire dealers to tires that are no
longer reusable.
7.2.1 Cut
Cutting refers to the act of removing the sidewalls of a waste tire.
It can be accomplished manually using a linoleum knife or cutter or by
means of a machine, necessary especially for cutting commercial truck tires.
Cutting a tire provides the following benefits:
•	Retained water inside waste tires is easier to remove.
•	Disposal fee reduction (In Texas up to 80% and average savings of
55%, refer to Figure 7.1).
•	Volume reduction ranging from 70% to 79% depending on the tire size
demanding less storage area and diminishing transportation costs (see
Figure 7.2).
•	Increase recycling and marketing options (refer to Section 8).
Figure 7.1.
Comparison of the disposal fees for whole and cut tires
in several Texas border cities (US dollars / tire)
¦ Whole tires ¦ Cut tires
$3.00
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80%
Figure 7.2.
Approximated waste tires volume reduction when sidewalls are
removed and the resulting pieces packed
75%
70%
65%
12 13 14 15 16 17 18 19 20 21
Tire and rim diameter (in)
	7.2.2 Pack	
Packing refers to the act of storing in an ordered fashion the cutting
resulting pieces to take advantage of their reduced volume.
It is easy to notice the volume reduction advantages obtained when tire
sidewalls are removed as well as several packing alternatives.
Packing the resulting cut tire pieces provides the following benefits:
•	Diminish the storage area required.
•	Increase storage order.
•	Diminish transporting cost per tire.
•	Facilitate the loading and unloading into transport vehicles. (Either by
hand or stacking on standard pallets).
7.2.3 Recycle
Waste tires tread and sidewalls can have different alternative uses than
whole tires depending on whether they belonged to passenger of commercial truck
tires. Recycling involves classifying activities based on whether they came from
commercial or passenger tires, tread quality and dimensions. The following tread
quality classification is suggested:
Type A
No visible wiring is observed, when sliding a plastic bag across the surface
(in any direction) it isn't cut or damaged meaning a person can handle the tread
without using gloves without hurting his skin.
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Image 7.1.
Example of a Type A waste tire tread.
Type B
Tread presents visible wiring and/or when sliding a plastic bag across the
surface (in any direction) it is cut or damaged meaning a person cannot handle the
tread without using gloves.
Image 7.2.
Examples of type B tire treads.
¦ a i
¦M '
W/rZMW:te~\
» Ffrm
WW Ei:
"
'J**, f
Dimensions and tire of origin classification is only relevant on specific
recycling options. Tire part properties as well as market and recycling options are
enumerated and detailed on the market recommendations of Section 8.

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7.3 Tire Fire Prevention Measures
The following fire prevention measures should be implemented in every tire
storage site, plus the local, state and federal fire prevention requirements.
•	Waste tires should be separated from vegetation or any other flammable
material by at least 40 feet. (12.2 meters).
•	Every tire storage site should be fenced or surrounded by walls at least
2m tall, barb wired on the top, and have access doors with control such
as locks. This with the objective to prevent the entrance of arsonists.
7.4 Tire Ordinance
The tire ordinance recommended is based on the regulations already in
place in the cities of Laredo and Pharr, Texas. These ordinances both share the
sections marked on blue on the following table:
Table 7.2.
Comparison of tire ordinances sections
Laredo
Pharr

Purpose and intent
Definitions
Definitions

Residential property
Tire business registration program
Tire business permits
Tire business and mobile repair road
service units application
Terms of registration

Denial of permit or renewal; suspension
or revocation of permit
Denial of permit or renewal; suspension
or revocation of permit
Fees


Tire hauler permit

Destruction of tires

Storage of tires
Disposal of tires
Disposal of tires
Disposal records/Transmittal Manifest

Administration/Enforcement
Penalty for violations
Violations and penalties
Injunctive relief
Injunctive relief
Severability

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Tire ordinances common sections are:
1.	Definitions.
2.	Denial of permit or renewal; suspension or revocation of permit.
3.	Disposal of tires.
4.	Penalties.
5.	Injunctive relief.
In summary the Pharr ordinance presents a more specific approach,
especially on violations and penalties, and covers more tire related issues than the
Laredo ordinance.
Both cities report significant waste tire management improvement when
applying their own tire ordinances. I EMS recommends that each city, county or
municipality in the Texas-Mexico border facing tire related issues to pass an
ordinance which as a minimum contains the enumerated sections.
This suggestion should be considered, taking into account that always the
opinion of a professional legal ordinance advisor should be obtained when an
ordinance is to be written and passed. This recommendation doesn't replace the
need of legal professional counseling when writing an ordinance or any other legal
document.
Naturally it would also be desirable to consider including all of the
recommendations presented in this report in the tire ordinances. These
recommendations should be carefully reviewed by a professional experienced in law
making of each country and consulted with all involved entities, public or private,
before passed.
7.4.1	Passing
The city of Laredo set the example on the Texas-Mexico border area by
passing a tire ordinance; afterwards it was followed by the city of Pharr. Other cities
such as El Paso are in process of passing one. The stakeholders interviewed in said
cities highlighted the benefits of possessing a specific legal framework for waste tire
management in their areas because it facilitates antidumping enforcement and
prevention.
7.4.2	Training
The person in charge of setting up, direction and enforcement of the tire
ordinance should perform the following activities:
1. The regulated entities have to be notified and trained on the purposes,
scope and application of the tire ordinance. To effectively perform this,
the following activities are suggested:
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¦	Summon a meeting with the waste tire generators, haulers and
processors of the area. Present the tire ordinance and provide a
copy of it. Finally request them to sign a confirmation of notification
and training by means of a list of assistance. (The presence and
coverage of the event by the local media is desirable).
¦	Perform a visit to each tire generator, signal it location by means of
a GPS, provide a copy of the ordinance and have them sign of
reception and give them a period of time to comply, (six months).
2. Enforcement agents training. Passing an ordinance is not effective if the
following agencies do not know its purpose and scope. The following
agencies and agents should be educated on the tire ordinance purpose,
scope and application:
Enforcing agency personnel.
Special commission personnel.
Code enforcement agents.
Fire department.
Police department.
Vector control and health departments.
3. Also after the enforcing personnel has been trained in the purposes,
scope and application of the tire ordinance, the training on these
subjects of the Municipal judges is key
The success or failure of a tire ordinance relies on the consequences faced
by violators. The municipal court will have the final word on whether a civil penalty
should be applied or not as well as its severity.
An untrained or unwilling to punish judge may let go violators without any
punishment discouraging and disempowering enforcement agencies and officers
and sending the wrong message to the regulated entities which may think complying
is not necessary.
7.4.3 Enforcement
Immediately after the time given to the regulated entities to comply with the
new legislation has passed, tire ordinance enforcement agents should visit all
notified regulated entities and inspect their compliance if any violation is identified
the corresponding fine or consequence should be applied with zero tolerance.
Periodic visits should be performed, at least annually to ensure a continued
compliance and application of the tire ordinance.
New regulated entities identified should be trained and afterwards also be
visited.
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Spots
7.5 Make Access Difficult to Sensitive Dumping
Although tire dumping always generates negative impacts, these are
exacerbated when it occurs on waterways causing their course reduction or
blocking.
In most cases illegal dumping takes very little effort. It can take more effort
to dispose of waste legally tan to dump it illegally, areas continue to experience
illegal dumping problems after being cleaned up.
Effective structural solutions will increase the effort and risk of being caught
thereby deterring offenders. Structural solutions can reduce accessibility to popular
sites for illegal dumping. A clean up plus:
•	Introducing signs;
•	Lighting;
•	Barriers;
•	Landscaping; and,
•	Increasing the visibility;
Image 7.3.
Diagram of a tire tread fence
Further information is available on Section 8 Markets Report.
Attachment 5 of this report presents an extract of Chapter 4 (Illegal
dumping prevention techniques) of the following document:
S Crackdown on Illegal Dumping - Handbook for Local Government
(Department of Environment and Climate Change (DECC) New South
Wales Government, 2008)
This document presents experience and suggestions on access control
techniques and their efficiency in preventing dumping.
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	7.6 TCEQ Scrap Tire Program Modification	
Transporters, scrap tire facilities, and storage sites must file annual reports
to the Texas Commission on Environmental Quality (TCEQ). Current Scrap tire
annual reports do not include reselling used tires as an option, meaning that waste
tires which are reported to be disposed of could actually be reinserted into the
market.
By counting the number of waste tires reused a more realistic number of
properly processed tires will be at hand. As well as facilitating the tracking of used
tires and their actual generation within Texas. No modification to the report format is
required.
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67
Section 8.
Recommendations
Regarding
Potential Markets
for Tire-Derived
Products in
Mexico
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8 Recommendations Regarding Potential Markets for
Tire Derived Products in Mexico	
Each stakeholder should decide what market is more attractive to him
based on his own considerations. Nevertheless I EMS recommendations are based
on the following criteria:
•	Markets which require the minor equipment investment and provide the
higher income per tire (high market price) were selected as the most
recommendable markets.
•	Estimated incomes per tire which are minor than the income theoretically
obtained from the burning of tires for metal extraction were not
considered recommendable.
•	By doing this discrimination the market thrives to burn waste tires for
metal extraction would theoretically be discouraged because a higher
income could be obtained through alternative recommended markets.
•	Alternatives which imply higher green house gas emissions per tire
	8.1 Social Considerations	
Only Mexican legal framework was considered. To identify legal restrictions
and regulations, concerning the markets identified a search was performed on
Mexican Official Standards (Normas Oficiales Mexicanas, NOMs), International
treaties signed by Mexico, federal, state and local Mexican laws.
All recycling markets identified as long as they promote energy and raw
materials savings without affecting health, ecosystems or their elements, are
allowed. It would be recommendable for each project to perform a SIA prior to make
any decision regarding a processing project.
By identifying impacts in advance:
•	Better decisions can be made about which interventions should proceed
and how they should proceed; and
•	Mitigation measures can be implemented to minimize the harm and
maximize the benefits from a specific planned intervention or related
activity.
•	In order to aid stakeholders to assess social impacts the SIA is
described according to the international principles of the social impact
assessment emitted by the International Association for Impact
Assessment.
processed are considered less recommendable.
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I EMS will present the bases of a social impact assessment and useful data
in order for each stakeholder to perform its own local social impact assessment on
the area to be impacted by their planned projects.
	8.2 Economic Impact Considerations	
To make evident the difference in amount of economic investment required
by each raw material state, the necessary investments on equipment to process
waste tires was obtained from previous studies and quotations from manufacturers.
The equipment necessary was determined according to market tire derived
raw materials specifications such as:
•	Tire part
•	Type of tire where the raw material originated
•	Particle size
•	Metal content
•	Fiber content.
This estimation considers the required machinery to modify waste tires in
order to obtain the raw materials as the market demands them. It does not include
secondary equipment, land, vehicles or facilities.
	8.3 Environmental Impact Considerations	
Since all alternatives identified are actually recycling activities, all
alternatives provide the positive environmental impacts and benefits of:
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil pollution.
•	Prevent atmospheric and potentially water contamination by eliminating
tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
Yet health and environment issues have been presented though time
regarding tire derived products.
I EMS performed a search of serious publications and studies and selected
the one that was considered to be performed in the most scientific rigor in order to
assess if health and environmental risks may present in any of the identified
markets.
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Based on electrical energy consumption and processing speed a
comparison of estimated green house gas emissions per passenger tire equivalent
processed was performed to identify the less pollutant alternatives.
Emission per kilowatt-hour were the ones reported for the Mexican Federal
Commission of Electricity (Comision Federal de Electricidad, CFE) estimated by the
Technicians and Professionals in Energetic Application Association (Asociacion de
Tecnicos y Profesionistas de Aplicacion Energetica, ATPAE), which is of 0.6539
Kilograms of equivalent C02 per kilowatt-hour.
	8.4 Markets Identified	
Markets are any tire derived application where waste tires can be put to a
new use, different than their original and the end user or processor economically
compensates their tire derived raw materials supplier. The identified markets on the
Texas-Mexico border area are the following:
1.	Passenger tire sidewalls (bulk).
2.	De-beaded passenger sidewalls (bulk).
3.	Passenger tire sidewalls' bead wire (bulk).
4.	Tire treads (bulk).
5.	Tire derived geo cells (TDGC).
6.	Steel belted rubber for rammed-earth encased walls.
7.	Landscaping edging.
8.	Tire fences.
9.	Tire derived aggregates (TDA) (bulk).
10.	Ground rubber for rubberized asphalt (RA) (bulk).
11.	Ground rubber for athletic and recreational surfaces (bulk).
12.	Rubber mulch (bulk).
13.	Ground rubber for molded and extruded products (bulk).
During this search a pattern was identified and products could be
catalogued by the state of the raw material needed by them, it could be:
Shredded or ground rubber.
A specific part of a whole tire (i.e. tread, sidewalls, tread with one
sidewall, etc).
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8.4.1 Passenger Tire Sidewalls
Bulk passenger tire sidewalls can be considered a source for rubber, metal,
synthetic fibers and thermal energy.
Passenger tire sidewalls are also employed in the creation of diverse
handcrafts and pet biting toys.
Sidewalls from passenger tires can be easily obtained by cutting through
the tires shoulder using a knife. Also sidewall removing machines of different models
and brands are available in the market.
Truck tire sidewalls can only be removed employing a truck tire sidewalls
remover.
Benefits from recycling tire sidewalls:
•	Sidewalls are easily removed.
•	Sidewalls can be available with no investment costs through a dead tire
Cut-Pack-Recycle (CPR) campaign
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent tire piles burns.
•	Savings in disposal fees.
•	Savings in landfill space.
Image 8.1.
Passenger tire sidewalls, slit at the shoulder of the tire, ready to be transported
at a processors site in El Paso, Texas, USA
!WTJ M f
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Issues related to recycling tire sidewalls:
•	Need of a shredding machine capable of shredding rubber with metal
content.
•	Rubber obtained contains metal traces even if magnetic separation is
applied.
•	Demand may not be locally available.
Note: Open air burning of tires or of any of their pieces is illegal in all states
of the Mexican side of the border.
Image 8.2.
Rubber garden jars made out of tire treads and sidewalls
8.4.2 De-beaded Passenger Tire Sidewalls
Bulk de-beaded passenger tire sidewalls can be considered a source of
rubber, metal, synthetic fibers and thermal energy. Passenger tire sidewalls are also
employed in the creation of diverse handcrafts and pet biting toys.
Sidewalls from passenger tires can be easily obtained by cutting through
the tires shoulder using a knife. Also sidewall removing machines of different brands
and models are available in the market. Truck tire sidewalls can only be removed
from a tire employing a truck tire sidewall removing machine.
The benefits identified are:
•	Sidewalls are easily removed from a tires body using a linoleum knife
or a sidewall removing machine.
•	De-beaded passenger tire sidewalls are a source or non metallic
content rubber which has a higher market value.
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•	Bead wire removed can be sold as scrap steel.
•	Less powerful shredding equipment is necessary since rubber and
fiber are the only constituents of passenger tire sidewalls.
•	Tire sidewalls can be available with no investment costs through a
dead tire Cut-Pack-Recycle (CPR) campaign implemented in
coordination with waste tires generators.
•	Waste reduction. Reuse of a raw material that was considered a
waste.
•	Tire pile mitigation which means a reduction in soil and water
pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
Issues related to recycling tire sidewalls are:
•	Demand may not be locally available
8.4.3 Passenger Tire Sidewalls' Bead Wire
The bead is a rubber-coated steel cable whose function is to ensure that
the tire remains attached to the wheel rim. Bead wire removed from passenger, light
truck and heavy truck tires is a source of metal.
De-beading machines are commonly employed for this purpose. No manual
techniques were identified in this study's desktop and fieldwork activities.
Benefits from recycling tire sidewalls:
•	Attractive purchase prices from diverse buyers are available in most
large cities Mexico.
•	Waste reduction.
•	Tire pile mitigation.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
The following related to recycling tire sidewalls' bead wire issues were
detected:
• Specialized equipment is required to remove the sidewall's bead wire.

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• If the rubber was set on fire to obtain the steel bead wire a large amount
of carcinogenic and toxic gases and liquids are released, additionally it is
one of the main causes of tire pile fires in the Mexican side of the scope
border area.
	8.4.4 Tire Treads	
Bulk tire treads can be considered a source of tire derived geo cells, molds
for rammed earth tire walls, landscape edging, fencing components, rubber, metal,
synthetic fibers, thermal energy,
Benefits from recycling tire sidewalls:
•	High value products such as TDGC, landscape edging, and fence
railings can be locally obtained at very low costs.
•	The use of treads as rammed earth walls molds presents an opportunity
for low income families without access to commercial building materials
or for enthusiasts of eco-friendly buildings.
•	Passenger tire treads may be easily obtained using a knife to slit through
a passenger tire shoulders.
•	Transportation of tire treads is cheaper than transportation of whole tires
due to extreme volume reductions.
•	Tire cylinders, with sidewalls removed, can be available with no
investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign
implemented in coordination with waste tires generators.
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
Issues related to recycling tire treads:
•	If the rubber was set on fire to obtain the steel belts a large amount of
carcinogenic and toxic gases and liquids are released, additionally
burning of tires to extract the metal in the is one of the main causes of
tire pile fires in the Mexican side of the border area.
•	Rubber obtained would present metal traces lowering its market value
and increasing rubber production costs if metal is removed.
•	Some markets may not be locally available.
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8.4.5 Tire Derived Geo Cells (TDGC)
Geo cells are widely recognized in the construction industry as a
permanent soil stabilization best management practice (BMP) used for a variety of
applications including: Roadway load support and stabilization, erosion control, soil
stabilization on steep slopes, revetments and flexible channel lining systems, earth
retention structures.
By removing one or both sidewalls of a tire, slit at the shoulder, the
remaining tread cylinder can be used as a geo cell, herein the name tire derived geo
cell or tire derived geo cylinder (TDGC).
Benefits from recycling TDGC applications:
Use of TDGC as road base strengthening in Mexican scope
municipalities could completely remediate all identified tire piles.
Local materials and soils may be used as TDGC fill material eliminating
the need of transport and mining of aggregates from distant locations
thus eliminating the transport and mining environmental and economic
impacts.
Reduced cost of materials and construction since both scrap tires and
backfill soils can be recycled local materials.
The construction of the system is relatively simple. It doesn't require
skilled workers or heavy machinery.
A problem causing waste is converted into a high value engineering
input which improves the quality of life and safety of its users.
Large number of applications in civil engineering projects.
Green Building certification.
Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
Tire cylinders, with sidewalls removed, can be available with no
investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign
implemented in coordination with waste tires generators.
Waste reduction.
Tire pile mitigation which means a reduction in soil and water pollution.
Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
Savings in disposal fees.
Savings in landfill space.
The following related to TDGC issues were detected:
•	Some tire derived geo cell technology applications are patented in the
United States, such as the Mechanical concrete® application.
•	Zinc Leaching.
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8.4.5,1 TDGC Mechanical Concrete®
Mechanical Concrete® is built with cylindrical tension bands created from
used auto tires from which both sidewalls have been removed. When appropriately
sized stone aggregate is poured into the cylinders, the stones tightly lock together
and behave as a solid, immovable mass: Mechanical Concrete®. This construction
method uses less stone, requires no compaction or curing, and is instantly ready to
support construction loads.
It is a way of binding crushed stone aggregates together into a load bearing
cellular building unit. The Mechanical Concrete® unit can support compressive
loads and resist lateral soil pressure. It is basically a compressive material. The
TDGC performs functions similar to the cement / water mixture, the rebar and the
formwork in hydraulic cement concrete. It actually improves the load bearing
capacity of the aggregate material be it sand, stone or sandy clay.
Image 8.3.
Mechanical cement® and mechanical concrete® images
Tire derived geo cylinder	Tire derived geo cylinder (TDGC)
(TDGC) also named	filled with aggregates also named
Mechanical Cements®	Mechanical Concrete®
Mechanical Concrete® geo-cylinder confinement system has many
economical and beneficial uses reported by its patent holder. Rural and heavy duty
road base, gas well pad, mechanically stabilized earth retaining wall systems (MSE)
and bearing wall applications have been currently implemented.
Image 8.4.
TRIAD Consulting Engineers Parking Lot, Morgantown, WV USA
(REAGCO, 2011)
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Potential applications of mechanical concrete TDGC are:
Load Support for
•	Paved and Unpaved road sub-base, base, and shoulders
•	Unpaved and Paved Low Volume Road intersection interfaces
•	Industrial and mining roadways
•	Rail road ballast bed stabilization, repair and reconstruction
•	Conveyor foundations
•	Bridge piers
•	Underwater foundations
Earth Retaining Walls and Free Standing Load Bearing Walls
•	MSE & Gravity Retaining Walls
•	Industrial and commercial building and other load bearing walls and
foundations
•	Mining protective walls and sound wall structures
•	Dams, ponds, levees, embankment construction
•	Industrial Security walls and sound walls
Channel and Slope Protection
•	Drainage control structures
•	Bridge pier scour protection
•	Erosion control structures to reduce and absorb water runoff velocity
energy
•	Storm water retention
•	Channel, Slope and Embankment stabilization and Restoration
Other Uses
•	Helipads
•	Oil and Natural Gas Drill Pads
•	Airfield Construction
•	Overflow parking site stabilization
•	Emergency Vehicle Road Entrances
•	Energy Absorbing Highway and Transportation Crash Barriers
•	Natural stone golf cart paths, cycle and walking paths and trails that
support natural drainage patterns
•	Permeable structures for highway, railway and trail slippage repair and
reconstruction
•	Military force protection.
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Benefits on the implementation of MC technology on road bases:
•	Road bases load tested to greater than HS 20 wheel loads.
•	Using a tire tread cylinder, i.e. any standard automotive tire with both
sidewalls removed, in a construction application; i.e. where the
supported vertical loads are in the range of 10Opsi, 7 TSF; provides a
rugged, very conservative materials engineering approach.
•	Tire-derived-geo-cylinders economically create a virtually indestructible
base so it basically eliminates most road maintenance problems.
•	It can be used effectively and economically in nearly all construction, on-
road or off-road applications for a maximum wheel loading of 50,000lbs.
•	It more than triples the usual maximum load carrying capacity of sandy,
granular, and graded stone materials.
•	Less general labor and less skilled labor is required.
•	It consumes less energy in its construction process since it can use
smaller equipment.
•	It requires no compaction, vibration, forms or rebar.
•	It reuses a ready-made cylinder that is a low cost, combination stay-in-
place form and reinforcing element.
•	It uses the compressive load bearing capacity of low-cost stone
aggregates or other recycled or earthen aggregate materials.
•	It is simple to understand and use so it improves construction worker
productivity.
•	Speeds-up and facilitates the construction process.
•	Common infrastructure problems such as potholes and ruts are virtually
eliminated.
•	When compared to the cost of retaining walls, bearing walls and
foundations, roads and site stabilization made of conventional concrete
or compacted stone; Mechanical Concrete® can deliver a minimum 25%
savings. In many cases this savings can be as high as 50%. In road
construction the savings can be 25 to 30% or more depending on the
aggregate used.
The following related to Mechanical concrete® issues were detected:
•	Tire derived geo cylinder technology is patented in the United States
(U.S. Patent 7,470,092 B2).
•	It should be implemented using accepted civil engineering design
techniques, processes and traditional construction techniques.
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8.4.6 Steel Belted Rubber for Rammed Earth Tire Walls
In order to build a rammed earth structure, temporary forms are needed in
which the soil may be compressed. Generally, rammed earth walls are simple to
construct, requiring only a form to mold the dirt in and the soil itself. Tires perform
the function of a mold that can withstand the pressure generated by fill dirt being hit
by a sledgehammer in order to compress it.
The most common method of building rammed earth tire walls is to place a
used tire on the ground, fill the tire with dirt and compress the dirt with a hammer.
Cardboard is often placed in the bottom of a tire before the dirt is placed in it to
prevent the soil from falling out as it is compacted. This process is repeated until the
tire is completely filled with compacted soil.
An individual tire is placed on the running axis of the wall; it is filled and
compacted in that position. Other tires are then placed and filled next to the first tire.
Once one row of tires is complete, another row is placed on top of the first row, but
staggered in alternate lay from the first row, like bricks. In order for this to happen,
half tires must be used.
Benefits of structures built using rammed earth tire walls:
•	Incombustible, thermally massive and nearly soundproof
•	Strong and durable.
•	Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
•	Tire cylinders, with sidewalls removed, can be available with no
investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign
implemented in coordination with waste tires generators.
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
Issues of structures built using rammed earth tire walls:
•	Ramming earth is labor intensive.
•	As with any construction a proper technique is imperative for security's
sake.
•	Thick walls diminish internal living spaces on buildings with small lots.
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8.4.7 Tree and Landscaping Tire Tread Edging
Landscaping using tire derived products is a proven and current use of
waste tires, mostly in the form of tire derived rubber mulch. Garden edging is a new
application developed by I EMS' team. No knowledge of its application in the Texas-
Mexico border or elsewhere was found. Nevertheless it is presented as a potentially
large market once its viability is confirmed through testing and pilot applications,
which are strongly suggested but not part of this study's scope.
Landscape edging provides the following benefits:
•	Edging permanently defines the landscape bed, so that continual
reshaping of the bed is virtually eliminated.
•	Significant savings in maintenance expenses will be achieved as
landscape edging eliminates the continual spading of the bed edge by
hand or using power edgers.
•	Edging assures crisp, clean lines will be maintained throughout the
landscape bed, ensuring the original design intent is maintained.
•	Edging blends architectural details with the landscape beds, building a
properly designed and balanced landscape.
•	Landscape is truly defined by proper separation of lawn, flowerbeds and
aggregates and edging will achieve those goals.
•	When various aggregates are used in a contained area, edging is the
only way to assure a permanent separation.
•	Properly installed, quality landscape bed edging gives clarity and
significantly increases the level of visual aesthetics and adds value to
the business or residence.
Landscaping edging using cut tire treads provides the following additional
benefits:
Long lasting product materials, virtually indestructible.
Use of low carbon footprint product since required energy input to
produce it is minimum compared to extruded and molded ground rubber
products.
With a relatively low investment an almost ubiquitous residue becomes a
highly valued product.
Because of its relatively low required investment it can represent a
viable market solution to the waste tire problems occurring on the Texas-
Mexico border, especially on the Mexican side where municipal solid
waste management budgets are significantly lower.
Municipalities, cities and counties can improve the public landscaping on
parks and public areas with a minimum investment, avoiding tire
disposal costs which burden them nowadays.
Tire tread cylinders, with sidewalls removed, can be available with no
investment costs through a Cut-Pack-Recycle (CPR) campaign
implemented in coordination with waste tires generators.

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•	Using 100 percent acrylic exterior house paint the edging can be colored
as desired.
•	Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
Issues from tree and landscape edging using cut tires:
•	Accidentally exposed wires could harm people or animals.
•	Possible human health hazards.
No adverse human health or ecological health effects are likely to result
from these beneficial reuses of tire materials.
Since recycled tire rubber has been deemed non dangerous for human
health or the environment in playgrounds, which are located in parks and gardens, it
is lEMS's opinion that cut tire treads (with a protection installed on each extreme to
prevent wires to be exposed) will be as safe for humans and the environment as
both applications evaluated by ChemRisk.
8.4.8 Tire Tread Fences
The creation of fences using cut tire treads is an innovative solution
developed by I EMS' team. No knowledge of its application in the Texas-Mexico
border or elsewhere was found. Nevertheless it is presented as a potentially large
market once its viability is confirmed through testing and pilot applications, which are
strongly suggested but not part of this study's scope.
Image 8.5.
Diagram of tread hog fence
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Benefits expected from cut tire tread fencing:
•	Cut tire tread fences may lower labor and inputs costs making them
more affordable than treated wood applications with similar performance
except on strength.
•	For intruder control, cut tread fences would have the added value of
being more resilient to vandalism or entrance attempts by cutting them
than other kinds of fences, such as chain link which can be easily cut
with manual tools.
•	Tread fences wouldn't be see through, providing more privacy to the
protected area.
•	Long lasting product materials.
•	Use of a recycled product which avoids the use of virgin materials such
as wood.
•	Municipalities, cities and counties can fence municipal properties using
waste tires with a minimum investment.
•	The tire dump sites may be fenced using this technology to avoid arson.
•	Tire cylinders, with sidewalls removed, can be available with no
investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign
implemented in coordination with waste tires generators.
•	Using 100 percent acrylic exterior house paint the fence can be colored
as desired.
•	They require low energy input.
•	Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
	8.4.9 Tire Derived Aggregate (TPA)	
Tire derived aggregate (TDA) is an engineered product made by cutting
scrap tires into 25- to 300-millimeter (mm) pieces. Depending on particle sizes TDA
is classified on types A and B (Gray, 2010).
8.4.9.1 Type A TDA
Type A TDA is appropriate for a range of drainage applications in layers up
to 1 m (3.3 feet) thick.
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Potential drainage applications include (Gray, 2010):
•	Drainage layers within landfill leachate collection and removal systems.
•	Permeable aggregate for landfill gas collection layers and trenches.
•	Free draining aggregate for edge drains for roadways.
•	Permeable backfill for exterior walls below the ground surface.
•	Septic system drains fields.
•	Landfill gas collection systems.
8.4.9.2 Type B TDA
Type B TDA is used for lightweight fill applications in layers up to 3 m (10
Fill applications include:
•	Lightweight fill for highway embankments.
•	TDA and TDA soil mixtures have been used as a replacement for
conventional soil in embankment construction.
•	Compressible layers behind integral abutment and rigid frame bridges.
•	Backfill for retaining walls, bridge abutments, and sheet-pile walls.
•	Limit the depth of frost penetration and to provide drainage during the
spring thaw.
•	Use as drainage layers in landfills, septic system drain fields, and
highway edge drains.
•	A TDA layer beneath the stone ballast of rail lines reduces off-site
vibrations.
Benefits from using TDA in specific engineering applications:
•	TDA provides many solutions to geotechnical challenges since it is
lightweight: 50 pounds per cubic foot.
•	Produces low lateral pressures on walls (as little as one-half that of soil).
•	Is a good thermal insulator (eight times better than soil).
•	Has high permeability (more than 1 centimeters per second [cm/s]
dependent on TDA size).
•	Has good shear strength
•	Absorbs vibrations.
•	Moreover, each cubic meter of TDA fill contains the equivalent of 100
passenger car tires.
•	Is used to improve the stability of embankments constructed on weak
marine clay.
•	Cost reduction
•	Small scale applications can be implemented by municipal officials such
as public works directors.
•	Waste reduction.
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•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
•	Green Building certification. Facilities earn more points for the US Green
Building Council's LEED® certification program or for any other green
building certification standard.
Issues arising from using TDA in specific engineering applications:
•	The economics of using TDA for civil engineering applications depend
on the local costs to produce TDA and the local costs for competing
alternative construction materials. TDA is not a generally cost-effective
substitute for conventional earth fill.
•	Zinc leaching
•	Sophistication
8.4.10 Ground Rubber for Rubberized Asphalt (RA)
Rubber modified asphalt is the product of mixing crumb rubber from scrap
tires or other sources with asphalt. It is used as Asphalt pavement for roads.
Benefits obtained from paving using rubberized asphalt (RA)
Performance. Roads last longer than traditional asphalt, sometimes
dramatically longer, but this performance has not been universal.
Cost. Use of thinner rubber modified asphalt lifts (layers) can turn cost
into an advantage where applicable and accepted.
Noise reduction and increased safety are accomplished through use of
open-graded friction course (OGFC) pavement using large, uniformly
graded aggregate. Improves the flexibility and tensile strength of the
asphalt mix reducing the appearance of cracks due to fatigue or
temperature changes.
Waste reduction.
Tire pile mitigation which means a reduction in soil and water pollution.
Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
Savings in disposal fees.
Diminish the environmental impacts of virgin materials extraction and
transportation.
Savings in landfill space.
Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
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Issues arising from paving using rubberized asphalt (RA):
•	Poor performance has been attributed to improper installation, weather
conditions, bed preparation, and aggregate grading.
•	Florida found that rubber modified asphalt performed well, but that
polymers out-performed terminal-blended rubber modified asphalt for
some high-traffic applications.
•	The installed cost of an equivalent thickness of rubber modified asphalt
is generally 10 to 100 percent higher than unmodified asphalt, as
previously discussed.
8.4.11 Ground Rubber for Athletic and Recreational Surfaces
The current generation of artificial sports turf uses 7.6-cm (3-inch)-long
strands of green polyethylene embedded in a porous backing to form a carpet like
structural framework for the turf system.
The polyethylene grass-like blades add containment to the ground rubber,
and the rubber provides cushioning while the combined synthetic turf system bears
the physical forces of athletic activity (Gray, 2010).
Synthetic sports turf is mostly used in football stadiums but now this can be
used on a wide range of sports fields at all levels of play, like American football, field
hockey, baseball, etc.
Benefits obtained from using ground rubber for athletic and recreational
surfaces:
•	Health. Studies indicate that the severity of injuries is worse on natural
grass turf. There are more head, neural, and ligament injuries on natural
grass, while there are more epidural, muscle trauma, and temperature
related injuries on synthetic turf.
•	Economics. Synthetic turf's higher initial cost is offset by reduced
maintenance associated with water, fertilizer, pesticides, cutting, turf
replacement, and manpower.
•	Synthetic turf drains rapidly, allowing use quickly after heavy downpours.
In addition, synthetic grass turf can reportedly tolerate up to 3,000 hours
of use per year, about four times more use than natural grass turf.
•	Tire pile abatement
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
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•	Savings in landfill space.
•	Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
Issues from using ground rubber for athletic and recreational surfaces:
•	Elevated Turf Temperature
•	The pieces of black rubber and colored synthetic turf blades absorb light
energy and become warmer than ambient temperatures.
•	Zinc Leaching
8.4.11.1 Playground Safety Surfaces
In order to avoid injuries derived from falls from playground equipment the
areas under and surrounding them are covered with surfaces with high shock
absorbing properties.
Benefits obtained from applying rubber for playground safety surfaces:
Higher fall protection.
Durability. Rubber is flexible, resilient, and durable, properties that make
it a good outdoor cushioning material.
Accessibility of equipment by children in wheelchairs or on crutches can
be an important consideration.
Waste reduction.
Tire pile mitigation which means a reduction in soil and water pollution.
Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
Savings in disposal fees.
Diminish the environmental impacts of virgin materials extraction and
transportation.
Savings in landfill space.
Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
Issues from applying rubber for playground safety surfaces:
•	Flammability.
•	Latex Sensitivity.
•	Toxicity and environmental questions associated with ground rubber
have been raised for playground applications as well as for synthetic
turf.
•	Zinc Leaching.
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8.4.12
Rubber Mulch
Mulch is any material applied to the garden in order to retain soil humidity
and suppress weeds. It also has esthetical purposes. It can be made of leaves,
gravel, wood chips and rubber, among other many materials, which normally are
locally available.
Benefits of rubber mulch:
Control weeds
Resist mold.
Retain moisture.
Requires infrequent addition.
Does not harbor insects or attract neighborhood animals.
Waste reduction.
Tire pile mitigation which means a reduction in soil and water pollution.
Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
Savings in disposal fees.
Diminish the environmental impacts of virgin materials extraction and
transportation.
Savings in landfill space.
Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
Issues that arise from using rubber mulch:
Flammability
Temperature. Black ground rubber pieces absorb light and can heat up.
Zinc Leaching
8.4.13
Ground Rubber for Molded and Extruded Products
Molded products are created when heated rubber is pressed into a mold or
through a die cast to shape it into a new product. Extrusion normally involves using
a screw system to mix, heat, and force a raw material through a die to produce a
continuous shape.
This market is very versatile and can create a wide variety of products.
Molded crumb rubber for example can be transformed into items such as
pavers, tiles, splash guards, tree rings, curbing, mats, wheels for trash cans, traffic
cones, vehicle bumpers, wheels, mud flaps, etc.
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Long items such as: hoses, weather stripping, tubes, molding, belting, pet
toys, car bumpers, gaskets, garden hoses, complex components for medical and
electrical equipment, synthetic woods, shingles and other structural materials are
made by extrusion processes.
Benefits from creating molded and extruded products from ground rubber
•	Low-Cost Raw Material.
•	Ground rubber can be a low-cost raw material with many of the intrinsic
performance properties of rubber.
•	This market is very versatile and can create a wide variety of products.
•	Waste reduction.
•	Tire pile mitigation which means a reduction in soil and water pollution.
•	Prevent atmospheric, soil and potentially water contamination by
eliminating tire piles which could burn.
•	Savings in disposal fees.
•	Diminish the environmental impacts of virgin materials extraction and
transportation.
•	Savings in landfill space.
•	Facilities earn more points for the US Green Building Council's LEED®
certification program or for any other green building certification
standard.
Issues involved in creating molded and extruded products from ground
•	Displacement Challenges. Making any new product can involve
substantial investment in processing technology, equipment,
optimization, product testing, distribution, and marketing.
•	Any residual wire or fiber can accelerate wear, or damage extrusion
heads and equipment.
•	This technology can be labor intensive in its basic form.
•	Mixtures. Rubber generally functions as filler in mixtures with plastics.
Thermoset rubber and thermoplastics do not naturally bond, resulting in
significant changes in the performance characteristics of plastics when
rubber is added.
New tires can contain from 5% to 10% of recycled rubber, if more than that
is added the tire will fail (Information provided by Francisco Martha Hernandez,
general director of the Mexican rubber industry national chamber. Tire rubber dust
can be de-vulcanized at very high costs; it would be over than 3 times more
expensive than virgin materials.
Ground rubber for extruded products could also be presented as a separate
market since additional equipment is necessary in order to achieve the fine mesh
size required by these applications (30 to 200 mesh).
rubber:
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8.5 Market Recommendations
Products in Mexico
of Tire Derived
Each stakeholder should select the market that better suits him/her needs,
the purpose of this section is to present the evaluation results in order to aid in the
market selection process.
8.5.1 Tire Derived Products Market Prices
The following references to Attachments included in the study Full report,
present information on market prices for the identified tire derived products:
>	Attachment 27. Estimated and consulted market prices of tire derived
products currently supplying the identified markets.
>	Attachment 28. Daily prices of tire derived products and parts during
May 2012.
>	Attachment 29. Potential revenue per passenger tire equivalent (PTE)
for each market and formulas applied to obtain each.
>	Attachment 32. Scrap tire wire purchase prices in the Mexican side of
the Texas-Mexico border region.
8.5.2 Required Investments on Equipment
The following references to Attachments included in the study Full report,
present information on equipment necessary to produce each of the identified tire
derived products. It is relevant to note that the amounts presented are for equipment
only, not including required land, facilities, secondary equipment, production costs,
etc:
>	Attachment 30. Matrix of required equipment per type of product.
>	Attachment 31. Equipment quotations and pricing sources.
Of the identified existing and potential markets the most expensive to
access, based only on required investment on equipment, are the following:
Type B tire derived aggregate (TDA) (bulk).
Type A tire derived aggregate (TDA) (bulk).
Ground rubber for Rubberized Asphalt (RA) (bulk).
Ground rubber for Athletic and recreational surfaces (bulk).
Rubber mulch (bulk).
Ground rubber for molded and extruded products (bulk).
Ground rubber for extruded products (bulk).
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Of the identified existing and potential markets the most accessible ones,
based only on required investment on equipment, are the following:
Passenger tire sidewalls (bulk).
Tire-derived-geo-cylinders, (TDGC).
Steel belted rubber for rammed-earth encased walls.
Tire treads (bulk).
Passenger tire de-beaded passenger sidewalls (bulk).
Passenger tire sidewalls' bead wire (bulk).
Cut tire tread tree and landscape edging
Cut tire tread fencing.
8.5.3 Recommendations
A)	The income per tire of any promoted market should be higher
than the amount paid for the steel present in the tire to discourage tire open
burning for metal extraction. One of the main causes of tire fires is tire burning for
metal extraction. This is caused by the need to obtain resources through the sale of
the steel wire embedded inside tires.
For example: scrap tire wire is bought in Reynosa, Tamaulipas, Mexico at
an estimated mean of $2.92 Mexican pesos per kg ($0,096 USD per pound). So the
potential income per passenger tire by burning it for metal extraction is $4.38
Mexican pesos per passenger tire ($0,316 USD per passenger tire) in Reynosa.
B)	Zinc leaching should be considered an Environmental Issue of
Concern (EIC) on some tire derived products. Since the following tire derived
applications will be in direct contact with rain water and soil, it was considered
relevant to consider this EIC also for them: TDGC, Landscape edging, TDA, RA,
Ground rubber for athletic and recreational surfaces and Rubber mulch
C) To implement CPR dead tires campaigns, or similar, in the Texas-
Mexico scope areas
Image 8.6.
English version example of a CPR dead tires campaign
CPR dead tires
Cut ^ Pack ^ Recycle
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Image 8.7.
Spanish version of example of a CPR dead tires campaign
Haz RCP a las llantas muertas
Rajalas ^Compactalas ^ Procesalas
A CPR dead tires campaign promotes waste tire generators to:
i.	Slit passenger waste tires on the shoulder to remove both sidewalls
"Cut".
ii.	Order and pack the resulting tread cylinders and sidewalls in a way the
volume they occupy is minimum "Pack".
iii.	Recycle them or send the packed tire pieces to a recycling facility
"Recycle".
By implementing a CPR dead tires campaign the following benefits could
be obtained:
Eliminate mosquito breeding areas.
Health benefits. By eliminating mosquitoes breeding sites, their related
diseases such as Dengue Fever and West Nile Virus are also fought.
Storage space required by waste tires is greatly reduced.
Transportation costs are reduced.
Disposal fees are reduced.
Promoting a Cut-Pack-recycle (CPR) campaign among waste tire
generators would make tire derived cylinders (treads) and slit sidewalls
available to recyclers, authorities and processors without the need of
investing resources such as time, labor and money in sidewall removing
activities.
Also by implementing a CPR dead tires campaign recyclers, authorities and
processors would have direct and cheap access to:
•	Tire derived geo cells for civil engineering projects.
•	Steel belted rubber for rammed earth tire walls.
•	Slit sidewalls ready for de-beading.
•	Packaged tire treads ready for transportation to processing or disposal
sites at lower costs than when transporting whole waste tires.
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Image 8.8.
Used tire dealership worker manually cutting passenger tires' sidewalls using a
cutter knife in Brownsville, Texas
8.6 Markets Evaluation
8.6.1	Legal Evaluation
While none of the proposed market alternatives is illegal in Mexico, some
alternatives are more heavily regulated and or restricted than others.
A general prohibition throughout the Mexican side of the border is the
burning of tires in open air.
Only the rubberized asphalt application is specifically regulated in Mexican
legal framework. These regulations are focused on ensuring the quality control of
the modified asphalt created in part of tire ground rubber.
It should be noted that even if no specific regulations were found, it doesn't
mean general regulations and laws don't apply. The purpose of this search was to
identify regulations that applied specifically to tire derived products, apart from the
general regulations which apply to a traditional application.
8.6.2	Economic Evaluation
8.6.2.1 Market Prices per Tire
Prices currently paid for each tire derived product identified are described in
study Full report. Since some of these products are not yet available on the market,
the prices presented for these are the ones paid for similar products with which they
would compete.
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Figure 8.1 displays the potential income per Passenger Tire Equivalent
(PTE) received when supplying each of the identified markets.
It is relevant to note that the following are considered to use de-beaded tire
sidewalls as rubber source:
•	Ground rubber for athletic and recreational surfaces.
•	Molded and extruded products.
Meaning that an alternative income for the tire treads sale can be obtained
depending on the market supplied with them. Violet bars represent consulted current
prices of the tire derived products on existing markets. Gray bars represent
estimated prices based on what similar products are currently worth in the market.
8.6.2.2	Required Equipment Investment per Market
In order to supply any of the identified markets, waste tires require
modifications in order to comply with the demand specific needs. The equipment
necessary to perform said modifications greatly varies in size, complexity, required
energy input, required investment, labor needs, etc.
The estimated economic investment on equipment to modify waste tires
according to current and potential markets demands is presented on Figure 8.2.
This figure displays the required investment on equipment, not including the
required facilities, labor, energy inputs, secondary equipment, etc.
Rubber for extruded products is presented on a separate column in Figure
8.2. because mesh size required can be as low as 200 mesh, to obtain this mesh
size it is required additional equipment which would further elevate the investment
required. Since no quotations were obtained for this specific equipment it is only
noted that the market which requires the largest investment on equipment is the
ground rubber for extruded products.
The section below evaluates in more depth which markets require large
investments on equipment to process tires.
8.6.2.3	Most Expensive Markets to Enter Based on Equipment Required
Investment
Based on the information presented on Figure 8.2. it is visible that some
markets require larger initial investments on processing equipment than others.
Of the identified existing and potential markets the most expensive to
access, based only on required investment on equipment, are the following:
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Type B tire derived aggregate (TDA) (bulk)
Type A tire derived aggregate (TDA) (bulk)
Ground rubber for Rubberized Asphalt (RA) (bulk)
Ground rubber for Athletic and recreational surfaces (bulk).
Rubber mulch (bulk).
Ground rubber for molded and extruded products (bulk).
8.6.2.4 Most Accessible Markets Based on Equipment Required
Investment
Of the identified existing and potential markets, the most accessible ones
based only on required investment on equipment are the following:
Passenger tire sidewalls (bulk).
Tire-derived-geo-cylinders, (TDGC).
Steel belted rubber for rammed-earth encased walls.
Tire treads (bulk).
De-beaded passenger sidewalls (bulk).
Passenger tire sidewalls' bead wire (bulk).
Tire tread tree and landscape edging
Tire tread fencing.
It is evident that some markets require the same equipment to produce tire
derived products. For example to sell passenger tire sidewalls, treads, TDGC and
steel belted rubber for rammed earth tire walls the investment is the same. The
same happens with the equipment required to produce de-beaded sidewalls and
bead wire, and yet again on the fencing and edging markets.
More accessible equipment investment range from $3,900 USD ($54,011
Mexican pesos) in order to manufacture:
•	Passenger tire sidewalls in bulk.
•	Tire-derived-geo-cylinders, (TDGC).
•	Steel belted rubber for rammed-earth encased walls.
•	Tire treads (bulk).
These markets require only removing the sidewalls of waste tires.
Equipment investment to remove passenger tire sidewalls can be lowered to $15.2
USD ($210.5 Mexican pesos) for the purchase of a professional linoleum knife or
even lower. Making the markets that only require removing one or both passenger
tire sidewalls the most accessible based on required investment on equipment.
To a required equipment investment of $10,950 USD ($151,646.55
Mexican pesos) in order to manufacture cut tire tread for fencing.
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8.6.3 Environmental Evaluation
Performing environmental impact assessments on each application for
each location in the Mexican scope area is not possible since many variables would
be unknown. Such as: water bodies, biodiversity in the area, type of soil and its
characteristics, climate, processes, etc.
Yet during fieldwork and deskwork activities I EMS identified environmental
issues of concern which are presented as follows:
8.6.3.1 Environmental Issues of Concern (EIC)
Zinc Leaching
Tire rubber contains about 1.5 percent zinc as a vulcanization accelerator
within the rubber polymer matrix. Water can gradually leach small amounts of zinc
from the chip into the underlying soil. Traces of zinc serve as a micronutrient for
many species, but excessive quantities can have a negative impact on some plants
and grasses.
Leaching is slow and controlled with water flowing through chips on the
surface of beds, but it could be accelerated by continuous submersion in water or
soil (Gray, 2010).
The following information was obtained from the document "Kanematsua,
Masakazu et al. (2010) Characterization and potential environmental risks of
leachate from shredded rubber mulches". Davis: National Institutes of Health, and is
presented textually to illustrate why Zinc leaching is an environmental issue of
concern on some of the identified markets.
"In order to determine whether shredded rubber mulches (RM)
posed water quality risks when used in stormwater best management
practices (BMPs) such as bioretention basins, batch leaching tests were
conducted to identify and quantify constituents in leachates from RM such
as metal ions
"The results indicate that aqueous extracts of RM contain high
concentrations of zinc (Zn) compared with wood mulches (WM), and its
concentration increased at lower pH and higher temperature.
Leaching of Zn from RM appears to be a potentially larger water
quality issue for RM" (Kanematsua, 2010)".
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Analysis of EIC
Some zinc concentrations on rubber mulch leachate are higher than 20
mg/L, which is the maximum permissible monthly average limit established by
Mexican Official Standard NOM-001-SEMARNAT-1996 for zinc concentrations in
water discharges on national water bodies or soil. Although this regulation does not
directly apply to mulch leachate it provides a reference value of how relevant these
concentrations are.
In mediums with pH of 5 all rubber mulch leachates at any temperature,
ranging from 10°C to 40°C, surpassed zinc concentrations of 10mg/L, which is the
maximum daily authorized average concentration of zinc in waste water discharges
according to the mentioned standard.
Although the study of the NHS encompasses rubber mulch on a very
conservative approach, since the following tire derived applications will be in direct
contact with rain water and soil, it was considered relevant to consider this EIC also
for them.
Tire applications where relevant Zinc leaching may occur:
•	Tire derived geo cells (TDGC).
•	Landscaping edging.
•	Tire derived aggregates (TDA) (bulk).
•	Ground rubber for rubberized asphalt (RA) (bulk).
•	Ground rubber for athletic and recreational surfaces (bulk).
•	Rubber mulch (bulk).
IEMS strongly suggests that the Environmental Impact Assessment (EIA)
performed for the application of any of the markets mentioned above should
consider the impact caused by zinc leaching from tire rubber when in contact with
water. And propose mitigation alternatives to prevent contamination of soil and
ground or surface water bodies.


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Figure 8.1.
Potential income per passenger tire equivalent on each market
$3,000
$2,000
US dollars /PTE
$1,000
$0,000
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Figure 8.2.
Required Investment on processing equipment to produce each tire derived product (US dollars)
$700,000.00
$600,000.00
"(US Dollars) J500.00O.OO
$400,000.00
$300,000.00
$200,000.00
$100,000.00
$0.00
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99
Section 9.
Waste Tires
Appropriate
Disposal
Alternatives
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9 Waste Tires Appropriate Disposal Alternatives
	9.1 Methodology	
The following methodology was followed for the determination of
appropriate disposal alternatives.
	9.1.1 Identification	
Appropriate disposal alternatives in this study are the ones which, as a
base, comply with the legal regulations that apply where the disposal site is located.
Waste tire disposal stakeholders in both sides of the border were interviewed to
gather the required information for this section.
A brief description based on previous publications, studies, regulations,
laws and government agencies data bases, publications, fieldwork and deskwork
data, associations, etc., are presented to educate the reader.
9.1.2 Recommendation
Based on the evaluation results specific recommendations regarding
appropriate tire disposal management are presented.
	9.1.3 Evaluation	
Texas' border region tire disposal alternatives evaluated:
>	Land reclamation projects using tires (LRPUT).
>	Landfills.
Mexico's border area evaluated alternatives:
>	Landfills
>	Tire derived fuel in cement kilns (TDF)
Each local stakeholder should base local disposal guidelines on:
S Social	evaluation:
•	people's way of life;
•	their culture;
•	their community;
•	their political systems;
•	their environment;
•	their health and wellbeing;
•	their personal and property rights;
•	their fears and aspirations;
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S Environmental impacts on:
•	Inert physical media;
•	Living physical media;
S Economic evaluation:
•	Transportation costs;
•	Disposal fees.
	9.2 Identified Disposal Alternatives	
Appropriate tire disposal alternatives identified in the Texas-Mexico border
region and the ones developed by I EMS are the following:
1.	Landfill, shred or cut waste tires;
2.	Burial of whole, shred or cut waste tires in land reclamation projects
using tires (LRPUT);
3.	Burning, shred, cut or whole, waste tires as tire derived fuel in cement
kilns (TDF);
4.	Reclamation of depleted open pit coal mines.
Options 1 and 2 are applied in the U.S. side of the border while only 1 and
3 are applied in the Mexican side of the border. Option 4 was developed by I EMS'
team of engineers and is not yet applied in any side of the border.
Landfills are engineered areas where waste is placed into the land.
Landfills usually have liner systems and other safeguards to prevent polluting the
groundwater.
Modern landfills are well-engineered facilities that are located, designed,
operated, and monitored to ensure compliance with federal regulations. Solid waste
landfills must be designed to protect the environment from contaminants which may
be present in the solid waste stream.
Only split, quartered, or shredded tires may be disposed of in a landfill.
Storage or processing activities must be specified in a landfill's permit and scrap
management registration is required.
According to Mexican remote interviews private landfills in Mexico also
receive waste tires. These are previously shredded in order to prevent them from
floating into the surface.
Landfills in the Texas side of the border area are classified, according to
the type of waste they may receive, as following:
S Type I landfills are authorized to accept municipal solid wastes.
9.3 Landfill Shred or Cut Waste Tires
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$ Type IV landfills are normally more limited in that they may only accept
brush, construction and demolition debris, and other waste that will not
putrefy.
An additional designation "AE" in the landfill type indicates an "arid exempt"
facility, AE landfills normally are limited in the amount of waste they are authorized
to accept.
Image 9.1.
Hogzilla® shredder
Waste tires are considered by Mexican legislation as a special handling
waste. The federal standard NOM-083-SEMARNAT-2003 dictates the
environmental protection specifications for the selection, design, construction,
operation, monitoring, closure and complementary works of an urban solid waste
and special handling waste disposal sites.
This standard classifies final disposal sites (landfills) based on the amount
of daily waste entering to them, in metric tons, as the following table displays.
Table 9.1.
Final disposal sites categories
Type
Tons received Per Day
(Tons / Day)
A
More than 100
B
From 50 to 100
C
From 10 to less than 50
D
Less than10
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9.3.1 Disposal of Cut or Shred Tires in Landfills
Tires present unique and challenging disposal problems because of their
size, shape, and physical and chemical properties. Landfill of whole tires consumes
a large volume of landfill space because the tires are relatively incompressible and
75 percent of the space a tire occupies is empty. In addition, they tend to trap gases
and rise to the top of landfills after being buried. As a result, laws in both Mexico and
the United States prohibit landfill tires along with other types of waste.
In the US, the tire management laws in most states do not ban disposal
outright. In all, 38 states have bans, however, of those states with tire bans, some
states allow disposal if the tires have been shredded, chipped, or halved. To keep
track of who is collecting and transporting tires some states also have put permitting
or registration requirements into legislation. Along the Mexican boundary, solid
waste disposal sites began accepting waste tires that had the sidewalls removed.
There, the tires are buried in the landfill. Waste tires that have been shredded or cut
into three pieces also are allowed to dispose in the landfills.
Private landfills in the Mexican side of the border, such as the Piedras
Negras PASA facility, posses an exclusive cell for shredded of cut waste tire final
disposal. In theory all sanitary landfills which comply with federal legislation in
Mexico are able to receive cut or shred waste tires.
Cutting Process Description
Cutting the sidewalls out of waste passenger tires, and also making at least
one cut across the tread for larger tires are the ways in which a tire must be
processed prior to disposal at a landfill since these methods of processing reduce
the volume of the tire by at least 50% and prevent the tire from retaining water.
	9.4 Land Reclamation Projects Using Tires (LRPUT)
LRPUTs are projects to fill, rehabilitate, improve, or restore already
excavated, deteriorated, or disturbed land, using no more than 50 percent by
volume of tire pieces along with inert fill materials, to restore the land to its
approximate natural grade and to prepare or reclaim the land for reuse. In Texas all
tires used to fill land must be split, quartered, or shredded. Whole tires cannot be
placed belowground. Completed projects must be covered with 18 inches (0.46
meters) of clean soil.
In the state of New Mexico, USA, land reclamation projects are not required
to cut or shred waste tires in order to bury them as it is stated in the New Mexico
Administrative Code (NMAC) 20.9.20 and specifically in 20.9.20.43.
Mexican legislation does not contemplate the use of special handling
wastes such as tires as filling material in abandoned open pit mines. The only
allowed disposal alternative are sites which comply with standard NOM-083-
SEMARNAT-2003.
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Image 9.2.
LRPUT in EI Paso, Texas
	9,5 Tire Derived Fuel (TDF) in Cement Kilns	
Calcinations of raw materials to manufacture clinker (a fundamental
element in the production of cement) which takes place inside of kilns, is the core of
the process within the cement plants; which requires a large amount of energy,
supplied by fuel, which is injected into the kilns, and represents the bigger cost in
the manufacture of cement. High temperatures in kilns and long residence times
inherent to the cement manufacturing process, represent an high potential for the
destruction of organic compounds, which enables the use of a wide variety of fuels,
by-products of other industrial processes or derived from wastes, both solid (waste
tires, wood, paper, cardboard, plastic, urban and industrial sludge, etc.) and liquids
(solvents, used oils, distillation waste, etc.). For this, cement plants meet the
necessary conditions to carry out a clean burning of tires and taking advantage of its
high caloric content instead of petroleum or coal.
No cement kilns are installed in the Texas side of the scope border area,
only one kiln is located in the Mexican side of said border in the city of Ciudad
Juarez, Chihuahua, which has no facilities for the use of tires as TDF.
The General Law for the Prevention and Integral Management of Waste
(Ley General para la Prevention y Gestion Integral de Residues, LGPGIR)
promotes waste valorization, which encompasses the principle and group of
associated actions whose objective is the recovery of the remaining value or caloric
power of the materials which make up wastes, through their incorporation in
productive processes, under shared responsibility criteria, integral management and
environmental, technologic and economic efficiency.
de
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105
	9,6 Reclamation of Depleted Open Pit Coal Mines
Open pit mining is an industrial activity of high environmental, social and
cultural impact. It is an inherently unsustainable industrial activity.
Technical innovations that have experienced mining from the second half of
this century have radically changed the activity, so that it has gone from the
exploitation of underground mines of high quality to exploitation in open pit mines of
lower quality minerals in larger deposit areas.
Open pit mining removes the surface layer or overload the soil to make
accessible the extensive deposits and low quality ores, it is profitable because it is
less expensive than an underground mine (AECO-AT, 2001).
Coal, like all other sources of energy, has a number of environmental
impacts, from both coal mining and coal use. According to World Coal Association,
coal mining raises a number of environmental challenges, including soil erosion,
dust, noise and water pollution, and impacts on local biodiversity.
Image 9.3.
Active open pit coal mine in Coahuila, Mexico
Image 9.4.
Unrehabilitated inactive coal mine in Coahuila, Mexico.

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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
9.6.1 lEMS's Land Reclamation Proposal in Open Pit Mines
In Land Reclamation Projects Using Tires (LRPUT), tires are used as a fill
material on land that has been mined or subjected to significant erosion and is in the
process of being restored (reclaimed). Tires are used to level out the contour of the
land before the land is covered with soil and reseeded. In 2007, about 70.8
thousand tons of scrap tires were used in reclamation projects in the United States.
Reclamation projects were reported in four states: Arkansas, Nebraska, New Mexico
and Texas, being the later one that has the more relative usage of scrap tires in land
reclamation projects (87.8 %).
Land reclamation is commonly used in the United States; the second
largest use category for scrap tires in Texas is Land Reclamation Projects Using
Tires (LRPUT). Shredded scrap tires have routinely been used as fill material in civil
engineering and reclamation projects for a number of years.
Figure 9.1.
Diagram of surface coal mining operations (top) & mine rehabilitation
activities (bottom)
Graded embankment
to act as battle against
noise and dust
~
stripped by motor s<
and carefully stored
~
Overburden from benches
rapers dug by shovels and hauled
by dump trucks
~
Overburden being
excavated by drag
Spoil pile - t
unloads bur
backfill
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107
As a reference: in areas that have been strip mined or mined for sand and
gravel, a 50:50 mixture of tire pieces and soil is usually used as fill material to
reclaim the mined area.
The mine reclamation process proposed by I EMS consist in the use of a cut
tires layer less than 1 meter thick followed by a soil layer with 1 meter thick and then
repeated. Since the mineral coal extracted in Coahuila has 69-86% of carbon, it is
feasible to refill open pit mines with waste tires, whose composition has 85% of total
carbon approximately, practically replacing the coal extracted with a similar carbon
source.
Since carbon mines are to be reclaimed at the end of their life, the
reclamation equipment and machinery could very well be used for the burial of
already cut or shredded tires. This assuming tires disposed by generators are cut or
shredded before being sent for disposal. Figure 9.2. displays a diagram of the
proposed reclamation technique using tires.
Figure 9.2.
Coal mine rehabilitation diagram including intermediate cut-tires layers
To determinate layers thickness, I EMS proposes to apply the Design
Guidelines to Minimize Internal Heating of Tire Shred Fills published by the EPA on
the Scrap Tires: Handbook on Recycling Applications and Management for U.S. and
Mexico (EPA, 2010). According to this report, although there have been no projects
with tire layers less than 4 meters (13.1 feet) that have experienced a catastrophic
heating reaction, to be conservative, tire layers greater than 3 meters (9.8 feet) thick
are not recommended. Additionally no design features are required to minimize
heating of tires layer less than 1 meter thick.
It also recommends that tires are contaminant-free such as oil, grease,
gasoline, diesel fuel, etc., that could create a fire hazard or leachate. In any case the
cut tires shall not contain the remains of tires that have been subjected to a fire
because the heat of a fire may liberate liquid petroleum products from the tire that
could create a fire hazard or leachate when the tires are placed in a fill.
For every cubic meter of volume to be reclaimed 28 passenger tires could
be disposed. Considering millions of cubic meters of coal are extracted from the
mines, a large disposal volume potential is available.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
9.6.1.1 Coal Mining in the Texas Border with Mexico
Currently four coal mines are located in the Texas side of the scope area.
Three of them, located in Webb County, were still in reclamation process on August
2011 which presents a waste tire disposal opportunity for Texas border cities
nearby. Figure 9.3. displays the coal mining locations in Texas.
Figure 9.3.
Permitted coal mines in Texas
Coal Mining Locations
August 2011
Railroad Commission of Texas
Surface Mining and Reclamation Division
=Legend
~ Areas of Geologic Conditions
Relating to Occurrence of Coal
Areas of Geologic Conditions
Relating to Occurrence of Lignite
Q Permitted Coal Mine
[R] Reclamation Only
5.- (Rachal Mine)Farco Mining, Ire. [R]
13.- (Palafox Mine)Farco Mining, Inc. [R]
14 - (Eagle Pass Mine) Dos Republicas Coal Partnership
15.- (Trevino Mine) Farco Mining, Inc. [R]
The currently active Eagle Pass mine could be an appropriate tire disposal
site once it begins reclamation works for Del Rio and Eagle Pass cities which
currently only posses a type 1 landfill for local waste tire disposal.
9.6.1.2 Coal Mining in the State of Coahuila, Mexico
The coal mining industry and the variability of its activity have played a
decisive role in the structuring and regional evolution of the central-eastern and
northeastern areas of Coahuila state. The dependence of this region on mining
exploitation in the absence of other economic activities that constitute real
development alternatives, have made this region become vulnerable because of its
geographical impact due to overexploitation of coal in open pit mines.
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In 2010 State of Coahuila participated with 5.86% mining national
production, occupying the first place in coal, iron and magnesium sulfate production.
Coahuila is the Mexican state with more production of coal.
Mining in Coahuila started in 1828 by extracting coal in mines. The
overexploitation of coal deposits in Coahuila began in the Sabinas basin to serve the
steel industry of Piedras Negras, Monclova and Monterrey. Coal exploitation was
subsequently extended to Fuentes-Rio Escondido Basin as a result of the need to
supply fuel to Rio Escondido and Carbon II power plants.
Figure 9.4.
State of Coahuila, Mexico coal basins
M. MUZQUIZ SABINAS
PARRAS SAITILLO*
Graphical scale
CRETACIC BASINS
.-FUENTES- RIO ESCONDIDO BASIN
I .-SAB IN AS- M ON C LOVA BASIN
SUB BASINS
1.-MONCLOVA
2- SABINAS
3.-	LAS ESPERANZAS 7 - SAN PATRICIO
4.-SAN	SALVADOR 8.-ADJUNTAS
5-EL GAVILAN
6.- SALTILUTO-LAMPACfTOS
TERTIARY BASIN
III.- COLOMBIA-SAN IGNACIO BASIN
CAPITAL CITY ~
MUNICIPAL HEAD. •
STATE LIMIT —
The coal extracted from Coahuila open pit mines is Bituminous and has a
total carbon concentration range of 69-86% as well as high sulfur and ashes
content, so according to international standards, it is considered of poor quality, due
to having a high polluting potential, before and after being extracted, as well as
during its use.
As it was previously mentioned on the LRPUT description current Mexican
legislation doesn't allow the final disposal of special handling wastes on sites unless
they comply with the standard NOM-083-SEMARNAT-2003.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
	9.7 Recommendations	
The Texas-Mexico border region being of great extent does not present a
unique disposal alternative for all of its population. Each city should evaluate
independently which alternative fits its economic and social needs based on the
presented cost estimations and environmental impacts. Nevertheless all alternatives
recommended theoretically comply with their local, state and federal regulations and
are authorized by their corresponding environmental authorities.
By identifying social, environmental and economic impacts in advanced a
stakeholder:
1.	Can make better decisions about which appropriate tire disposal
alternatives to select, how to proceed; and,
2.	Select what mitigation measures can be implemented to minimize the
harm and maximize the social, environmental and economic benefits.
In IEMS' opinion each individual community should perform the following
based on what it's presented in this document and other sources they consider
appropriate:
>	Decisions need to be deduced from principles, and principles need to be
derived from core values. Only by first establishing the core values of the
community of practice, then deriving the principles, and only then
developing guidelines, can truly appropriate guidelines emerge.
>	Guidelines and principles must be developed in participatory processes,
include the people to whom the guidelines are directed. These are the
people who ultimately need to develop 'ownership' of the guidelines if
they are to be adopted and be utilized. (Vanclay, SIA principles, 2003)
9.7.1 Appropriate Tire Disposal Alternatives
Texas international border area appropriate tire disposal alternatives
currently available:
LRPUT being an option which does not occupy landfill space and its used
in a re-habilitation process its more socially and environmentally desirable tire
disposal alternative than landfills. Although both are considered appropriate by this
study.
A. Land Reclamation Projects Using Tires (LRPUT);
B. Type 1 Sanitary Landfills.
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TCEQ authorized tire transporters and processors which finally dispose of
waste tires in these alternatives or other TCEQ authorized alternatives located
further north should also be considered appropriate. This study focus was
specifically on final disposal alternatives, not including intermediaries.
Mexican side of the Texas-Mexico border:
The following attachments present information regarding LRPUTs and Type
1 landfills:
>	Attachment 6. Display map of appropriate tire disposal alternatives
identified in the Texas side of the Texas-Mexico border area.
>	Attachment 7. Display map of appropriate tire disposal alternatives
identified in the Mexican side of the Texas-Mexico border area.
Additional information including:
S List of appropriate tire disposal alternatives identified in the Texas side
of the Texas-Mexico border area and disposal fees charged at the time
this study was written.
S Environmental evaluation regarding the disposal of tires in land
reclamation projects.
S Environmental evaluation regarding tire disposal in a sanitary landfill.
S Approximate driving distances from Texas scope cities to appropriate
tire disposal sites in the Texas side of the Texas-Mexico border area.
S List of appropriate sites in the Texas side of the Texas-Mexico border
area and disposal fees charged at the time this study was written.
S Environmental performance report of using tires as fuel in cement kilns
both in Mexico and the U.S.A.
S Approximate driving distances from Mexican scope cities to appropriate
tire disposal sites in the Mexican side of the Texas-Mexico border area.
S Transportations costs to cement kilns available to the Mexican side of
the Texas-Mexico border area (per city per whole, cut or shredded tire).
Is presented within study Full report attachments for further reference.
	9.7.2 Tire Management Recommendations	
Waste tires should be cut or shred by generators prior to their
transportation. From these actions, transportation and disposal benefits can be
obtained.
A. Tire Derived Fuel in Cement Kilns;
B. Sanitary Landfills complying with standard NOM-089-SEMARNAT-
2003.
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
Table 9.2. presents estimated savings obtained when transporting cut tires
instead of whole tires.
Table 9.2.


Estimated savings when transporting cut tires
instead of whole
Vehicle
Cost/tire/mile
Savings*
whole
cut
Pickup truck
$0,017
$0,010
41%
Pickup with trailer
$0,004
$0,003
29%
Box truck
$0,003
$0,002
27%
Tractor with 48 foot trailer
$0,002
$0,001
38%
'Increasing the gross weight at which a vehicle operates will increase its
fuel consumption (Coyle, 2007) this increase is not considered when
estimating the savings.
As Table 9.2. displays important savings may be obtained when
transporting cut tires instead of whole tires. These savings will be more relevant as
the hauling distance increases. This savings are obtained because of the increase in
the number of tires that can be transported. As an example a 48 foot trailer may
transport approximately 60% more tires if the tires are cut.
Additionally, tire disposal fees are 75% minor when disposing of cut or
shred waste tires in appropriate disposal sites compared to whole tire disposal fees
on the same sites. This occurs because sites no longer need to further process
waste tires in order to landfill or bury them.
9.8 Alternatives Economic Evaluation	
As previously mentioned, two main variables affect the disposal cost:
1.	Transportation costs
2.	Disposal fees
9.8.1 Common Transportation Options
The purpose of evaluating the different transporting options in this section
is to aid the reader in choosing the one which better suits his/her needs. Figure 9.5.
presents the cost per tire (whole and cut) per mile employing each type of
equipment considered for Texas.
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113
Figure 9.5.
Estimated transportation cost per tire per mile
$0,018
$0,016
$0,014
$0,012
$0,010
Transportation costs
(USD/PTE/mile)
Pickup truck

mt

Pickup with trailer

*

Box truck
M4
W-
$0,008



$0,006
$0,004
$0,002



Tractor with 48
foot trailer
Jr—-



$0,000


Whole tires Cut tires

Based on the results presented on Figure 9.5. it is visible that tractors with
trailers are the most cost efficient way to transport cut and whole tires, especially on
large distances. Pickup trucks are the most inefficient in the same way.
As previously mentioned in Table 9.2., important savings may be obtained
when transporting cut tires instead of whole tires. These savings will be more
relevant as the hauling distance increases. This savings are obtained because of
the increase in the number of tires that can be transported. This increase in the
number of tires that can be transported per trip is summarized in Table 9.3.
Table 9.3.
Estimated increase in tires per load capacity when
transporting cut tires instead of whole.
Vehicle
PTE / load
Load capacity
estimated increase
whole
cut
Pickup truck
50
85
70%
Pickup with trailer
250
350
40%
Box truck
400
550
38%
Tractor with 48 foot trailer
1400
2250
61%
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Tire Flow Study in the Texas-Mexico Border Region
Executive Summary
It is worth mentioning that cost efficiency when transporting shredded tires
on the mentioned vehicles and equipment would not further increase since their
maximum payload capacity is already reached when transporting cut tires.
	9.9 Disposal Fees per Tire	
Disposal costs per tire are presented separately for the Texas and Mexican
sides of the border.
9.9.1 Texas Side of the Border
A full list of costs for appropriate tire disposal alternatives identified in the
Texas side of the Texas-Mexico border area and disposal fees charged at the time
this study was written is presented on Attachment 44 of the study Full report.
Since the tire disposal in reclamation of depleted open pit coal mines sites
alternative is not currently being applied there is no available data regarding
disposal fees that could be charged by the site owner. It could be presumed that
fees would be similar to the ones charged on LRPUT currently working on the
border area.
9.9.2 Mexico's Side of the Border
A full list of costs for appropriate tire disposal alternatives identified in the
Mexican side of the Texas-Mexico border area and disposal fees charged at the
time this study was written is presented on Attachment 49 of the study Full report.
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Attachments
ATTACHMENT 1
Ultimate disposal locations of
waste tires that are being
transported from Texas into
Mexico
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Tire Flow Study in the Texas-Mexico Border Region
Attachment 1
Table 1.
Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border
area
General Data
Accumulated
waste tires
(tires)
Directions to the site
si
(UT
te's coordinates
M, Datum WGS84)
Elevation
Id
#
Municipality
State
Zone
X
Y
(FASL)
(MASL)
1
Matamoros
Tamaulipas
2,250,000
"Ejido of Guadalupe".
Road to Reynosa Km 11.5 (7.15
miles)
14
642436
2866898
33
10
2
Rio Bravo
Tamaulipas
32,000
Taking federal highway 2 (Reynosa-
Matamoros) turn right 4.17 km (2.59
miles) after "Camioneta Tahoe" road.
Cross a ditch and continue 3.45km
(2.14 miles), turn right and continue
400m (0.25 miles)
14
598665
2868165
89
27
3
Reynosa
Tamaulipas
200,000
Open air dump "Las Anacuas".
Taking the Reynosa-San Fernando
road, turn right on "Beatriz Velazco"
(or "Puerto Escondido"), then turn left
on "Prolongacion Boulevard Loma
Bonita", continue 1.42Km (0.89
miles), the road will turn right,
continue 1.17Km (0.72 miles) and the
disposal site is located on the right
side of the road.
14
568689
2876212
194
59
4
Reynosa*
Tamaulipas*
50,000*
Open air dump "Las Calabazas"*
14*
Unknown*
Unknown*
Unknown*
Unknown*
5
Reynosa*
Tamaulipas*
50,000*
Open air dump "Corrales"* UTM
coordinates point an approximate
location.
14*
575974.53*
2882372.51*
0*
0*
0\
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Tire Flow Study in the Texas-Mexico Border Region
Attachment 1
Table 1.
Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border
area
General Data
Accumulated
waste tires
(tires)
Directions to the site
si
(UT
te's coordinates
M, Datum WGS84)
Elevation
Id
#
Municipality
State
Zone
X
Y
(FASL)
(MASL)
6
Reynosa*
Tamaulipas*
50,000*
Open air dump "Cumbres"*
14*
Unknown*
Unknown*
Unknown*
Unknown*
7
Reynosa*
Tamaulipas*
50,000*
"Las Colmenas" Landfill*
14*
Unknown*
Unknown*
Unknown*
Unknown*
8
Reynosa*
Tamaulipas*
50,000*
"Alto Bonito" Landfill*
14*
Unknown*
Unknown*
Unknown*
Unknown*
9
Reynosa
Tamaulipas
200
Km 187.5 (116.5 miles) Monterrey-
Reynosa road. UTM coordinates
point an approximate location.
14
558979
2880564
263
80
10
Gustavo Dias
Ordaz
Tamaulipas
Unknown
4Km (2.48 miles) taking the road to
Monterrey from Gustavo Diaz Ordaz
city.
14
541240
2897625
125
38
11
Camargo
Tamaulipas
800
"Las Flores" colony municipal yards.
Entering Camargo city from Reynosa
turn right on "Acceso No. 4" Drive
750 meters (0.465 miles) then turn
left. Continue one block to arrive to
the municipal grounds. UTM
coordinates point an approximate
location.
14
518635
2910553
164
50
12
Miguel Aleman
Tamaulipas
3,000
Located on the "5 de Junio" overpass
in "Rodriguez" colony. UTM
coordinates point an approximate
location.
14
496410
2920211
0
0
0\
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Tire Flow Study in the Texas-Mexico Border Region
Attachment 1
Table 1.
Ultimate disposal locations of waste tires that are being transported from
area
Texas into Mexico on the Texas-Mexico border
General Data
Accumulated
waste tires
(tires)
Directions to the site
si
(UT
te's coordinates
M, Datum WGS84)
Elevation
Id
#
Municipality
State
Zone
X
Y
(FASL)
(MASL)
13
Guerrero
Tamaulipas
200
"General Lazaro Cardenaz" street
corner with "Adrian Gonzalez
Gonzalez". Take "Avenida Hermanos
Gutierrez de Lara" towards the city
center, turn left on "sexta", and
continue 3 blocks west. Behind the
city's cemetery.
14
475931
2938002
325
99
14
Nuevo Laredo
Tamaulipas
Unknown, site
was remediated
on year 2012
Integral center for the handling of
waste tires. Located on Km 18 (11.2
miles) of national highway Mexico 85.
Take Nuevo Laredo-Sabinas Hidalgo
road (Mexico 85) continue 11,88km
(7.38 miles) starting from the corner
with "Luis Donaldo Colosio"
boulevard, then turn left and continue
1.5 km (0.96 miles) towards east.
14
443827
3022773
446
136
15
Anahuac
Nuevo Leon
13,000
6.5 Km (4 miles) from the city center
on the Anahuac-Nuevo Laredo road,
on the left side.
14
392412.45
3016770
686
209
16
Cerralvo*
Nuevo
Leon*
200*
Not available*
14*
445886*
2888049*
Unknown*
Unknown*
17
Cerralvo*
Nuevo
Leon*
Unknown*
Not available*
14*
442743*
2888198*
Unknown*
Unknown*
iJBL\	£&
1 f i j
Printed on 100% recycled fiber paper using solid ink	# | E M S
.....................
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 1
Table 1.
Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border
area
General Data
Accumulated
waste tires
(tires)
Directions to the site
si
(UT
te's coordinates
M, Datum WGS84)
Elevation
Id
#
Municipality
State
Zone
X
Y
(FASL)
(MASL)
18
Cerralvo*
Nuevo
Leon*
Unknown*
Not available*
14*
442709*
2888207*
Unknown*
Unknown*
19
Cerralvo*
Nuevo
Leon*
1,500*
Not available*
14*
442706*
2888060*
Unknown*
Unknown*
20
Sabinas
Hidalgo*
Nuevo
Leon*
8,000*
Not available*
14*
384468*
2926343*
Unknown*
Unknown*
21
Los Aldamas*
Nuevo
Leon*
230*
Not available*
14*
480135*
2881301*
Unknown*
Unknown*
22
Los Aldamas*
Nuevo
Leon*
Unknown*
Not available*
14*
480115*
2881384*
Unknown*
Unknown*
23
Los Aldamas*
Nuevo
Leon*
Unknown*
Not available*
14*
480099*
2881301*
Unknown*
Unknown*
24
General Bravo*
Nuevo
Leon*
450*
Not available*
14*
481032*
2846332*
Unknown*
Unknown*
25
General Bravo*
Nuevo
Leon*
Unknown*
Not available*
14*
480653*
2846462*
Unknown*
Unknown*
26
General Bravo*
Nuevo
Leon*
Unknown*
Not available*
14*
481099*
2846526*
Unknown*
Unknown*
27
General Bravo*
Nuevo
Leon*
Unknown*
Not available*
14*
480626*
2846671*
Unknown*
Unknown*
28
Vallecillo*
Nuevo
Leon*
65*
Not available*
14*
402210*
2948724*
Unknown*
Unknown*
29
Vallecillo*
Nuevo
Leon*
Unknown*
Not available*
14*
402182*
2948764*
Unknown*
Unknown*
0\
Printed on 100% recycled fiber paper using solid ink	\	*
%
/


V ^	I.JEM	S
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 1
Table 1.
Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border
area
General Data
Accumulated
waste tires
(tires)
Directions to the site
si
(UT
te's coordinates
M, Datum WGS84)
Elevation
Id
#
Municipality
State
Zone
X
Y
(FASL)
(MASL)
30
Vallecillo*
Nuevo
Leon*
Unknown*
Not available*
14*
402393*
2948827*
Unknown*
Unknown*
31
Acuna
Coahuila
200,000
Acuna-Santa Eulalia road 7.18km
(4.46miles) from the "Emilio
Mendoza Cisneros" overpass.
14
299864
3245347
1085
330
32
Piedras Negras
Coahuila
115,500
Taking the Piedras Negras-Acuna
road (Federal 2), turn right 7.5km
(4.64miles) after the "Manuel Perez
Trevino" overpass and drive north
800m (0.5miles).
14
345497
3182226
833
254
33
Nava
Coahuila
1,000
Progreso street, 2km (1.24 miles)
west of downtown Nava.
14
328493
3143850
1049
321
34
Ojinaga
Chihuahua
50,000
Taking the Chihuahua freeway turn
right 8.4km (5.23 miles) after
crossing the overpass with the road
to Camargo (Avenida de la
Juventud). The site is located
100meters (328 feet) from the
freeway.
13
548717
3269389
2684
818
0\
Printed on 100% recycled fiber paper using solid ink	\	*
%
/


de
I EMS
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Tire Flow Study in the Texas-Mexico Border Region
Attachment 1
Table 1.
Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border
area
General Data
Accumulated
waste tires
(tires)
Directions to the site
si
(UT
te's coordinates
M, Datum WGS84)
Elevation
Id
#
Municipality
State
Zone
X
Y
(FASL)
(MASL)
35
Juarez
Chihuahua
2,500,000
Located at km 27.5 (17 miles) of the
Panamerican freeway (Mexico 45).
Taking Mexico 45 towards the south
turn right 6Km (3.72 miles) after
crossing Federal 2 freeway, finally
continue 1.5 km (0.93 miles) towards
the west.
13
358959
3492229
4065
1239
36
Matamoros
Tamaulipas
400,000
Federal Freeway number 101, Km.
21 (75.2 miles) without number, turn
right and follow the road 1.54Km
(0.96 miles)
14
641485
2843741
23
7
* Means data was not confirmed with a key stakeholder, it is presented as it was obtained from previous tire pile inventories mentioned on Chapter 3 and public
Geographical Information Systems.
Tire sites 16 to 30 are not located within the study's selected search area but are located within 100km from the Texas-Mexico border.
MASL = meters above sea level.
FASL = feet above sea level
0\
Printed on 100% recycled fiber paper using solid ink	\	*
%
/


de
I EMS
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Tire Flow Study in the Texas-Mexico Border Region
Attachments
ATTACHMENT 2
Operation and management
procedures of each waste tires
accumulation site of the Mexican
side of the Texas-Mexico border
area
Printed on 100% recycled fiber paper using solid ink
tfto srAf
& 	 Ss>
PROlt0
/
CO
1
a
$



de
I EMS
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data
Number of waste
tires accumulated
Operation and management procedures
Id
#
Municipality
State
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
1
Matamoros
Tamaulipas
2,250,000
Municipal
government
Municipal
Waste Tires
Collection
Center
All waste tires collected in
the cleaning of drainage
ditches, junk collection
programs, incidentally
collected by garbage
trucks, disposed by
factories, among other
sources used to be taken
to this collection and
storage center by the
municipal authorities. Site
is currently not receiving
waste tires, they are being
sent to the landfill waste
tire storage center.
Tires are sent to a cement
kiln to be used as Tire
Derived Fuel (TDF) in the
city of Monterrey, state of
Nuevo Leon, Mexico. 32,000
waste tires were sent on the
year 2011.
Active
2
Rio Bravo
Tamaulipas
32,000
Municipal
government
Municipal
Landfill and
waste tires
storage center
Waste tires are collected
by the municipal
government employees
from people's homes and
taken to the storage
center.
Non
Active
3
Reynosa
Tamaulipas
200,000
Municipal
government
City open-air
dump.
Municipal employees
collect the waste tires
throughout the city and
leave them in the open air
dump.
On 2010 nearly 800,000
waste tires were burned in a
fire.
Active
Printed on 100% recycled fiber paper using solid ink
i Q \
Kmj


I € H S
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data
Number of waste
tires accumulated
Operation and management procedures
Id
#
Municipality
State
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
4
Reynosa *
Tamaulipas*
50,000*
Unknown*
Open air dump
"Las
Calabazas"*
Unknown*
Unknown*
Active*
5
Reynosa *
Tamaulipas*
50,000*
Unknown*
Open air dump
"Corrales"*
Unknown*
Unknown*
Active*
6
Reynosa *
Tamaulipas*
50,000*
Unknown*
Open air dump
"Cumbres"*
Unknown*
Unknown*
Active*
7
Reynosa *
Tamaulipas*
50,000*
Unknown*
"Las Colmenas"
Landfill*
Unknown*
Unknown*
Active*
8
Reynosa *
Tamaulipas*
50,000*
Unknown*
"Alto Bonito"
Landfill*
Unknown*
Unknown*
Active*
9
Reynosa
Tamaulipas
200
Private
company:
RECOde
Reynosa S.A.
de C.V.
Private landfill.
Waste tires generated by
their own vehicles or
accidentally introduced
into garbage collecting
trucks.
Waste tires are used within
the landfill to delineate
roads, to create planters and
when 100 waste tires are
accumulated they are used
as daily cell base.
Inactive
10
Gustavo Dias
Ordaz
Tamaulipas
Unknown
Municipal
government
Open air dump.
Waste tires are taken and
dumped into the municipal
open air dump.
Waste tires are burned as
they arrive to the municipal
open air dump.
Active
0\
J ?
Printed on 100% recycled fiber paper using solid ink	\	#¦
%
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data

Operation and management procedures
Id
#
Municipality
State
Number of waste
tires accumulated
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
11
Camargo
Tamaulipas
800
Municipal
government
Municipal
Waste Tires
Collection
Center
Tires are collected and
stored were the municipal
junk yard was located
waiting to be processed.
Non
Active
12
Miguel Aleman
Tamaulipas
3,000
Municipal
government
Provisional
Municipal
Waste Tires
Collection
Center
Tires are collected and
stored on the municipal
fair grounds.
During a period of time
waste tires were sent to
Nuevo Laredo for their
handling. Actually they are
stored waiting for disposal
due to a lack of budget.
Active
13
Guerrero
Tamaulipas
200
Municipal
government
Municipal open-
air dump
Tires are collected and
sent to the open air
municipal dump.
The Mexican armed forces
use them as barricades. Also
400 waste tires were lost
during a fire.
Active
14
Nuevo Laredo
Tamaulipas
Unknown, during
year 2012 site was
remediated
Municipal
government
Storage center
Waste tires are collected
on 5 mobile collection
centers by the
environmental municipal
authority, taken to the
storage center where they
are counted.
Waste tires are shredded
and sent to the city of Ramos
Arizpe in the state of
Coahuila, Mexico to be used
as Tire Derived Fuel (TDF) in
a cement kiln. 300,000 waste
tires were burned during a
fire in August 2011.
Active
Printed on 100% recycled fiber paper using solid ink
i Q \
r«L PBOl4-0


I € H S
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data
Number of waste
tires accumulated
Operation and management procedures
Id
#
Municipality
State
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
15
Anahuac
Nuevo Leon
13,000
Municipal
government
Municipal
Landfill
Tires are collected by the
municipal authorities from
tire repair shop and stored
in a storage center
adjacent to the city landfill.
Also the inhabitants
dispose of their waste tires
on said location.
Waste tires are sent to the
city of Monterrey in the state
of Nuevo Leon, Mexico were
they are shredded and used
as Tire Derived Fuel (TDF) in
cement Kilns or sent to a
state managed landfill.
Active
16
Cerralvo*
Nuevo
Leon*
200*
Not available*
Unknown*
Unknown*
Unknown*
Inactive*
17
Cerralvo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
18
Cerralvo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
19
Cerralvo*
Nuevo
Leon*
1,500*
Not available*
Unknown*
Unknown*
Unknown*
Inactive*
20
Sabinas Hidalgo*
Nuevo
Leon*
8,000*
Not available*
Unknown*
Unknown*
Unknown*
Active*
21
Los Aldamas*
Nuevo
Leon*
230*
Not available*
Unknown*
Unknown*
Unknown*
Inactive*
22
Los Aldamas*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
23
Los Aldamas*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
Printed on 100% recycled fiber paper using solid ink
i Q \
r«L PBOl4-0


I € H S
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data
Number of waste
tires accumulated
Operation and management procedures
Id
#
Municipality
State
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
24
Gral. Bravo*
Nuevo
Leon*
450*
Not available*
Unknown*
Unknown*
Unknown*
Active*
25
Gral. Bravo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
26
Gral. Bravo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
27
Gral. Bravo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
28
Vallecillo*
Nuevo
Leon*
65*
Not available*
Unknown*
Unknown*
Unknown*
Inactive*
29
Vallecillo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
30
Vallecillo*
Nuevo
Leon*
Unknown*
Not available*
Unknown*
Unknown*
Unknown*
Unknown*
31
Acuna
Coahuila
200,000
Municipal
government
Municipal
Landfill
Waste tires are taken to
collection centers by tire
repair shops personnel
and by regular people
motivated by different
education campaigns.
Then taken to a storage
center by the Ecology
municipal authorities.
Non
Active
Printed on 100% recycled fiber paper using solid ink
i Q \
r«L PBOl4-0


I € H S
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data
Number of waste
tires accumulated
Operation and management procedures
Id
#
Municipality
State
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
32
Piedras Negras
Coahuila
115,500
Promotora
Ambiental S.A.
De C.V.
Private landfill.
The municipal Ecology
and Urban Image
department picks up the
tires throughout the city
and takes them to the
private company landfill.
Tires are shredded and
buried in an exclusive cell.
Also waste tires were
transported, by train, to the
city of Torreon, state of
Coahuila, Mexico for their
handling.
Active
33
Nava
Coahuila
1,000
Municipal
government
Storage center
Tires are collected from
tire repair shops by
municipal workers and
accumulated in a storage
center adjacent to the
municipal landfill waiting
for an adequate disposal.
Inhabitants also take there
their waste tires.
Non
Active
34
Ojinaga
Chihuahua
50,000
Municipal
government
Storage center
Tires are collected from
tire repair shops by
municipal public services
workers and accumulated
in a storage center
adjacent to the municipal
landfill waiting for an
adequate disposal.
Non
Active
Printed on 100% recycled fiber paper using solid ink
i Q \
r«L PBOl4-0


I € H S
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachment 2
Table 1.
Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border
area
General Data
Number of waste
tires accumulated
Operation and management procedures
Id
#
Municipality
State
Responsible
of the site's
management
Type of site
Waste tires inflow
source
Waste tires outflow
destiny
Status
35
Juarez
Chihuahua
2,500,000
Municipal
government
Storage center
Tires are accumulated in
a storage center adjacent
to the municipal landfill.
Tires are sent to a cement
kiln to be used as Tire
Derived Fuel (TDF).
Active
36
Matamoros
Tamaulipas
400,000
Municipal
government
Municipal
landfill waste
tire storage
center
Waste tires collected in
the cleaning of drainage
ditches, junk collection
programs, incidentally
collected by garbage
trucks, disposed by
factories, among other
sources are taken to the
collection and storage
center by the municipal
authorities.
Tires are cut in four pieces
by a machine. Then the
pieces are accumulated.
Active
* Means data was not confirmed with a key stakeholder, it is presented as it was obtained from previous tire pile inventories mentioned on section 2.0.1 of the Chapter 3.
Tire sites 16 to 30 are not located within the study's selected search area but are located within 100km from the Texas-Mexico border.
The information presented on this attachment was obtained through remote interviews with the key stakeholders mentioned on Attachment 1.
0\
J ?
Printed on 100% recycled fiber paper using solid ink	\	#¦
%
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachments
ATTACHMENT 3
Ultimate disposal locations map
of waste tires being transported
from Texas into Mexico
Printed on 100% recycled fiber paper using solid ink
tfto srAf
& 	 Ss>
PROlt0
/
CO
1
a
$



de
I EMS
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LaiCruco*
Ciudad
El PaTo*Juirez

CarKbad
'itta&llupe Pt&k
Tylriw
35
TEXAS
*- T
^ K.
**» ^
.Midland
'od«M
ian Angelo
.Waco
Killeen
TEXAS
College
Bryan •. Walton
Austin
i34
Ojm;
Chihuahua
t# Cuauhtemoc
HIHUAHUA
wr
.Delia as
MEXICO
CCAHUIt A
¦ ¦' ¦ i '
hid <<90
del Pan aj

ROM I
\

c-drasNegras
Sabine

San Antonio.
•Victoria
Corpus Chns b
Moridova
Site's Identification
Numbers
1,14,34,33, 29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.

Approximate amount of waste tires per pile:
^>1.000,000 d0,000.99,999 ^Quanmy
^ 100.000 - 1 000,00( JL 500 - 9,999
unknown
• <500 Non
significant
29 OQ
30^1 13. 12/
N,r?0^8 «dti1/
17—Aj 21 "*4
* ipjf VT _
Monterrey. 2g -V\ 3 2
' 2y?4)2 23
	27	ff	
Saltillo
ownsville
I EMS
iuue UtirrdLe
dspc6d latere
CLIENT.
N AD B
PROJECT.
432.01
LOCATION
Texas-Mexico
Border Region
LATE.
1 / 02 / 201 2
c •
TheV
CRW BY
E ste ban lb a rra
3-.AI F
1:5'900,000
MK
RV
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachments
ATTACHMENT 4
Waste tire sites display map per
Mexican city
Printed on 100% recycled fiber paper using solid ink




o
lie
%
I EMS
-------
345000
350000
355000
360000
365000
370000
375000
Msntwood 0
Paso
1
cot>9< s
"• In V»nl« 5
• \ 9 Avc Vicente Guerrefo
_ A w
FLORES
O


Ciudad Juarez *
¦iV /V A	^ •
• yjK • $

X.v


•&
• •
-fc* • ***
Abraham Gonzalez
Intl Aii^diT •
+ *•
r

A
y
•V
\
ZARAGOZA^I
» SOCORRO
\ °
\

Site's Identification
Numbers
1,14,34,33, 29,24,
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
35
J.
International borderline.
^Principal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
tT
\\ \
%
5 km
	 watercourse, (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/k. Possible illegal tire pile
# Possi ble Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Ciudad Juarez
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Ciudad Juarez
Chihuahua, Mexico.
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
548000
550000
552000
554000
556000
558000
560000
\
s

Unldad Hab Rovlssste ijouv»in Bivd
> Rio
203

34
Ciudad Ojinaga Centro	J Brav(s > ynrk.,
Manuel	^ EmHiatao L~J or»iiiy st Presidio
Ojinaga	* Zapato
• Ojinaga	% '* A
r •	4 Z \ *-	^
\ V • 'v %
16
Ejido
Canada
Ancha >
Porflri<* ^ c
Ornelas
¦v»* 1 »
oX

I 0
» »

•, v
"• o
aV* ° ^
\L
\
Tarahutnara
N
n
H
1
2 km
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possible Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Ojinaga
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Ojinaga
Chihuahua, Mexico.
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
300000
302000
304000
306000
308000
310000
312000
V
314000
239
31
Ciudad *cU
ft* 5

O
o
3"


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• <¦. "*»/>,
Independence %
V •	r*(3rt
\	• 0 •
Aeropuerto Intl
•	D«£iud3d
^ • Af iiri.i
'•"•ro,
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Cap lM|.
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GuadaluP* V
Acuria
j 0* Abni
El Porvenir
Vista
Hermosa
"» "2
o> v
o.
*
B
>
29
2 km
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possi ble Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Acuna
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Acuna
Coahuila, Mexico.
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
Pi «tras
Negras In#
Airport
338000
344000
350000
356000
362000
Approximate amount of waste tires per pile:
1>1'000,000 ^10,000-99,999 ,Quantity
'	• unknown
100,000 - 1'000,000 J 500 - 9,999 *Sannl
TITLE
Piedras Negras
sites display map.
432.01
DATE
23/08/2012
SCALE.
Graphic
CUENT.
N A D B
LOCATION.
Piedras Negras
Coahuila, Mexico.
DRAWN BY.
Marcel Lopez
International borderline.
^EPrincipal road.
.Secondary road.
^Minor road.
OTown.
^Perennial lake.
	1	1	Rail.
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
wa te r CO U r se . (presence of water not implied)
Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/a. Possible illegal tire pile
• Possible Junkyard .
SANTO DOMING O
° /
-------
325000
326000
etera Nava-Morelo*
327000
\
328000
f
// ; y/
Ejldo
Ef Encino
<*
329000
330000
331000
Ca''

,c\°v
,P<
ed<:
.*e
1
VIacJaDe/e
Primavera
Alamo
Francisco Gomez Farias
EJido
Acacia
6^

Ca,
'^ter
Vav,

n
~
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tp
2 st>
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Mondragon
Nava
5 n £¦
£ *2
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//
£
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Juan Aldama?
Q
Ign aci  L opei Ray on
Francisco Javier Mina
Nicolas Bravo
in rail *
Mariano Matamorosjj
I	<*
33
o
o
5
w
1 km
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possible Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Nava
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Nava
Coahuila, Mexico.
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
386000
387500
389000
390500
392000
393500
15 4.

_ o Coahulla
o.\
Z
%
 -
\\
X%


Maiz
ijr



Hospital 1'000,000 ^10,000-99,999 ,Quantity
• ' ' "unknown
100,000 - 1 '000,000 d 500 -9,999 *2^°" I EMS
TITLE
Anahuac
sites display map.
CUENT.
NADB
432.01
LOCATION.
Anahuac
Nuevo Leon,
Mexico.
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
434000
438000
442000
446000
450000
454000
458000
462000
Laredo
4
< •
S NUEVO LAREDO
t) *
a
o •
"A
y
Quetzal®atl *
Intl Airport
,*o
EL DESIER
ENHANCES
85
14
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
Guadalupe St

4 km
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal bord<
Urban area.	A Possible illegal
• Possible Junkyard.
i rl i ne .
ti re pile
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Nuevo Laredo
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Nuevo Laredo
Tamaulipas, Mexico
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
476000	476500	477000	477500	478000	478500
13


\

«/•?-
Ruiz
Cortlnes
\ \

5 Avenida tOOe Oclub»e |
V * i	I
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•V *v,
\ >
y\ i
Carr*te(a Nuovc Laiedo-Reynoaa
Gu«r««ro
tiik

Cardura Nuwo larvdo-
1.5 km
8
O
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possible Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Nueva Cd.
Guerrero
gffii^rspnw-^raTr
N A D B
432.01
LOCATION.
Nueva Cd. Guerrero
Tamaulipas, Mexico
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
489500
491000
492500
494000
495500
497000
498500
500000
\
X
\
'WlBO


\ 1
W|
x
•	Lo*
Guerra
jdes Maria Mor«c
Fiacc
Industrial
Poniente
12
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Fracc
Jardines D«
SoFGerin m\
Benito
Juarez
social
Mezquita!
Ocl
Rio Ciudad
Miguel Bruno**'
® Aleman,nl0navU
Rlnconoda
a
Arguollo
» ! £
\l '1
,T Miguel v
Fracc Aleman Centrq
San Pedro
% \
"~mbrr
Independent
Fracc
i-~i	Nuevo
Rom.J
Cludad
Miguel
Oaftciat
0	j Parqut
1	1 ln1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Miguel Aleman
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Miguel Aleman
Tamaulipas, Mexico
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
512000	514000	516000	518000	520000	522000	524000
Ciudad
<-.j?
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
Approximate amount of waste tires per pile:
1>1'000,000 ^10,000-99,999 ,Quantity
'	• unknown
100,000 - 1'000,000 J 500 - 9,999 *Sannl
TITLE
Camargo
sites display map.
432.01
DATE
23/08/2012
SCALE.
Graphic
CUENT.
N A D B
LOCATION.
Camargo
Tamaulipas, Mexico
DRAWN BY.
Marcel Lopez
I nternational border line .
^^sPrincipal road.
.Secondary road.
iMinor road.
°To wn .
^Perennial lake.
-i	1	1	Rail.
•watercourse, (presence of water not implied)
Non perennial strear
Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possi ble Junkyard .
Res Los
Angeles
Camargo C(udad ± 11
r Camargo Centro
1		P	
c. 5
'•tera Nu#vo Lar#do-R«yn0#a
-------
^ Terron
o o d o
^ ¦>
¦2 *, Cludad Gustavo
Diaz Ordaz Centro
Ciudad
Gustavo \
Diaz Ordaz C ?
539000	540000	541000	542000	543000	544000	545000
Approximate amount of waste tires per pile:
1>1'000,000 ^10,000-99,999 ,Quantity
'	• unknown
100,000 - 1'000,000 J 500 - 9,999 *Sannl
TITLE
Gustavo Diaz Ordaz
sites display map.
432.01
DATE
23/08/2012
SCALE.
Graphic
CUENT.
N A D B
LOCATION.
Gustavo Diaz Ordaz
Tarnaulipas, Mexico
DRAWN BY.
Marcel Lopez
Site's Identification
Numbers
1,14,34,33,29,24,
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
I nternational border line .		watercourse, (presence of water not implied)
^Principal road.	•	Non perennial stream.
.Secondary road.	^^Airport.		Mu n i ci pa I borde rl i ne .
~Minor road.
^iMinor roaa.	i	1
OTown.	Urban area.	^.Possible illegal tire pile
Perennial lake
Perennial lake.
	1	1	Rail.	® Possible Junkyard .
Sarh
2
Pre
-------
556000
562000
568000
574000
\*
115
cOr
HIDALGO 281
580000
u
in

241
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\
• •
• •
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• •
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•%	i	^
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••
GdieraWLucio
Blanco tir»tl An port
4* •
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
6 km
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possible Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Reynosa
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Reynosa
Tamaulipas, Mexico
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
587910
589910
591910
593910
595910
597910
/
Bl*°
"M

ov'o Mar

* !? €
t « i.
si 2
on««Jlrw
t •
i i V
e « *(
Calba *
*	Ebanoi
3 Oral tkVBdf1
'i ri
? I «
Ciudad £
Rio Bravo
ChinuAua
Son or a
•U
3» "
3
£¦
Graciano
Sanchez
Did
. *ai«(
Cant Ira

T
r(fc Hae.ones Unrtfas ^
Avcri-.i	- r'r-fi.i
^vm c > Ri Br^o
Cuauhtemoc

• a
C o.ihui) J
H«rtiar Coftw
I
3 -
S
8
O
o
o
IJ
Condtta
*'«v
«o*f,
Jrf/ C
Am pi

Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile
2 km
2
International borderline.
iPrincipal road.
.Secondary road.
^Minor road .
OTown.
^Perennial lake.
	1	1— Rail.
wa tercourse. (presence of water not implied)
........... Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/*. Possible illegal tire pile
• Possi ble Junkyard .
i
Approximate amount of waste tires per pile:
>1'000,000	j| 10,000-99,999
Quantity
"'unknown
100,000 - 1 000,000 d 500 -9,999
• <500 Non
significant
I EMS
TITLE
Rio Bravo
sites display map.
CUENT.
N A D B
432.01
LOCATION.
Rio Bravo
Tamaulipas, Mexico
DATE
23/08/2012
DRAWN BY.
Marcel Lopez
SCALE.
Graphic
El
RV
-------
'HTROL
Brownsville South Padre
Island Intl Airport-^
Brown svil le
California Rd
MATAMokofe
General Servando
Canales Intl Airport
620000	626000	632000	638000	644000	650000	656000	662000
Approximate amount of waste tires per pile:
1>1'000,000 ^10,000-99,999 ,Quantity
'	• unknown
100,000 - 1'000,000 J 500 - 9,999 *Sannl
TITLE
Matamoros
sites display map.
432.01
DATE
23/08/2012
SCALE.
Graphic
CUENT.
N A D B
LOCATION.
Matamoros
Tamaulipas, Mexico
DRAWN BY.
Marcel Lopez

-—
V~ - if
i

r *
Site's Identification
Numbers
[1,14,34,33,29,24.
The color of the Id. number depends on
the approximate amount of waste tires in
the pile.
wa te r CO U r S© . (presence of water not implied)
Non perennial stream.
^^Airport.		Municipal borderline.
Urban area.	/a. Possible illegal tire pile
• Possible Junkyard .
I nternational border line .
^^sPrincipal road.
.Secondary road.
iMinor road.
°To wn .
^Perennial lake.
-i	1	1	Rail.
I N
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachments
ATTACHMENT 5
Crackdown on Illegal Dumping -
Handbook for Loca l Government
Printed on 100% recycled fiber paper using solid ink
SI.
&


0
lie
%
I EMS
-------
4.0 ILLEGAL DUMPING PREVENTION TECHNIQUES
When researchers at University College London studied
the opportunities that give rise to illegal dumping
they found that conventional enforcement tactics can
sometimes reduce the activity quickly but the effects
soon fade without additional preventive measures.
Whereas well-designed and well-focused illegal
dumping prevention programs can have a substantial
and long-term impact on illegal dumping.12
Which techniques councils choose to adopt will depend
on the analysis of existing data and information.
Importantly, the decision must focus on the mechanism
most suited to the problem, for example, increase
the effort or reduce the rewards, before going on to
select the particular technique that's most likely to
trigger it. Too often practitioners jump to the technique
before thinking through how it is supposed to work
and whether this is likely in the circumstances of the
particular problem.
You will then need to monitor how it is done and the
outcome to identify the need for any further intervention.
This may involve refining the initial response, or if
necessary trying something completely different.
It may also be necessary to keep an eye on newly
emerging problems so that they can be dealt with as
quickly as possible. Where appropriate, a combination
of mechanisms, if used strategically, can often be more
effective.12
Figure 17 summarises the techniques you can use to
tackle illegal dumping.
4.1 Increase the effort: make
access difficult
In most cases illegal dumping takes very little effort.
It can take more effort to dispose of waste legally than
to dump it illegally. Councils can change the balance to
make it easier to comply with the law and make it harder
to not do so. Many areas continue to experience illegal
dumping problems after being cleaned up. Effective
structural solutions will increase the effort and risk of
being caught thereby deterring offenders. Structural
solutions can reduce accessibility to popular sites for
illegal dumping.12 A clean up plus introducing signs,
lighting, barriers, landscaping or increasing the visibility
of a site can contribute to reducing or eliminating
continued dumping.
Structural approaches
Councils across NSW have used the following structural
approaches, usually combined with a mix of education
and regulation.
Lighting
When lighting is used in other crime prevention
strategies it can be an effective deterrent in poorly lit
or remote areas. This may be useful where dumping
occurs under the cover of darkness. Additional lighting
increases the visibility of the offender and increases the
risk of being caught. The impact of sensor lights has yet
to be evaluated.
o
Solar lights in
hotspots
City of Canada Bay Council installed solar
lights and signs in a dumping hot spot.
Outcome
The enhanced lighting has deterred
dumping in the area and resulted in fewer
complaints to the council. Anecdotal
opinion is that other known dumping areas
near this hot spot are also experiencing less
illegal dumping.
Crackdown on Illegal Dumping - Handbook for Local Government 37
-------
©
Figure 17:The five main illegal dumping prevention mechanisms
1. Increase the effort: make access difficult (see Section 4.1)
¦ Make access difficult to hot spots using structural approaches, such as:
•	lighting
•	landscaping, revegetation or beautification
•	barriers, such as fences and locked gates, concrete blocks, logs and boulders and earth mounds.
2. Increase the risk of getting caught (see Section 4.2)
¦
Strengthen surveillance:

• use surveillance cameras and signs to indicate the area is being watched

• increase patrols in hot spots

• assist community surveillance and reporting of suspect activities

• use aerial surveillance in rural and remote areas.
¦
Carry out periodic, high-profile compliance campaigns.
¦
Use partnerships with other councils, agencies and stakeholders.
¦
Publicise successes as widely as possible.
3. Reduce the rewards: deny financial benefits (see Section 4.3)
¦	Provide and/or promote free or subsidised waste services.
¦	Issue fines to offenders.
¦	Require offenders to clean up.
4. Reduce provocations: don't give them a reason to dump (see Section 4.4)
Provide efficient and well communicated waste services.
Ensure reasonable waste service costs where possible.
Foster community pride by enhancing the area's aesthetic appeal.
Keep areas free of illegally dumped material.
5. Remove excuses: educate and inform the community (see Section 4.5)
¦	Publicise waste services.
¦	Carry out education programs outlining responsibilities.
¦	Keep areas free of illegally dumped material.
¦	Install signs at hot spots with illegal dumping prevention messages.
It is crucial to alter the perceived as well as the actual degree of effort, risk and reward involved.12
V	J
38 Crackdown on Illegal Dumping - Handbook for Local Government
-------
Landscaping, revegetation and
beautification
Landscaping and revegetating a site can indicate it is
valued, monitored and used. Simple landscape activities,
such as grass cutting and weed removal, can be enough
in some areas to suggest that a site is cared for and
maintained, which will deter some of the nuisance
dumping offenders.
Beautification, such as benches, pathways, picnic tables,
murals or flowerbeds, can change a community's
perception of a site. Many communities will get involved
in and take part in projects that build community pride
and can lead to changed perceptions and increased
community surveillance, which all contribute to
increasing the riskfor people illegally dumping.
Barriers
Physical barricades that restrict access are very effective
for reducing dumping in areas with a single point of
entry, such as lanes, fire trails and private roads. Fences,
posts, earth mounds, bollards and rocks have all been
used to prevent vehicle access. Each site is unique and
therefore deterrents need to be carefully managed and
planned. On some sites a single barrier blocking access is
all that is required. In some cases offenders may be able to
continue to dump over a barrier, but this increases the risk
of being caught and may deter the majority of offenders.
Councils used funding from the 2002-2004 Illegal
Dumping Clean-up and Deterrence Grants to build a
range of physical barriers with varying success.They
reported that some sites were difficult to enclose.
Beautification: Woollahra Municipal Council's 'Liveable Lanes' project
a
Woollahra Municipal Council's'Liveable Lanes'project was designed to change its community's perception
of back lanes as a dumping ground. The council was committed to beautify and improve the look and feel
of the area to increase community pride and, therefore, reduce the incidence of illegal dumping. It used
a 2002-2004 Illegal Dumping Clean-up and Deterrence grant to clean up dumping hot spots, landscape
them and carry out an education campaign to deter future dumping. Minor capital works in the area
complemented the educational component.
The council developed its project in an attempt to keep sites clean long after the campaign had finished.
A second part of the project focused on a reserve that experienced persistent dumping. It used landscaping
works, including new plants for garden beds, to improve the aesthetics of the area and detract dumpers.
The new plants were selected to make it difficult to hide bags and other dumped rubbish, as was previously
the case. Plants were widely dispersed so that the garden is more open to deter other anti-social behaviours.
The council also built a retaining wall to stop bins being dragged through, presented and stored in the
garden area.
Woollahra Municipal Council attributes the success of its project to a multidisciplinary team of council
staff, including team members from communications, waste section, compliance, outdoor works and
management, who collaborated and brought together areas of the project according to their expertise.
A broader, more strategic prevention program can bring in representation from much wider sections of
council asking for comments on program design, use and evaluation. The project is also a good example
of community participation where the council values the community as a partner.
Outcome
The enhancement of the Oswald Street Reserve has provided the most positive results in improved
environment. Dumps in this area have decreased and been maintained over a five-month period.
Crackdown on Illegal Dumping - Handbook for Local Government 39
-------
Fences and locked gates
Many councils used illegal clumping clean up and
deterrence grants of 2002-2004 to install fences
and locked gates.
Some councils indicated that new gates and locks were
vandalised almost immediately after installation. Locks
were tampered with or gates and fences broken down.
For some dumpers, locked gates "just seem to be an
invitation to become a vandal as well". Often there was no
real alternative to fences and gates and so many councils
need to consider vandalism in project planning as either
programmed maintenance scheduled for a period of time
or as the additional cost of vandal-resistant materials.
At a number of sites vandal-resistant locks, locking
bollards and almost indestructible fence materials have
been carefully selected.
Concrete blocks
A number of councils reported using concrete blocks
to barricade entry to a site. This was described as a
'relatively cheap, inexpensive and effective option!
For many residents though the blocks are unsightly,
do not fit in with the natural environment and may
incur complaints to council. Some sites had experienced
graffiti soon after installing the blocks.
Indestructable
fencing materials
a
Tharawal Local Aboriginal Land Council (LALC)
and DECC Parks and Wildlife Division used
almost indestructible fence materials at a
remote site in Wedderburn to prevent 4WD and
commercial vehicles dumping materials.The
adjoining landholder (industry) donated railway
track and steel rope, which was used to erect a
500-metre fence line.
Outcome
The fence has remained intact and unauthorised
vehicles have been kept out.
Fences to protect
rural hotspots
a
Maitland City Council selected a rural
style fence to restrict vehicle access at
some rural sites.
Outcome
It helped reduce illegal dumping on the sites
and restricted access to a small stockpile area
for local road reconstruction works. Four of
the five fenced sites continued to show little
signs of illegal dumping activity 12 months
after the project.
40 Crackdown on Illegal Dumping - Handbook for Local Government
-------
Tire Flow Study in the Texas-Mexico Border Region
Attachments
ATTACHMENT 6
Display map of appropriate tire
disposal alternatives identified in
Texas
Printed on 100% recycled fiber paper using solid ink
tfto srAf
& 	 Ss>
PROlt0
/
CO
1
a
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de
I EMS
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300000
500000
700000
310000
510000
UTM Coordinates
710000
Lm Cm<«
0 CHAPARRAL SAND & GRAVE
O
O
O
rn
Clud«l
iuirez-

-cstrsa-
CLINTTYPE 1 LAN
t - \
L LRPUT
TRES PESETAS LRPUT
M mm
OociW

sj if*1 v
**> -
S-n An, 7to
.Ablene

13

Copfjcoi Crivtf
Arlington
Ckhjini
&
	Wafco
Kilinn
Tnnyc
Dalla
o
o
o
o
o
fj Caa
«ie»
lutiw nluu
VltU ASl* Mdrf
brrvttc
Bound Rock
Austin
SinMarctn
\ Oitugj

9-qi
Anjiia
.San A'ltonio
r * i
OKU
OUL'dfO
Cuauhtemoc
Grhuahua
«*«»u c,ud»d
" Dc itiai
1 Negras
• E
Mfartffc 1
L INDIO LAI
NDFIUP
O
Symbology
Appropriate tire disposal alternatives
in Texas' international border area
Land Reclamation Project Using Tires
(LRPUT)
Land Reclamation Project Using Tires
(LRPUT) with whole tire buriai
authorized.
Type 1 Sanitary Landfill.
300000	500000
r~
I 7
ii d a Map
tw*<«
MufMU
Mi tW* »«r
U K»: t JmAuts
&
LJW1 LRPU
*K^»rto
San fimnm *ua
; %
diutJd i
inMux. {
tCcpcs
. Christ)
o
o
o
i'edL\RED0 LAMDFILL
.'Arton
I0VJ
fx S

SANTA AN I
H tfdigo

A LRPUT
Ouo*d A
Mt^ud W
UmJn
WO GI1ANDE VALLEY
ft jnovco i. sin Pedro oe U*
t jlonui
700000
'"Sjr.t
310000
General c jrtMj
tscol*4fl# A(cdafJl
i Catanra ,
Ai\ini n i llgT
EDINBURG
LANDF^L
~dad Rio Bravo
^msmcr
Of^hrtviilc

o
o
o
o
BROWNSVILLE LANDF
LL
510000
710000
Note: Sites colored according to social and/or environmental performance, being green the most recommended, and red the least recommended
alternative .Although all are considered appropriate tire disposal alternatives by this study.	
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Tire Flow Study in the Texas-Mexico Border Region
Attachments
ATTACHMENT 7
Display map of appropriate tire
disposal alternatives identified in
the Mexican side of the Texas-
Mexico Border Area
Printed on 100% recycled fiber paper using solid ink
tfto srAf
& 	 Ss>
PROlt0
/
CO
1
a
$



de
I EMS
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lamogordo
Tucson
Doug! a:
O
Waco
Austin,
SONORA'
OHermosillo
'-^Laredo
CEMEX PI
lALGO
nterrey vrBrowns
CEMEX PLANTA MONTERREY
NUEVO p J^Z '
LEON^ f /
APASCO
Snlfillo
Durango
Ciudad
Victoria
32°0'0"N-
30°0'0"N-
28°0'0"N-
26°0'0"N-
24°0'0"N-
-32°0'0"N
-30°0'0"N
¦28°0'0"N
•26°0'0"N
•24°0'0"N
110°0'0"W
los-o'o-w
	I	
Mesa

GCC PLANTA SAMALAYUCA
100°0'0"W
	I	
\ Garland
Abilene	Fort Dallas
Worth V	o
Sano
Angelo
San
Dei wo Antonio^
AC liNA MUNICIPAL LANDFILL
La Paz
Chihuahua
GCC PLANTA CHIHUAHUA
* -- - Ts cmhiMho/t
Houston L
Victoria
JCT
PIEDRAS NEGRAS
\
SIN ALO At
APASCO-
RAMOS ARIZPE
Corpus Christ
\Culiacan DjJRANGO
110o0'0"W
T
105°0'0"W
	1	
lOO-O'O-W
COAHUILA\ (
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