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Environmental Enforcement
Roundtable
Tires - Generation, Storage and Transport
Jason Ybarra, Team Leader
TCEQ Houston Waste Section
October 13, 2011
10:00 AM to 12:00 PM
Houston-Galveston Area Council
Conference Room A, 2nd floor
Tire Code
Scrap Tire Management in Texas
DISCUSSION TOPICS
TCEQ Scrap Tire Registration Program
 Health and Safety Code, SW Disposal Act, 361.112
 30 TAC 328, Subchapter F,
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Purpose: Requirements for the safe storage, transportation
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processing utilization, and disposal of used or scrap tires or tire pieces
Manifesting
Types of TCEQ Registration Authorizations
 Location of Authorized Scrap Tire Storages Sites
 Location of Unauthorized Tire Sites
Scrap Tire End Uses
Challenges of Abandoned Tire Stockpiles
Tire Fires
General Used/Scrap Tire Information
▪
Texas generates an estimated 24 million used/scrap
tires annually (essentially 1 tire per person)
▪ Significant reduction in stockpiles of whole scrap tires
and tire pieces since FY 2000:
▪ January/2000 –
▪ Stockpile more than 65,000,000 (whole scrap tires)
▪ December/2010 –
▪ Stockpile less than 15,000,000 (whole scrap tires)
Scrap Tire Management

Types of Registrations for the State
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Generators – 12,000 Registered Facilities
Transporters – 620 Registered Facilities
Scrap Tire Facilities – 98 Registered Facilities
Tire Storage Sites – 12 Registered Facilities
Transportation Facilities – 1 Registered
Facilities
◦ Land Reclamation Project Using Tires
(LRPUT)– 7 Active Projects
Generator
An entity that is a fleet operator, an automotive dismantler, or is a whole new
or used tire retailer, wholesaler, manufacturer, recapper, or retreader.
(30 TAC 328.56)
▪
▪
▪
Generator that Stores less than 500 tires
▪ No Registration Required
Stores more than 500 tires –
▪ Generator Registration Required
▪ Good used tires must be sorted, marked, classified, and arranged in an
organized manner for sale to the consumer.
Generators.......
▸ May transport between businesses or to an authorized facility without
transporter registration
▸ Must comply with manifesting requirements
Transporter
An entity that collects and transports used or scrap tires and tire
pieces to an authorized scrap tire facility. (30 TAC 328.57)
▪
Must comply with manifest requirements
▪ Name, Place of Business and TCEQ ID No. must be
properly displayed on sides and rear of trailers and
trucks.
▪ Must transport used and scrap tires and tires pieces to
an authorized scrap tire facility.
▪ Must File an Annual Report
Manifesting - Generator

Generators shall obtain from the transporter collecting tires from
their place of business and maintain a record of each individual load
of used or scrap tires or tire pieces hauled off from their business
location.The record shall be in the form of a five-part manifest or
other similar documentation approved by the executive director.
The generator shall complete the information pertaining to
generator name, address, and telephone number, number of tires
removed on the manifest, and registration number, if applicable.The
generator shall indicate the destination of all used or scrap tires or
tire pieces removed from the business location. A representative of
the generator shall sign the manifest acknowledging that the
information on the manifest is true and correct.
Manifesting -- Transporters

The transporter shall complete the information on the manifest
pertaining to transporter name and registration number and the
transporter's driver's license number and the state where the
license was issued. The transporter shall record the number and
type of scrap tires removed from the generator and delivered and
the location of any whole used or scrap tires removed from the
load and delivered. Transporters shall maintain a manifest record of
each individual collection and delivery. The transporter shall sign
the manifest acknowledging that the information on the manifest
form is true and correct. If the transporter removes, for beneficial
reuse, all tires from an individually manifested load, the transporter
shall return the original manifest to the generator within 60 days of
the date of collection.
Manifesting – Authorized Facility

The authorized facility accepting delivery of the used or
scrap tires or tire pieces shall complete the information
on the manifest pertaining to the authorized facility
identification and number or weight of tires or tire
pieces accepted for delivery. A representative of the
authorized facility shall sign the manifest acknowledging
that the information on the manifest form is true and
correct. The authorized facility shall ensure that the top
original of the five-part manifest is completely filled out
and returned to the generator within 60 days of the
date and time of collection as indicated in Section 1 of
the manifest.
Manifesting

A generator shall obtain the completed manifest within
60 days after the scrap tires or tire pieces were
transported off-site by the transporter.

The generator shall notify the appropriate commission
regional office of any transporter or authorized scrap
tire facility that fails to complete the manifest, alters the
generator portion of the manifest, or fails to return the
manifest within three months after the off-site
transportation of the used or scrap tires or tire pieces.
Manifesting

Originals of manifests, work orders, invoices or other documentation used to
support activities related to the accumulation, handling, and shipment of used or
scrap tires or scrap tire pieces shall be retained by the generator for a period of
three years. All such records shall be made available to the executive director upon
request.

Any change made to the face of an original record shall be made by drawing a single
line through the item being changed, ensuring that the item remains legible and
readable. To the side of the mark, the person making the change shall place his or
her initials with the date of such change.
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Any change made to the face of an original record shall be accompanied by a
written justification stating the reason and purpose for the change. This written
justification shall be prepared simultaneously with the change to the original record,
attached to the original record, maintained at the designated place of business for a
period of at least three years, and made available to the executive director upon
request. The justification shall include the date of the change, and the full name and
position of the individual making the change.

Should the executive director identify discrepancies/errors in records, an
opportunity will be given to justify, in writing, any such errors or discrepancies.
What is an Authorized Facility?

30 TAC §328.53 Definitions
◦ Authorized Scrap Tire Facility: A facility authorized to accept scrap tires
including, but not limited to, a registered scrap tire storage site, scrap
tire facility (processor, recycler, energy recovery), or permitted landfill.
This would include a LRPUT.
◦ Scrap Tire Facility: A facility that processes, conducts energy recovery,
or recycles used or scrap tires or tire pieces.
◦ Beneficial Use Projects: May be considered an authorized end use
facility if they have met the requirements as stipulated in the TCEQ
“Guidance for Projects Involving the Beneficial Use of Used or Scrap Tires”
(form No. 10302)
 Local Authority Notifications or Authorizations
 If storing or processing on-site, entity is subject to 30 TAC 328
Subchapter F applicability and requirements
 If no longer serving as a beneficial use and/or creating a nuisance –
subject to 30 TAC §330.15 MSW General Prohibition Requirements
Scrap Tire Facility
A facility that processes, conducts energy recovery, or recycles
used or scrap tires or tires pieces. (30 TAC 328.63)
▪
Processor/Recycler - The extraction of materials from
or the transfer, volume reduction, conversion to
energy or separation and preparation of solid waste
for reuse or disposal.
▪ Energy Recovery
▸ Uses whole scrap tires or tire pieces for fuel
▸ Requires Fire Marshal approval
Scrap Tire Storage Facility
A facility that stores more than 500 used or scrap tires or tire pieces on the ground or
more than 2,000 used or scrap tires or tire pieces in enclosed, lockable containers.
(30 TAC 328.60 & 328.61)
▪
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Engineering certification required;
Fire Marshal approval required for fire protection system and allweather roads;
Adequate fire protection required - water storage ponds, fire
hydrants, equipment, etc.;
40 foot space encircling piles and buildings;
Financial Assurance required;
Registration Expiration;
Local authority authorizations required.
Authorized Storage Facilities
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Registered Scrap Tire Storage Facilities in Texas:
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Thoshanowasti, Amarillo, Potter County
Synergy Management Group, Stamford, Haskell County
Vista International Technologies, Hutchins, Dallas County
Liberty Tire Recycling, Midlothian, Ellis County
Tres Pesetas, El Paso, El Paso County
Liberty Tire Recycling, Inc., Baytown, Harris County
Bulldog Tire Recycling, Inc., Cleveland, Liberty County
Latham Tire Transporter, Porter, Montgomery County
Genan, Inc. , Houston, Harris County
Penitas Landfill, Harlingen, Cameron County
City of Brownsville Landfill, Brownsville, Cameron County
Unauthorized Scrap Tire Storage Sites
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Unauthorized sites currently storing in excess of
100,000 scrap tires on-site:
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Safe Tire Disposal Corporation, Penwell, Ector County
Safe Tire Disposal Corporation, San Antonio, Bexar County
Quantum Tech, Inc., Houston, Harris County
Scrap Tire Recycling, Inc., Pasadena, Harris County
Former Gibson Recycling, Inc., Beaumont, Jefferson County
World Tire Recycling, Brownsville, Cameron County
◦ (Former) Touche International, Gordonville, Grayson County
◦ Glenn Pike Site, Boyd, Wise County
◦ Tiretex, Inc. DBA Jerry Waller Tire – Seagoville, Dallas county
Transportation Facility
A facility such as a marine terminal, rail yard, or trucking facility where scrap
tires or tire pieces may be stored for periods longer than 30 consecutive
calendar days.(30 TAC 328.64)
▪
Specific Guidelines
▸ Engineer Requirements
▸ Financial Assurance Requirements
▸ Registration Expiration
▸ Fire Marshal Notification
▸ Local Authority Authorization
Land Reclamation Project Using Tires (LRPUT)
A project to fill, rehabilitate, improve and/or restore already
excavated, deteriorated, or disturbed land. (30 TAC 328.66)
▪
Uses no more than 50% by volume of tires pieces
along with inert fill material, for the purpose of
restoring the land to its approximate natural grade to
prepare to reclaim the land;
▪ Engineering certification required;
▪ Fire Marshal notification documentation required;
▪ Local authority authorizations required.
Active LRPUT’S
Silver Creek Materials – Forth Worth, Tarrant County
 TireTex Inc. – Seagoville, Dallas County
 B&G Tire Disposal, Odessa, Ector County
 Liberty Tire Recycling , Houston, Harris County
 Santa Anita Reclamation LLC, Hidalgo County
 UTW Tire Collection Services, Laredo, Webb County
 Tres Pesetas Inc. – El Paso, El Paso County

Scrap Tire End Uses
Energy Recovery/Tire Derived Fuel – Approx. 45-50%
Cement kilns
Paper and pulp mills
Can use whole scrap tires or tire pieces
Tire Derived Fuel - EPA Oversight
The EPA supports the responsible use of tires as
fuel in portland cement kilns and other industrial
facilities, so long as the facilities:
◦ have a tire storage and handling plan;
◦ have secured a permit for all applicable state
and federal environmental programs; and
◦ are in compliance with all the requirements of
that permit.

Scrap Tire End Uses
Land Reclamation Projects Using Tires (LRPUT)
Approx. 25-35%
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Project to reclaim previously excavated or
disturbed land (mines)
50/50 mix of tire pieces and soil
18 inches of final cover
P.E. seal, prop. owner affidavit
Public/local government notification and
comment
Scrap Tire End Uses
Civil Engineering Projects – Approx. 2-5%
▪
Leachate Collection Systems at Landfills
▪ Bioreactor Process at Landfills
▪
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Alternate daily cover
Erosion Control/Embankment stabilization
▪ Along Highways, Bridges and Overpasses
Scrap Tire End Uses
Crumb Rubber – Approx. 5-8%
▪
Two Authorized Crumb Rubber Facilities
ire Mulch
Scrap Tire End Uses
Disposal in Permitted Landfills - 17%
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Disposal not considered an “end use”.
The only option in some areas.
Whole scrap tires must be split, quartered or
shredded prior to disposal.
Manifest Required.
Scrap Tire End Uses
Other – @ 4%
▪
Beneficial Use Projects
▪ Swings
▪ Playground equipment
◦ Retaining walls, fences, pet toys, floor mats, erosion control
▪
▪
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Agricultural Use
Septic system drain fields (<1%)
Other
Beneficial Use of Used or Scrap Tires
▪
Erosion control
▪ Houses
▪ Fences
▪ Bullet back stops at Gun Shooting Range
▪ Playground Equipment
▪ Sporting Equipment
▪ Mulch
See TCEQ Guidance Document Form 10302
New Technology -Tire Pyrolysis
Definition: The thermal decomposition of organic materials in
the absence of oxygen.
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The proposed process takes a non-hazardous waste (scrap tires) and
makes it a hazardous waste.
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Process generates Oil, Gas, and Carbon Char
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Regulatory Requirements
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On-site Storage of Hazardous Materials and Wastes
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Entity must demonstrate:
◦ Technical, Economic, Environmental and Capital Viability
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Other Issues
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Air Emissions
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Numerous Fire Hazards
Challenges of Pyrolysis Sites
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Have a history of operating without permits, registrations
and/or other applicable authorizations in Texas as well as other
states.
Have a history of not properly managing alleged products or
wastes and/or abandoning the wastes in Texas as well as other
states.
◦ Problems Funding Clean-up of the Abandoned Wastes
The proposed process takes a non-hazardous waste and makes
it a hazardous waste.
Have a history of not being able to demonstrate viable end use
markets in Texas as well as other states.
Operators are not able to demonstrate the “Burden of Proof”
provision pursuant to 40 CFR 261.2(f), Documentation of claims
that materials are not solid wastes or are conditionally exempt from
regulation.
◦ Gives the appearance of “Sham Recycling”.
Abandoned Pyrolysis Facility

List of Abandoned Wastes Rusk Co 2009
◦ 110 - Drums of Generated Product Oil
 Hazardous Waste
◦ 372 - Super Sacks of Carbon Char and Tire piece material
◦ 11 - Drums of Solvents (Toluene, Xylene)
 Hazardous Waste
◦ 133 - Drums of mixed industrial solid and hazardous wastes
◦ Other containers of solid wastes such as hydraulic oils, anti
freeze, motor oil, used oil, treated wood chips, metals,
absorbents, filters
Abandoned Sites
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Who pays to clean up abandoned scrap tire
sites?
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Property Owner Responsibilities
Access Funding from Financial Assurance Bonds
City and County assistance from COG
City and County Sponsored Citizen Collection
Days
◦ Legislative Direction
Gibson Atlanta Site 2000
Gibson – Atlanta 2008
Challenges of Stockpiled Tires and Tire Pieces
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Collection, removal, and final end use or disposal is
expensive.
Potential threat to human health and safety and the
Environment.
◦ Fire Hazard
◦ Vectors (any agent (animal or microorganism) that
carries and transmits a disease)
◦ Other wastes (known and/or unknown) stored onsite (such as San Benito Fire Aug/2011)
◦ Dry or Dead Vegetation in and around tires
Challenges of Tire Fires

General Information
◦ Size of the fire (relates to duration of the fire)
◦ Accessibility or Inaccessibility of the site
◦ Geographic, climatic, wind direction, and/or other obstacles
◦ Water availability and accessibility
◦ Possible Evacuations Required
◦ Whole Tires vs Tire Pieces
◦ On-site storage of other materials such as: by- products, used oil,
gasoline, solvents, miscellaneous trash and debris, etc...
◦ Containment of fire water and pyrolytic oil
◦ Resources and Equipment
TIRE FIRES
POTENTIAL ENVIRONMENTAL HAZARDS

Possible Contaminants in the Air:
◦ Benzene, Polynuclear Aromatic Hydrocarbons (PAHs), CO
Particulates, Carbon, Toluene, Xylene, Formaldehyde,
Sulfuric Dioxide, and Numerous Heavy Metals (primarily
lead, iron, and zinc).
◦ PAHs may include naphthalene, benzo(a)pyrene, pyrene,
crysene, fluorene, anthracene and phenanthrene.
TIRE FIRES
POTENTIAL ENVIRONMENTAL HAZARDS

Possible contaminants to the ground and waters of the
state;
◦ Pyrolitic Oil Contaminants:
– Benzene, Xylene, Toluene, Zinc, Phenol, Ammonia,
Trichloromethane, Styrene, Cyanide, Ethylene, PAH’s, and Heavy
Metals
◦ Ash Contaminants:
– Carbon, zinc oxide, titanium dioxide, silicon dioxides
Class A and B Foam
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Potential Environmental Concerns Using Foam
◦ Possible impact to waters of the State
◦ Potential for fish kill in impacted areas
◦ Suppression foams may potentially interfere with the
life-cycles of some aquatic organisms, so appropriate
containment measures should be taken to prevent
run-off into streams and storm drains.
◦ Long term environmental impact is unknown.
◦ Potential impact to Waste Water and Drinking Water
Treatment Plants.
City of San Benito -- August 2011
TIRE FIRE MAY, 2009
Wood County, Texas.
 Total scrap tires that were on fire
estimated at:

◦ 285,822 Passenger Tires
◦ 8,166 Truck Tires
◦ 1,225 OTR (off the road tires)

Total Amount Estimated: 40831.64 cu yds
Tire Fire Response
During the 56 hour fire operational period over
150 firefighters from the City of Hawkins and
other County fire departments responded.
 6.5 Million Gallons of Water was used to
extinguish the fire.
 EPA and Start Team conducted continuous air
monitoring of toxic smoke.
 The Mayor evacuated the town of Hawkins.

Scrap Tire Management Reference Information
TCEQ Scrap Tire Web Site:
www.tceq.state.tx.us/compliance/tires/
TCEQ Public Web Site:
www.tceq.state.tx.us
EPA Scrap Tire Public Web Site:
www.epa.gov/osw/conserve/materials/tires
www.epa.gov/osw/conserve/materials/tires/faq.htm
US Fire Administration Web Site:
www.usfa.dhs.gov
Scrap Tire End Use Markets:
www.rma.org
Mosquito Control - National Pesticide Information Center
http://npic.orst.edu/
Scrap Tire Management In Texas
Cynthia Hackathorn
Scrap Tire Management Registration Coordinator
SW Environmental Investigator
2309 Gravel Drive, Fort Worth, TX 76118
817-588-5817
[email protected]
TCEQ Contact Information
Jason Ybarra
TCEQ, Houston Region
Team Leader, Waste Section
5425 Polk Street, Suite H, Houston, TX 77023
(713) 767-3615
[email protected]