FOOTNOTES

¹ The authors gratefully acknowledge the support and assistance given by Ms. Deanna Ruffer to their efforts in preparing this report. they also wish to thank professionals with the Pollution Prevention Assistance Division and the Environmental Protection Division, as well as many knowledgeable individuals in the scrap tire processing and end-use industries, for their time in sharing with us their knowledge and insights concerning technical issues relevant for assessing the State's scrap tire management program. Responsibility for errors of omission and/or commission in the preparation and interpretation of materials presented in the report reside, of course, with the authors.

² Georgia Code Section 12-8-21(f) O.C.G.A., 1991.

³ Small amount of other products come out of processors' activities. Examples (that apply in large part to scrap tires obtained from scrap piles) include tires resold as used tires, inner tubes sold as scrap rubber, scrap metal (in the main, tire rims), and waste wire.

⁴ In 1994 Rubber Technology, a firm located in Crawford County, opened as a crumb producing enterprise. Unfortunately, the enterprise was unsuccessful. There is some possibility that Rubber Technology will be reopened under new ownership in the near future. In addition, both Greenman and United Rubber Recycling collect "purer" forms of used tire rubber, such as buffings and inner tubes, which they send out-of-state to crumb rubber operations. The volumes involved are quite small, however.

⁵ We are told that product price for tdf is tied to the price of coal--some 50% of coal prices. Coal prices have persistently declined over the last decade as have tdf prices.

₆ Tires in Georgia's scrap tire piles have declined from more than 7 million in 1993 to present levels of about 2 million, including recent discoveries of new scrap tire piles. There exist more than 40 million tires in known scrap tire piles in this region, however.

⁷ A common rule of thumb for estimating the generation of scrap tires is one tire generated annually per capita.

⁸ We are aware of at least two firms seeking investor support for the expansion and modernization of crumb rubber producing facilities in Florida and North Carolina.

⁹ Unlike chip processors, the crumb producer is typically not dependent on tipping fees as a major source of revenue because product prices are higher--much higher--than prices received by chip producers. For example, depending on quality, 40-100 mesh crumb commands prices in the range $0.49-$0.58 per pound ($980-$1,160/ton), compared with $10.00 per ton received for chips. (see prices quoted on the Internet by Recycler's World, http://www.net/recycle/Rubber/granule/xv132000.html, August 13, 1998. Lower grade 40 mesh is priced much lower: $0.08/lb. Rough crumb as feed stock for more refined crumb commands $55/ton).

¹⁰ The definition of excess capacity as total capacity minus production (volume) introduces the possibility of biases that the reader should recognize. Differences in individual reports of "capacity" may be based on differences in respondents' perception of operating hours "relevant" for defining capacity. Thus, one processor may report as capacity the volume of tires that could be processed in "normal," 12-hour shifts of operation while another processor may report capacity as the volume that could be produced with a 24-hour operation. We do not have access to data that would allow us to ensure consistent measures of capacity across all processors in our survey.

¹¹ Large numbers of scrap tires are presently shredded and disposed of in landfills in North Carolina and Kentucky. These tires may be viewed as a potential source of supply for the region's scrap tire processing industry.

¹² Telephone interview with Mr. Bill Parker with Florida's Environmental Protection Division, Division of Waste Management, September 28, 1998. There is presently one cement kiln in Florida that uses tdf and a new kiln that will use tdf when it comes on line. Two other kilns in the state used tdf at one time but no longer do so.

¹³ Telephone interview with Mr. Mark Mintz, North Carolina Department of Natural Resources, Division of Waste Management, September 28, 1998. See also, North Carolina Department of Environment and Natural Resources, Scrap Tire Management Report, FY 1996-97 [1997].

¹⁴ Scrap tires in known scrap tire piles total: 4.8 million, Florida; 2 million, Georgia; 8.5 million, Kentucky; less than 1 million, North Carolina; 9 million, Alabama; 16 million, Tennessee; and 0.2 million, Mississippi. Data are not reported for South Carolina. Scrap Tire Research Institute [1998; pp. 57-64].

¹⁵ In some ways, at $37-38/ton, yielding 13,500-14,000 btu/lb., coke is a more economical fuel. However, coke tends to be higher in sulfur content than coal, thereby restricting the attractiveness of its use for companies that are relatively constrained by their emissions permits. This may be particularly relevant for cement kilns.

¹⁶ There appears to be uncertainty at the present time as to the magnitude of this savings.

¹⁷ We are aware of ongoing considerations being given to new uses of whole tires for civil engineering application.

¹⁸ Arguable, lower prices might to some extent induce new paper plants to adopt the use of tdf.

¹⁹ This information was derived from an interview with Mr. Jimmy Johnson, Program Manager for the EPD's Stationary Source Program. Mr. Johnson was unfamiliar with a related source of concern to the paper industry associated with the Toxic Release Inventory: "waste disposal unit" designations for boilers used by the paper industry. Mr. Johnson indicated the EPD view as one in which tdf is viewed as a fuel, not as a waste. Precedents exist in which the EPD has determined, in an instance where a paper plant was burning combinations of bark and sludge, that the sludge was not regarded as being subject to waste disposal rules.

²⁰ This is not an issue for the use of whole tires by cement kilns.

²¹ Apparently, environmental and health inspectors with some local governments have (unspecified) concerns about "future problems" that could arise with the use of chips.

²² The General Assembly, in enacting the 1991 scrap tire legislation, specifically stated its intent: "...that every effort be undertaken to ensure the proper management of scrap tires from the point of generation to the ultimate point of reuse, recycling, or disposal and that every effort be made to ensure that, where possible, they be reused or recycled rather than being disposed." (Georgia Code Section 12-8-21(f) O.C.G.A., 1991)

²³ Present regulations imposed by the EPD is a quantity equal to 60 days of a firm's production.

²⁴ One individual interviewed as a part of this study provides a succinct statement of this position: "...if the ban is removed the industry dies!"

²⁵ See North Carolina Department of Environment and Natural Resources [1997].

²⁶ Telephone interview with Mr. Michael Blumenthal, Scrap Tire Management Council, Washington, DC, September 29, 1998. Only three other states have reached the sunset date for their scrap tire fee: Idaho, Wisconsin, and Minnesota, and these states have allowed the fee to sunset without serious adverse consequences.

²⁷ We have tried to give particular emphasis to the fact that with a "young" industry like the scrap tire industry, any crystal ball is necessarily clouded. The forward-looking state will attempt to anticipate adverse developments that might arise over the next decade. This process is made possible by the dedication of funds to be used for this particular kind of environmental monitoring. Of course, needs of this genre are basic to the rationale underlying the legislature's initial establishment of a Solid Waste Trust Fund. this rationale, in our view, makes compelling the argument that the state's scrap tire management program should continue to contribute its share to the Fund.

²⁸ Copies of all surveys are available upon request from the principal investigator.

²⁹ There is both documented and anecdotal evidence to support these findings based on the surveys with Georgia processors. One processor indicated a long standing contract with the state of Tennessee to take tires. One processor has a sister plant in South Carolina to which many Georgia tires are sent. Several processors indicated having an issue with tire jockeys taking tires to Alabama, where landfilling restrictions were lenient at best.