Tire Incineration

Check out our map of tire incinerators!

TOPICS WITHIN THIS PAGE

Back­ground Intro­duc­tion
Prob­lems with Test Data
Tire Incin­er­a­tion in Paper Mills
What we don’t know can hurt us
Tox­ic Pol­lu­tion from TDF Burn­ing
Foot­notes

OTHER PAGES ON THIS SITE:
Alter­na­tives to Tire Burn­ing
List of tire burn­ing facil­i­ties
Groups opposed to tire incin­er­a­tion
Resources and links

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See our Pow­er­points on tire incin­er­a­tion.

What is “Tire Derived Fuel” and why is it dangerous?

As of 2003, about 290 mil­lion tires are dis­card­ed in the U.S. every year (rough­ly one per per­son). Near­ly 45% of these scrap tires (130 mil­lion) are used as “Tire Derived Fuel” (TDF), which often involves burn­ing the (usu­al­ly shred­ded) tires along­side con­ven­tion­al fuels like coal (usu­al­ly no more than 10–25% TDF is used when co-fir­ing with coal). At the end of 2003, 89 U.S. facil­i­ties burned TDF on a reg­u­lar basis, about half of which (43) are cement kilns with the rest being pulp/paper mills (17), coal-fired pow­er plants (13), and oth­er indus­tri­al boil­ers or waste incin­er­a­tors (15). No ded­i­cat­ed tire incin­er­a­tors are still oper­at­ing in the U.S., but there used to be ones oper­at­ed in Ster­ling, CT (Exeter Ener­gy), in West­ley, CA (closed after a major fire), Hen­ry Coun­ty, VA, and Ford Heights, IL. Oth­ers were pro­posed, such as ones in Pre­ston, MN (stopped in 2005), the world’s largest (800 ton/day) plant that as planned for Erie City, then Craw­ford Coun­ty, PA (stopped with our help in 2010 and again a few years lat­er), and also a huge tire gasification/pyrolysis plant planned by Koach Ener­gy for the City of Chester, PA which we stopped in 2008. The num­ber of facil­i­ties burn­ing TDF is increas­ing, though. More cement kilns are begin­ning to use TDF and elec­tric arc fur­naces (EAFs) are start­ing to burn tires.¹

Tire man­u­fac­tur­ers, Tire Derived Fuel pro­duc­ers (tire shred­ders) and TDF users (burn­ers) and

gov­ern­ment agen­cies pro­mote burn­ing TDF as a solu­tion to the dire prob­lem of waste tires. What they fail to men­tion in their pro­mo­tion­al mate­ri­als is that tire incin­er­a­tion under any cir­cum­stance cre­ates pol­lu­tion that makes the air dan­ger­ous to breathe.

It is com­mon knowl­edge that burn­ing tires in the open is extreme­ly harm­ful to human health and the nat­ur­al envi­ron­ment. The fumes emit­ted are packed with the many tox­ic chem­i­cals that tires con­tain (includ­ing volatile organ­ic com­pounds such as ben­zene, met­als such as lead, poly­cyclic aro­mat­ic hydro­car­bons such as benzo(a)pyrene, and syn­thet­ic rub­ber com­po­nents such as buta­di­ene and styrene). Addi­tion­al­ly, the chlo­rine con­tent in tires leads to the cre­ation of diox­ins and furans (which are extreme­ly tox­ic chem­i­cals) when tires are burned.

Yet, users of Tire Derived Fuel are con­fi­dent that their machin­ery (which usu­al­ly is not even designed for burn­ing tires) and the com­bi­na­tion of tires with tra­di­tion­al fuels (like coal) will ren­der the incin­er­a­tion process harm­less. Accord­ing to the Auburn­dale Recy­cling Cen­ter, Inc, a Wis­con­sin-based for-prof­it cor­po­ra­tion that sells tire chips for incin­er­a­tion, “Most indi­vid­u­als are con­fused about the dif­fer­ence between a “burn­ing tire” which emits black smoke and dam­ages the envi­ron­ment, and the use of scrap tires as a fuel source for pow­er companies.”

Cit­ing gov­ern­ment approval of Tire Derived Fuels, Auburn­dale ignores the scathing cri­tiques that rep­utable sci­en­tists like Dr. Neil Car­man and Dr. Sey­mour I. Schwartz have writ­ten in response to the “junk sci­ence” and stacked sta­tis­tics behind the rub­ber-stamp approval of tire derived fuel. These experts, along with oth­er sci­en­tists, ecol­o­gists, and pub­lic inter­est groups, have uncov­ered the truth behind the pro­pa­gan­da — that tire incin­er­a­tion by any method is NOT safe.

Problems with Test Data

Sup­port­ers of Tire Derived Fuel claim that sub­sti­tut­ing 10–25% TDF for coal or nat­ur­al gas in incinerators/boilers does not sig­nif­i­cant­ly alter the chem­i­cal con­tent of the emis­sions. To jus­ti­fy their claims, TDF advo­cates point to gov­ern­ment stud­ies like the Envi­ron­men­tal Pro­tec­tion Agen­cy’s 1997 report “Air Emis­sions from Scrap Tire Com­bus­tion” ², which states that:

“Based on the results of the [EPA rotary kiln incin­er­a­tor sim­u­la­tor] test pro­gram, it can be con­clud­ed that, with the excep­tion of zinc emis­sions, poten­tial emis­sions from TDF are not expect­ed to be very much dif­fer­ent than from oth­er con­ven­tion­al fos­sil fuels, as long as com­bus­tion occurs in a well-designed, well-oper­at­ed and well-main­tained com­bus­tion device.” (Ital­ics ours.)

How­ev­er, there are many prob­lems with this. First of all, the test data is not an accu­rate mea­sure of the actu­al day-to-day emis­sions of a giv­en plant. As report­ed by Green­peace, “Tri­al burns are gen­er­al­ly con­sid­ered a poor indi­ca­tor of oper­a­tion on a dai­ly basis: dur­ing tri­al burns when reg­u­la­to­ry autho­riza­tion is at stake and gov­ern­ment offi­cials are at the site, vari­ables such as waste­feed, tem­per­a­ture, oxy­gen flow, and pol­lu­tion con­trol device effi­cien­cy are care­ful­ly main­tained to opti­mize per­for­mance. On a day-to-day basis, emis­sions may be con­sid­er­ably high­er.” ³ Dr. Neil Car­man con­firms this:

“But dur­ing stack tests of TDF, cement kilns will do sev­er­al things to make emis­sions and com­bus­tion look good-to-decent for such facilities:

• run at high­er excess air to improve com­bus­tion efficiency
• con­trol kiln para­me­ters more precisely
• pre­vent kiln sol­id ring for­ma­tion and buildup that cre­ates hav­oc for good com­bus­tion of any fuels
• burn low­er TDF lev­els dur­ing stack tests than they may be seek­ing to burn operationally
• oper­ate and main­tain their ESPs or bag­hous­es in top con­di­tion to keep par­tic­u­late emis­sions to a reduced lev­el, and
• mis­cel­la­neous tricks.” ⁴

Apart from this it should be kept in mind that facil­i­ties nat­u­ral­ly wear down with use. It is unlike­ly that any incin­er­a­tor could con­tin­u­ous­ly oper­ate for a long peri­od of time at the same lev­el of per­for­mance as it did dur­ing the ini­tial test­ing period.

Anoth­er dis­turb­ing aspect of tire incin­er­a­tion, par­tic­u­lar­ly in cement kilns, is the occur­rence of seri­ous “upsets.” As Dr. Car­man explains,

“Cement kilns cer­tain­ly do have com­bus­tion upsets and smoke may be emit­ted dur­ing such events. Cement kilns are not designed or required to have major fail-safe com­bus­tion devices such as large after­burn­ers that all state-of-the-art incin­er­a­tors must have by fed­er­al law today (all med­ical, munic­i­pal, and haz­ardous waste incin­er­a­tors can not oper­ate with­out their after­burn­er or sec­ondary com­bus­tion cham­bers in nor­mal oper­a­tion). The after­burn­er is required because of the poten­tial for flame outs and total com­bus­tion fail­ure in the pri­ma­ry burn cham­ber, which is all that cement kilns pos­sess. Cement kilns have no fail safe com­bus­tion devices which is unthink­able today in all incinerators…Cement kilns are sub­ject to a vari­ety of prob­lems, includ­ing a type of melt­down of the kiln when the ID fans lose pow­er or fail to oper­ate, with­out ade­quate air flow to con­trol kiln tem­per­a­tures at or below 3,000 degrees F, the kiln tem­per­a­ture may sky­rock­et quick­ly to 4,000 degrees F and the kiln is so hot that the steel shell sags toward the ground effec­tive­ly destroy­ing the kiln. Kiln melt­downs are not rare events and have hap­pened here in Texas at sev­er­al plants in the last ten years. Cement com­pa­nies do not like to talk about this prob­lem.” ⁴

Aside from all of this, it should be not­ed that a num­ber of tests con­duct­ed by or on behalf of the Tire Derived Fuel indus­try and its sup­port­ers have been noto­ri­ous­ly shod­dy in terms of sci­en­tif­ic method, vision, lan­guage, and con­clu­sions. As men­tioned ear­li­er, such reports have been repeat­ed­ly blast­ed by a num­ber of rep­utable sci­en­tists and orga­ni­za­tions. These experts raise very seri­ous con­cerns and cast a shad­ow of doubt over much of the “offi­cial sci­ence” behind tire incineration.

Tire Incineration in Paper Mills

The afore­men­tioned EPA test was not even per­formed on an actu­al oper­at­ing plant but rather on a scaled-down sim­u­la­tor. Such devices are obvi­ous­ly bound to be more sta­ble than large indus­tri­al incin­er­a­tors that are used on a dai­ly basis over a peri­od of years. Impor­tant­ly, the EPA sim­u­la­tor isn’t even designed to rep­re­sent the type of incin­er­a­tors typ­i­cal­ly used in paper mills, which often use Tire Derived Fuel.

Tire incin­er­a­tion in paper mills pos­es spe­cial con­cerns. The North Car­oli­na Divi­sion of Pol­lu­tion Pre­ven­tion and Envi­ron­men­tal Assis­tance, a gov­ern­ment agency that is gen­er­al­ly uncrit­i­cal of tire incin­er­a­tion as a whole, still has this to say about tire incin­er­a­tion in paper mills:

“[Paper mill] boil­er sizes are small­er, and oper­at­ing tem­per­a­tures are low­er. Thus, com­plete burn­ing of TDF par­ti­cles in this kind of boil­er is much more dif­fi­cult.
Data have indi­cat­ed that using TDF appears to dete­ri­o­rate the emis­sion qual­i­ty. Par­tic­u­lates in the emis­sions are increased with a cor­re­spond­ing increase of TDF usage. Oth­er cri­te­ria pol­lu­tants also increased in most cas­es… The emis­sion con­trol prob­lem is the great­est sin­gle con­cern for burn­ing TDF at pulp and paper mills.” ⁵

What we don’t know can hurt us.

Anoth­er major con­cern about Tire Derived Fuel is the enor­mous lack of knowl­edge about a wide range of poten­tial dan­gers. This has been painful­ly appar­ent even in the pro-TDF reports. What fol­lows is a selec­tion of quotes from the Cal­i­for­nia Air Pol­lu­tion Con­trol Offi­cers Asso­ci­a­tion (CAPCOA) report. The quotes were orig­i­nal­ly iso­lat­ed for analy­sis by Dr. Sey­mour I. Schwartz, a pro­fes­sor of envi­ron­men­tal sci­ence and pol­i­cy at Uni­ver­si­ty of Cal­i­for­nia at Davis.

• “Effects of expo­sure to more than one car­cino­gen or tox­i­cant are also not quan­ti­fied in the risk assess­ment [on tire burn­ing in CAP­COA’s report]. Many exam­ples of addi­tiv­i­ty or syn­er­gism (effects greater than addi­tive) are known” (CAPCOA, 1993; p. I‑3).
• “Addi­tion­al­ly, there may be chem­i­cals which pose health risks but are not con­sid­ered in a giv­en risk assess­ment for a num­ber of rea­sons, includ­ing lack of infor­ma­tion on tox­i­c­i­ty” (CAPCOA, 1993; p. I‑3).
• “The esti­mates of can­cer poten­cy in humans con­tain many sources of uncer­tain­ty.… Dif­fer­ences in these fac­tors … can­not be eas­i­ly quan­ti­fied and incor­po­rat­ed into risk assess­ment .… Oth­er uncer­tain­ties arise in the assump­tions under­ly­ing the dose-response mod­el used.” (CAPCOA, 1993; p. I‑4).

In his let­ter to the Cal­i­for­nia Inte­grat­ed Waste Man­age­ment Board, Dr. Schwartz also notes that “Vir­tu­al­ly noth­ing is known about the dose-response func­tions for impor­tant cat­e­gories of health effects, par­tic­u­lar­ly dis­rup­tions to the hor­mone sys­tems of humans, which could pro­duce life long dam­age in devel­op­ing infants. Also, vir­tu­al­ly noth­ing is known about the health effects caused by com­bi­na­tions of tox­ic chem­i­cals that are emit­ted when burn­ing tires. With­out such sci­en­tif­ic knowl­edge, and because some tox­ic pol­lu­tants increase from burn­ing tires, there is no sci­en­tif­ic basis for the Board to con­clude that burn­ing waste tires in cement kilns is safe.” ⁶

Toxic Pollution from Burning Tire Derived Fuel

So far we have looked at the dis­turb­ing unre­li­a­bil­i­ty of the exist­ing pro-TDF stud­ies, the spe­cial prob­lems posed by burn­ing tires in paper mill boil­ers, and the alarm­ing lack of knowl­edge about a wide range of poten­tial dan­gers that tire incin­er­a­tion may pose to the health and safe­ty of our com­mu­ni­ties and the envi­ron­ment. This next sec­tion will take a clos­er look at the exist­ing record and find that even based on the lim­it­ed knowl­edge that exists, it is already clear­ly evi­dent that tire incin­er­a­tion is dangerous.

Below is a break­down of some of the con­demn­ing test data, orga­nized by chem­i­cal groupings:

Diox­ins and Furans

Diox­ins are high­ly tox­ic and cause seri­ous health prob­lems, includ­ing infer­til­i­ty, learn­ing dis­abil­i­ties, endometrio­sis, sex­u­al repro­duc­tive dis­or­ders, birth defects, dam­age to the immune sys­tem and can­cer. Diox­in is fat-sol­u­ble and once it’s released into the out­side envi­ron­ment, it read­i­ly climbs up the food chain, caus­ing aver­age meat and dairy-prod­uct con­sumers to get over 95% of their diox­in expo­sure through their diet.⁷ In fact, accord­ing to the World Health Orga­ni­za­tion, the most tox­ic forms of diox­in are con­sid­ered to be the most car­cino­genic (can­cer caus­ing) sub­stances known to sci­ence.⁸ Even a very tiny quan­ti­ty of diox­ins can be dan­ger­ous. Accord­ing to an EPA’s Diox­in Reassess­ment, expo­sure to diox­ins, even at minute lev­els, pos­es can­cer risks and health con­cerns wider than pre­vi­ous­ly sus­pect­ed.⁹ Decep­tive­ly small diox­in emis­sion rates (for exam­ple, 0.0236 grams/year for the now-closed tire incin­er­a­tor in Modesto, Cal­i­for­nia) con­ceal the harm­ful­ness of these dead­ly chem­i­cals. Based on the EPA’s “risk spe­cif­ic dose” cri­te­ria, 0.0236 grams/year is the equiv­a­lent of a life­time max­i­mum accept­able dose for over two mil­lion peo­ple.³

Diox­ins and furans are chem­i­cals that are cre­at­ed by burn­ing chlo­rine (or oth­er halo­gens, like flu­o­rine or bromine) in the pres­ence of hydro­car­bons and oxy­gen. Hydro­car­bons (the bulk of the TDF itself, as well as coal, wood or gas it’s co-fired with) and oxy­gen (from the air) are read­i­ly avail­able when TDF is incin­er­at­ed. Diox­ins and furans are pro­duced by tire incin­er­a­tion because tires con­tain chlo­rine. The man­u­fac­ture of syn­thet­ic rub­ber for tires uses up to 25% aro­mat­ic exten­der oils, a tox­ic waste prod­uct of oil refin­ing which can con­tain chlo­rine. Anoth­er pos­si­ble source of chlo­rine in tires is through the use of the “salt-bath” vul­can­iza­tion process, a process where the rub­ber is made more elas­tic.¹⁰ One major source of chlo­rine in tires is their halo­genat­ed butyl rub­ber lin­ers. The addi­tion of chlo­rine or bromine (the lat­ter used more wide­ly for truck tires) to the butyl rub­ber gives lin­ers the air-imper­me­abil­i­ty required to main­tain prop­er tire infla­tion.¹¹ A con­tent com­par­i­son by the state of Cal­i­for­nia indi­cates that tires may con­tain as much as two to five times the chlo­rine lev­el of west­ern coal, with an aver­age of 0.04 weight per­cent for west­ern coal, and a range of 0.07 to 0.2 weight per­cent for tires.¹². The largest pro­po­nents of TDF burn­ing (the Rub­ber Man­u­fac­tur­ers Asso­ci­a­tion) con­firmed this on their own web­site, when they list­ed the chlo­rine con­tent of tires as being 0.149 — 0.150 % by weight.¹³ An exten­sive EPA sur­vey of the chem­i­cal com­po­si­tion of fuels burned in coal plants found chlo­rine lev­els in tires to be 2% high­er (1,064 ppm aver­age from 149 sam­ples) than the nation­al aver­age for bitu­mi­nous coal (1,043 ppm aver­age from 27,352 sam­ples) — the most wide­ly used type of coal, which also has the high­est aver­age con­cen­tra­tion of chlo­rine of any coal type. Since chlo­rine lev­els in coal vary through­out the nation, it’s pos­si­ble that the chlo­rine con­tent of tires could be far high­er or low­er than coal burned at any spe­cif­ic facil­i­ty.¹⁴

Cer­tain met­als present in tires (such as cop­per, iron, man­ganese, nick­el, sodi­um and zinc)¹⁰ serve as cat­a­lysts for diox­in for­ma­tion, pro­vid­ing a sur­face on which diox­ins can read­i­ly form dur­ing and after the com­bus­tion process.¹⁵ The greater chlo­rine con­tent of tires com­bined with the pres­ence of these met­al cat­a­lysts is the like­ly rea­son why burn­ing tires with coal has been found to pro­duce more diox­in pol­lu­tion than burn­ing only coal. Increased diox­in emis­sions have been found in most of the tests con­duct­ed where diox­in emis­sions at facil­i­ties burn­ing 100% coal were com­pared to those co-fir­ing 4–30% TDF.

Data From	TDF Con­tent (% TDF com­pared to 100% coal)	Dioxins/Furans
4 Cal­i­for­nia Cement Kilns6,16–22	<20%	Increased between 53% and 100%
5 Cana­di­an Cement Kilns23		Increased 37% and 247% in two tests Decreased 54% and 55% in two oth­er tests
Vic­torville, CA Cement Kiln24	24.6%	Diox­ins increased 139–184% Furans increased 129%
Cuper­ti­no, CA Cement Kiln26		Increased 30%
Dav­en­port, CA Cement Kiln24,27	30%	Diox­ins increased 398% and 1,425% in two tests Furans increased 58% and 2,230% in two tests
Dav­en­port, CA Cement Kiln28	20%	Increased 25%
Lucerne Val­ley, CA Cement Kiln29	20%	Diox­ins and some diben­zo­fu­rans increased
Chester, PA Paper Mill30	4–8%	Increased 4,140%
U Iowa, Iowa City, IA Indus­tri­al Boil­er2	4%	Decreased 44%
U Iowa, Iowa City, IA Indus­tri­al Boil­er2	8%	Decreased 83%

Oth­er Chorine-Based Pollutants

In addi­tion to diox­ins and furans, a num­ber of oth­er harm­ful chem­i­cals are emit­ted from incin­er­a­tion of chlo­rine-based sub­stances in tires.^3,25,26,28

Among the halo­car­bons emit­ted dur­ing tests at TDF incin­er­a­tors are PCBs, dichloroben­zene, trichloroben­zene, tetra­chloroben­zene, hexa­chloroben­zene, chlorophe­nol, and dichlorophe­nol, which are all high­ly tox­ic com­pounds and are all either proven or sus­pect­ed to be car­cino­genic.³¹

Non-Chlo­ri­nat­ed Hydro­car­bon Pollutants

Tires also con­tain petro­chem­i­cal feed­stocks, includ­ing buta­di­ene and styrene (the lat­ter being a ben­zene deriv­a­tive). The chem­i­cals are both car­cino­gens. Oth­er car­cino­genic ben­zene deriv­a­tives, such as M, P and O‑Xylenes are some­times found in tire derived fuel as well.⁴

Poly­cyclic Aro­mat­ic Hydro­car­bons (also known as Polynu­clear Aro­mat­ic Hydro­car­bons) is a name applied to over 100 chem­i­cals con­tain­ing mul­ti­ple ben­zene rings that are dif­fi­cult to break down. PAHs are known to cause can­cer in rats and “may rea­son­ably be expect­ed to be car­cino­gens” in humans as well, accord­ing to the Depart­ment of Health and Human Ser­vices.^4,32 Approx­i­mate­ly 25% of tire con­tents are PAHs.⁴ Tire incin­er­a­tion tests have shown increas­es (com­pared to only burn­ing coal) in PAHs of between 88% and 23,938% (most are in the sev­er­al hun­dreds or thou­sands), although one test found a decrease of 68%.^{6,16,17,25,26,28}

Heavy Met­als

Tires con­tain around 20 dif­fer­ent met­als, none of which can be destroyed by burn­ing them, since they’re ele­ments. Met­als known to be in tires include alu­minum, anti­mo­ny, arsenic, bar­i­um, beryl­li­um, cad­mi­um, chromi­um, cobalt, cop­per, iron, lead, mag­ne­sium, man­ganese, mer­cury, nick­el, sele­ni­um, sil­i­con, tin, tita­ni­um and zinc.^2,13,33,34 Zinc is present in par­tic­u­lar­ly high amounts, since zinc oxide is used in the vucan­iza­tion process. Most of them, includ­ing arsenic, lead, mer­cury, and chromi­um VI, are quite tox­ic to humans and can also wreak eco­log­i­cal hav­oc on aquat­ic wildlife if even a small quan­ti­ty finds its way into a body of water. Some met­als, like mer­cury, can accu­mu­late in wildlife. A 2002 test of emis­sions from a Col­orado cement kiln burn­ing TDF with coal found an 8% increase in mer­cury when TDF was used, lead­ing to near­ly 5 pounds of addi­tion­al mer­cury pol­lu­tion per year — enough to con­t­a­m­i­nate about 2,000 twen­ty-acre lakes to the point where the fish can­not be eat­en due to methylmer­cury bioaccumulation.

The test data for met­al emis­sions varies wide­ly for each met­al, but the over­all trend shows increas­es in most met­als when TDF is burned along with coal.^{2,3,16,16,17,25,26,28}

This evi­dence clear­ly demon­strates that tire incin­er­a­tion releas­es a vari­ety of tox­ic pol­lu­tants into the air, pos­ing a dan­ger­ous and poten­tial­ly dead­ly threat to human health and the environment.

Alter­na­tives to Tire Incineration

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Foot­notes:

1. “U.S. Scrap Tire Mar­kets 2005,” Rub­ber Man­u­fac­tur­ers Asso­ci­a­tion, Nov 2006.
   (796 KB PDF file) [Local copy]
2. Joel I. Reis­man, Paul M. Lemieux, “Air Emis­sions from Scrap Tire Com­bus­tion.” Envi­ron­men­tal Pro­tec­tion Agency, Oct. 1997.
   www.epa.gov/ttncatc1/dir1/tire_eng.pdf (PDF file) [Local copy]
3. Green­peace, “Tire incin­er­a­tion and Tox­ic Emis­sions: New data from the Modesto Incin­er­a­tor, West­ley, CA.” www.energyjusticenetwork.org/tires/files/greenpeaceletter.html
4. Dr. Neil Car­man, “Haz­ards of Burn­ing Tires.” June 1997.
   www.portaec.net/local/tireburning/hazards_of_burning_tires.html
5. North Car­oli­na Divi­sion of Pol­lu­tion Pre­ven­tion and Envi­ron­men­tal Assis­tance, “Tire-Derived Fuel.“
   www.p2pays.org/ref/11/10504/html/usa/emission.htm [Local copy]
6. Dr. Sey­mour I. Schwartz. Let­ter to Cal­i­for­nia Inte­grat­ed Waste Man­age­ment Board. Jan­u­ary 21, 1998.
   www.portaec.net/local/tireburning/dr_schwartz.html [Local copy]
7. Diox­in Home­page.
   www.ejnet.org/dioxin/
8. IARC Mono­graphs Pro­gramme on the Eval­u­a­tion of Car­cino­genic Risks to Humans
   www-cie.iarc.fr/htdocs/monographs/vol69/dioxin.html
9. Draft Expo­sure and Human Health Reassess­ment of 2,3,7,8‑Tetrachlorodibenzo-p-Dioxin (TCDD) and Relat­ed Com­pounds, Part III, USEPA, Office of Research and Devel­op­ment, EPA/600/P‑00/001Bg, SAB Review Draft, Sep­tem­ber 2000.
   cfpub.epa.gov/ncea/cfm/part3.cfm
10. “OECD Emis­sion Sce­nario Doc­u­ment — Addi­tives in the Rub­ber Indus­try,” Fed­er­al Envi­ron­men­tal Agency, Berlin, Ger­many, March 3, 2003.
    (1.2 MB PDF file) [Local copy]
11. “Sub­ject: Rub­ber Com­pound … Poly­mers,” Toyo Tire Talk
    [Local copy]
12. “Tires as a Fuel Sup­ple­ment: Fea­si­bil­i­ty Study,” Cal­i­for­nia Inte­grat­ed Waste Man­age­ment Board, Sacra­men­to, CA, Jan­u­ary 1992.
    www.ciwmb.ca.gov/Publications/default.asp?pubid=90
13. “Scrap Tire Char­ac­ter­is­tics,” Scrap Tire Man­age­ment Coun­cil web­site, archived Oct 10, 2000. Chlo­rine con­tent is list­ed as 0.15% of tires by weight. This is described as a “Rep­re­sen­ta­tive Analy­sis of TDF” pro­duced by Waste Recov­ery, Inc. in 1986.
    Archive of www.rma.org/scrapchn.html (Once it was brought to RMA’s atten­tion that chlo­rine con­tent of tires was avail­able on their own web­site, they removed the chem­i­cal com­po­si­tion of tires from their cur­rent page on Scrap Tire Characteristics)
14. U.S. Envi­ron­men­tal Pro­tec­tion Agency 1999 Infor­ma­tion Col­lec­tion Request (ICR) Coal Analy­sis Results
    www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html#TECR
15. “Met­als as Cat­a­lysts for Diox­in For­ma­tion,” Diox­in Home­page.
    www.ejnet.org/dioxin/catalysts.html
16. “Mar­kets For Tires As Fuel,” St. Vrain Val­ley Com­mu­ni­ty Watch­dogs
    www.geocities.com/watchdogs_99/ca_research.html [Local copy]
17. “Attach­ment A: Envi­ron­men­tal and Health Con­se­quences from Using Tires as Fuel; Health Risk Assess­ment,” Schwartz, Car­men, et. al., from report to CIWMB, Domes­tic Mar­kets for California’s Used and Waste Tires.
    www.energyjusticenetwork.org/tires/files/attacha-health-risk.pdf
18. Cal­i­for­nia Inte­grat­ed Waste Man­age­ment Board, (CIWMB). Tires as a Fuel Sup­ple­ment: Fea­si­bil­i­ty Study. Sacra­men­to, CA, (1992).
19. Cal­i­for­nia Port­land Cement Com­pa­ny. Mod­i­fy Pyro­proces­sor: Add Whole Tire Han­dling Sys­tem and Allow Use of Whole Tires as Sup­ple­men­tary Fuel to Kiln. Appli­ca­tion to Kern Coun­ty Air Pol­lu­tion Con­trol Dis­trict, (March 28, 1995).
20. Carnot Tech­ni­cal Ser­vices, Inc., and Radi­an Inter­na­tion­al, LLC, Tustin, CA. Kaiser Cement Cor­po­ra­tion TDF Demon­stra­tion Pro­gram. Vol­ume I, Exec­u­tive Sum­ma­ry, (April, 1996), pp. 1–15.
21. RMC Lon­es­tar Cement. Pre­lim­i­nary Eval­u­a­tion and Pro­pos­al to Con­duct Test­ing on the Use of Whole Tires as a Sup­ple­men­tary Fuel in the Cement Man­u­fac­tur­ing Process. Dav­en­port, CA, (May 1, 1992), pp. 6, 29.
22. Bate­man, Bri­an. Bay Area Air Qual­i­ty Man­age­ment Dis­trict. Per­son­al com­mu­ni­ca­tion with S. I. Schwartz, June 14, 1996.
23. “Proc­tor and Red­fern, Ltd. A Review of Emis­sions Per­for­mance of Cement Kilns Using Tire-Derived Fuel. Don Mills, Ontario, Cana­da, (July, 1995), pp. 5, 16–23.” Test of 5 Cana­di­an Cement Kilns. Cit­ed in Notes 16 and 17.
24. “Esti­mates of Organ­ic Emis­sions TDF for RMC Lon­es­tar and South­west­ern cement kilns burn­ing tires as fuel.” Cit­ed in Note 25.
25. “Pro­posed Per­mit No. 1003026(J) to Burn Tire Derived Fuel Cal­i­for­nia Port­land Cement Com­pa­ny,” Let­ter from Neil J. Car­man, Ph.D. to Cit­i­zens for a Bet­ter Envi­ron­ment, San Fran­cis­co, CA, Novem­ber 1995.
    www.energyjusticenetwork.org/tires/files/carman-cal-portland.pdf
26. “Com­ments on Haz­ards relat­ed to Tire-Derived Fuel use in Cement Kilns,” Let­ter from Neil J. Car­man, Ph.D. to Cal­i­for­nia Inte­grat­ed Waste Man­age­ment Board, Sacre­men­to, CA, Octo­ber 1997.
    www.energyjusticenetwork.org/tires/files/carman1997ciwmb.pdf
27. “Pre­lim­i­nary Eval­u­a­tion of RMC Lon­es­tar Dav­en­port Cement Plant: Pro­pos­al to Con­duct Test­ing on the Use of Whole Rub­ber Tires as a Sup­ple­men­tary Fuel in the Cement Mfg Process,” May 1, 1992. Cit­ed in Notes 25 and 26.
28. “Attach­ment B: Exam­i­na­tion of the Board’s Claim of ‘No appre­cia­ble dif­fer­ence in tox­ic emis­sions’,” Schwartz, Car­men, et. al., from report to CIWMB, Domes­tic Mar­kets for California’s Used and Waste Tires.
    www.energyjusticenetwork.org/tires/files/attachb-toxic-emissions.pdf
29. “Report of Air Pol­lu­tion Source Test­ing of a Cement Plant Rotary Kiln Fired on Rub­ber Tires and Coal at Mit­subishi Cement Com­pa­ny, Lucerne Val­ley, Cal­i­for­nia.” Cit­ed in Note 25.
30. “Kim­ber­ly-Clark Cor­po­ra­tion Chester Mill Tire-Derived Fuel Tri­al Emis­sion Test Results.” Tests con­duct­ed in 1999.
31. Inter­na­tion­al Agency for Research on Can­cer (IARC) Mono­graphs on the Eval­u­a­tion of Car­cino­genic Risks to Humans and their Sup­ple­ments. See Vol­umes 18, 41, 73 and 79.
    www-cie.iarc.fr/monoeval/allmonos.html
32. Envi­ro­Tools Fact­sheet: Poly­cyclic Aro­mat­ic Hydro­car­bons (PAHs) www.envirotools.org/factsheets/fs_pahs.shtml [Local copy]
33. “Emis­sion Con­trol,” North Car­oli­na Divi­sion of Pol­lu­tion Pre­ven­tion and Envi­ron­men­tal Assis­tance.
    www.p2pays.org/ref/11/10504/html/usa/emission.htm [Local copy]
34. “Tire Derived Fuel Char­ac­ter­is­tics,” North Car­oli­na Divi­sion of Pol­lu­tion Pre­ven­tion and Envi­ron­men­tal Assis­tance.
    www.p2pays.org/ref/11/10504/html/usa/tdfdata.htm [Local copy]