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The Inter-District Waste Tire Management Program:

An Analysis of the Pulaski County Regional Solid

Waste Management District’s Administration

Master of Public Administration Capstone Project

Spring 2014

Lane Bailey, Brent Dycus, Geoffrey Shiloh

May 7, 2014

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Abstract

The Pulaski Inter-District Waste Tire Program’s mission is to protect the public health and the

environment by collecting, processing, and recycling waste tires generated in the nine-county

central Arkansas area which includes Pulaski, Lonoke, Prairie, Monroe, Faulkner, Saline, Garland,

Hot Spring, and Clark Counties. This study focuses on the efforts of the Pulaski County Regional

Solid Waste Management District (PCRSWMD) and the Pulaski County office is the Administrator

of the Inter-District Program. The project analyzed current operations, best practices, regulatory

affairs, and funding structures with the intent to provide the Inter-District’s Oversight Group

with a strategic plan based on deliverable short-, medium-, and long-term policy and practice

recommendations.

Acknowledgements:

Stacy Edwards and Desi Ledbetter of the Pulaski County Regional Solid Waste Management

District; Elizabeth Hoover, Arkansas Department of Environmental Quality; George F. Gilbert, P.E.,

Environmental Engineer Consultant with the Kentucky Division of Waste Management.

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Table of Contents

Abstract ............................................................................................................................................................................... 5

Acknowledgements: ....................................................................................................................................................... 5

Key Terms and Acronyms............................................................................................................................................. 9

Introduction.................................................................................................................................................................... 11

The Existing Structure ................................................................................................................................................. 12

Arkansas’ Districts.................................................................................................................................................... 14

The Continuum: Current and Moving to the Future ...................................................................................... 15

Best Practices: Comparative Studies .................................................................................................................... 17

Alabama ...................................................................................................................................................................... 17

Kentucky...................................................................................................................................................................... 18

Tennessee ................................................................................................................................................................... 19

Mississippi .................................................................................................................................................................. 19

How Arkansas Compares ...................................................................................................................................... 20

Recommendations ....................................................................................................................................................... 22

Short Term ................................................................................................................................................................. 22

Data Management .............................................................................................................................................. 22

Build on Collaborative Efforts ......................................................................................................................... 23

Public Awareness and Increased Enforcement ........................................................................................ 23

Levy Charges for Waste Tires from City and County Public Works Departments ...................... 25

Medium-Term ........................................................................................................................................................... 25

Used Tire Dealers - Out from Under the Radar ....................................................................................... 25

Obtain Regulatory Approval on Intra-District Funds. ........................................................................... 25

Marketing Products ............................................................................................................................................ 26

Long-Term .................................................................................................................................................................. 27

Waste Tires and Asphalt ................................................................................................................................... 27

Legislative Activity .............................................................................................................................................. 27

Conclusions .................................................................................................................................................................... 28

Bibliography ................................................................................................................................................................... 31

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Key Terms and Acronyms

ADEQ – Arkansas Department of Environmental Quality

APCEC – Arkansas Pollution Control and Ecology Commission

AHTD – Arkansas Highway and Transportation Department

Civil Engineering Application – The use of waste tires in lieu of or in addition to

natural occurring materials (such as rock, sand dirt, gravel, etc.) in construction.

Crumb Rubber – The name given to any material derived by reducing scrap tires or

other rubber into uniform granules, with the inherent reinforcing materials such as steel

or fiber removed (along with inert contaminants such as dust, glass, or rock).

EPA – The Environmental Protection Agency

Fee Paid Tire – A waste tire in which a state waste tire fee has been collected, reported,

and paid on the replacement tire sold at retail.

Land Disposal – ADEQ’s preferred term for monofill (see below)

Landfill – A place to dispose of refuse and other waste material by burying it and

covering it over with soil.

Monofill – A landfill that accepts only one classification of waste material; in this report,

monofills refer to landfills designated or permitted for scrap tire burial. Monofills are

typically used with the intent to later unearth the tires for recycling or reuse.

Non-Fee Paid Tire – A waste tire in which no state waste tire fee has been collected,

reported, and paid on a replacement tire.

Oversight Group – The Inter-District governing body consists of the chair of each

participating RSWMD’s board.

PCRSWMD – Pulaski County Regional Solid Waste Management District

Processed Tire – Tires and commingled tire parts and pieces that have been cut,

shredded, or otherwise altered so that they are no longer whole and/or no longer

identifiable.

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PTE – Passenger Tire Equivalent; PTE is a notional term using a standard weight of 10kg

to represent the average weight of a passenger tire. The weight of various tire types can

be expressed in PTEs. For example, a Medium Truck tire, which weighs approximately

50kg, is considered equivalent to 5 PTE in weight.

RAF – Rubberized Asphalt Foundation, a research foundation “dedicated to the science

and practical use of recycled tire rubber in asphalt.” The foundation is comprised of

academic, government, and industry experts.

RPA – Rubber Pavements Association, a non-profit industry association that promotes

the use of rubberized asphalt.

RSWMD – Regional Solid Waste Management District

Rubber Mulch – Mulch made from chopped or crumbed rubber, often sourced from

used automobile tires.

Rubberized Asphalt (also known as Rubberized Asphalt Concrete, or RAC) – A blend of

paving-grade asphalt, cement, recycled tire crumb rubber, and other additives as

needed for use as binder in pavement construction

Scrap Tire – Any pneumatic tire no longer suitable or useable for its original purpose

and, in addition, includes, but is not limited to, all tires with a manufacturing defect,

except those that are in the process of being returned to the manufacturer for a refund.1

“Scrap tire” and “waste tire” (see below) will be used synonymously in this document.

TDF – Tired Derived Fuel; a process that uses shredded or chipped scrap tire material as

combustible material for power generation.

Waste Tire – a whole tire that is no longer suitable for its original intended purpose

because of wear, damage, or defect.2 “Waste tire” and “scrap tire” (see above) will be

used synonymously in this document.

1 Definition derived from the Alabama Department of Environmental Management.

2 Definition derived from the Mississippi Waste Tire Management Program.

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Introduction

Arkansas is not alone in facing the significant

challenge of diverting and managing millions of reusable

and waste tires that are generated each year. Every new

tire eventually becomes a waste tire. Historically,

waste tires were landfilled, taking up valuable space

and creating breeding grounds for mosquitoes. As

markets have grown, however, many waste tires are recycled for such uses as fuel, civil

engineering projects, playgrounds and trail surfacing, molded rubber products, and

rubber-modified asphalt. Others are retreaded for continued use on vehicles.

Storage and disposal of waste tires is recognized as a serious problem in the U.S.,

and states have passed legislation designed to strengthen local governments’ ability to

regulate these problems by overseeing the hauling, processing, and storage of scrap tires.

State and local governments also work with industry to recycle and beneficially use scrap tires

by developing markets for the collected scrap tires. Many states have grant programs

involving funding for waste tire collection and recycling activities including waste tire abatement

programs involving cleanup of illegal waste tire dumps as well.

Tires that are no longer fit for vehicle use, in the absence of successful recycling and

reuse programs, impose risks to the environmental and economic vitality of local jurisdictions.

Piles of tires pose at least two major health threats: as breeding grounds for disease-carrying

insects and carcinogen-laced smoke and debris from difficult to extinguish tire fires. Nuisance

dumping can be found in big cities, small towns, in ditches, empty lots, forests, and farms.

Public leaders and the citizens they serve want these tires collected and taken away.

Once the tires are collected by proper authorities, another problem surfaces-- what to do

with them? The era of burying waste tires in landfills is decidedly over. Federal, state, and local

jurisdictions have employed a myriad of efforts to reduce the number of waste tires littering the

landscape. Regulations, taxes and fees, public/private partnerships, and other efforts to publicly

subsidize the removal and repurposing of waste tires and materials have resulted in varying

levels of success. However, there does not appear to be an ideal, one-size-fits-all solution to the

problem.

This report analyses waste tire management efforts in Arkansas; specifically the nine-

county area in Central Arkansas known as the Inter-District Waste Tire Management District.

The goal of the project is to provide the Inter-District’s Oversight Group with recommendations

that will make the Inter-District the model for Arkansas and elsewhere. The study involved

It is commonly accepted

in the tire industry that

about one tire per person

per year is discarded.

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reviewing the current waste tire management environment, both within the district and beyond.

Activities included research of market conditions, regulatory affairs, state comparisons, and a

review of private-sector partnerships. The project also involved interviews with principal

personnel at the Arkansas Department of Environmental Quality (ADEQ) and several of the other

nine Waste Tire Management Districts in the State.

In addition to telephone interviews, the other nine districts were invited to participate in

an online survey. The Waste Tire Management, Operational and Administrative Survey obtained

information on current operational activities, funding and administrative challenges, and public

outreach efforts from the Districts. The team conducted similar research with several states via

telephone interviews, email correspondence, and online research.

Additionally, the project involved multiple interviews with Inter-District staff. This

approach resulted in an iterative process, as the staff and the project team exchanged

information gleaned from the research described above. This method helped the project hone

its research and final recommendations to best fit the needs of the District, and the Oversight

Group.

The Existing Structure

Arkansas’ scrap tire management efforts

began in 1991 with passage of Act 749, which

established the Waste Tire Program. This program

created a funding process for permitting waste tire

collection and processing facilities. The Act also

imposed a fee on every motor vehicle tire sold at

retail facilities in Arkansas to fund waste tire

programs and grants management procedures.

According to the 1991 law, the Waste Tire Program is administered by the Arkansas Pollution

Control and Ecology Commission (APCEC). APCEC’s Regulation 14 outlines the procedures for

Arkansas’ Waste Tire Program.

Act 749 also directed the APCEC to distribute grant funds to the already-existing

Regional Solid Waste Management Districts (RSWMDs). This funding and management

structure has evolved into ten Waste Tire Management Districts, generally based on

geographically-contiguous groups of counties. The state-level entity that enforces regulations

and funding distribution is the Arkansas Department of Environmental Quality (ADEQ).

The Inter-District Waste Tire

Management District,

oversees the processing of

more than 700,000 tires per

year.

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In Central Arkansas, the Inter-District Waste Tire Management Program consists of

Pulaski, Lonoke, Prairie, Monroe, Faulkner, Saline, Garland, Hot Spring and Clark Counties. The

District was established in 1992, with the Pulaski County Solid Waste Management District

(PCSWMD) identified as its administrative body.

According to its public literature, the Inter-District Waste Tire Program’s mission is “to

protect the public health and environment of our beautiful state by collecting, processing, and

recycling waste tires generated” in the nine-county area. A five-member Oversight Group, often

referred to as the Board, made up of the chairpersons of each of the collaborating RSWMDs,

guides the program. Since its inception, the Inter-District has processed over sixteen million

tires. The Inter-District contracts with Davis Rubber Company, Inc. of Little Rock, to transport,

process, and dispose the waste tires in the District.

In general terms, the waste tire process from beginning to end is quite simple, but it can be

difficult to implement. The process is as follows:

The Consumer purchases new tires and pays a $2.00 disposal fee toward his or her old

tires.

A licensed hauler collects used tires from dealer and delivers them to a collection center.

(Dealers may also haul their own tires.)

The Contracted Recycler retrieves the waste tires from the collection centers.

The Contractor converts and sells recycled

materials or products.

The Pulaski County Regional Solid Waste

Management District, as the administrator for the

Inter-District Waste Tire Management District,

oversees the processing of more than 700,000

tires per year. Almost 90% of all tires collected in

the Inter-District are diverted from landfill

disposal. Under the contract with Davis Rubber

Company, Inc., these tires are processed into tire-

derived fuel (TDF), playground surfacing and

mulching materials, and fine crumb rubber for

athletic fields.

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Arkansas’ Districts

Each of the ten Waste

Tire Districts in Arkansas

manages their activities

differently. On the

continuum of waste tire

recycling, most waste tire

districts in Arkansas have

reduced the use of

monofilling and tire exporting.

Arkansas and its ten-district

model have shown similar

success in turning tires into

fuel or crumb rubber as states

with highly centralized

models. Research indicates there are specific activities in some states that the Inter-district may

choose to adopt, which are outlined in further detail below.

Arkansas Waste Tire District Activities

Waste

Management

Districts

Land

Disposal

TDF (Tire

Derived

Fuel)

Crumb

Rubber

Rubberized

Asphalt and

Civil

Engineering

White River

Upper

Southwest

Boston

Mountain

Craighead

East

Inter-

District

Southeast

Southwest

West River

Valley

Ozark

Mountain

East Inter-District and White River District sell about a third of their tires to Electric Arc Furnace to use in their products.

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The Continuum: Current and Moving to the Future

The history of waste tire activities in the United States, alongside an evaluation of state-

by-state efforts, reveals a path of clear advancement. This report refers to that path as the

continuum. The continuum begins with the unregulated dumping of scrap tires in forests, empty

lots, or any other unregulated ground. It is almost impossible to account for every illegal tire

dump, but in 1994 there were 700 to 800 million tires in unregulated stockpiles, according to an

estimate by the EPA. It is estimated that there is at least one scrap tire produced per person in

the United States every year. Regulatory efforts have outlawed such dumping – though limited

enforcement has prevented the eradication of the practice. Tire dumping remains a problem; it

is easy, especially in rural areas, and often less expensive than proper disposal. However, It is

still illegal.

Landfills are legal destinations for waste tires in some

jurisdictions, but not a desired option. Tires have to be

recycled or repurposed separately from other solid wastes. For

this reason, in addition to space considerations, landfilling tires

is discouraged.

The next step along the path to better management is

monofilling, or the use of landfills dedicated solely to tires.

Monofilling is advancement over landfilling only in that it

keeps tires out of multi-use landfills, and provides a

destination for waste tires that might otherwise be illegally

dumped. Monofilling is not, however, a sustainable solution.

It requires an ever-growing amount of land. Though

environmental risks are mitigated by dirt cover, fire hazards

and insect breeding remain. Monofilling is an interim solution;

when economic and technological conditions make reuse and

recycling more feasible, the tires will be retrieved.

The next step on the continuum is not fully recycled products, but a step beyond

monofilling. Burning waste tires components as fuel for industry (known as tire-derived fuel,

or TDF) is in the middle of the continuum. It requires equipment that shreds tires and separates

rubber from steel. Burning rubber produces higher BTUs than coal; unfortunately, it also

produces toxins that are different from other fuels sources, requiring users to invest in

specialized filtering systems. Nationwide, about 54% of all scrap tires collected are turned into

fuel.

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The Inter-District has helped move

the jurisdiction further along the continuum

through a public-private partnership with

Davis Rubber Company of Little Rock since

1992. The tires are used as crumb rubber

for playgrounds and military training areas

and feeding stock to facilities that have

advanced equipment. While the majority of

tires Davis receives are currently converted to

fuel, Davis is expanding its operations to

allow for more diversified products. The

company recently installed a magnetized collection system to pull the steel from shredded

rubber, creating a secondary source of income by selling the steel to a recycling facility in Fort

Smith, Arkansas. Additionally, Davis recently purchased new shredding equipment that can

handle larger tires (such as those from earth-moving vehicles). Davis also has plans to upgrade

facilities that will allow shredding rubber into smaller pieces – a basic requirement for increasing

the number of products and uses for rubber.

At the idealized end of the continuum, at least with today’s technology and current

market environment, is the use of rubberized asphalt. Phoenix, Arizona is the leader in

rubberized asphalt, starting in 2003 with a three-year, $34 million project to resurface about 155

miles of Phoenix area freeways with asphalt fortified with finely ground waste tire material.

Alaska, California, Florida, Texas,

South Carolina, Massachusetts, Nebraska,

Rhode Island and New Jersey utilize

rubberized asphalt for highway and

interstate paving projects as well.

Rubberized asphalt is considered safer

than traditional asphalt, with greater skid

resistance and decreased splash and spray

in wet conditions. The rubberized asphalt

also reduces traffic noise by 5 decibels and

delays the aging of the asphalt.

This option is on the high end of

the waste tire management continuum

because companies that can shred tires to

the size needed for rubberized asphalt can

Rubberized asphalt is considered

safer than traditional asphalt, with

greater skid resistance and

decreased splash and spray in wet

conditions. The rubberized asphalt

also reduces traffic noise by 5

decibels and delays the aging of the

asphalt.

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recycle the majority of rubber and other materials in the tire. Neither the District nor Davis

Rubber Company have the ability to shred tires to the level needed for asphalt. Furthermore,

the Arkansas Highway and Transportation Department (AHTD) has not approved the use of

rubberized asphalt for use on Arkansas roads.

Best Practices: Comparative Studies

The team studied waste tire disposal practices in several states and opted to focus on

Alabama, Kentucky, Tennessee, and Mississippi. These states serve as apt comparison models

because they are geographically and demographically similar to Arkansas. The states also tend

to reside in the same general area of the political spectrum as Arkansas, which indicates that the

political will and popular views toward green initiatives are similar to Arkansas’ own.

Alabama

The Alabama Scrap Tire Environmental Quality Act of 2003 provides a funding

mechanism for waste tire management through a $1.00 per tire fee on the sale of each new

passenger-grade tire in Alabama. The law enables the Alabama Department of Environmental

Management (ADEM) to provide a uniform, statewide system of regulation of tires, from the

point of sale to the point of end use (or disposal), including a statewide scrap tire manifest

system, and effective enforcement of waste tire laws.

One thing that Alabama does well is help

promote and develop markets as an alternative to

the landfill disposal scrap tires or processed tire

material as an end use through the Scrap Tire

fund. In 2009, Alabama revised the Scrap Tire

Environment Quality Act, requiring ADEM to

research and develop a scrap tire marketing plan

for the State. From that revision grew the ADEM

Scrap Tire Marketing Program, which aims to increase public awareness about the utilization of

scrap tire material by showcasing waste-tire products used in Alabama state parks and

elementary school playgrounds. ADEM will also be partnering with the Alabama Department of

Transportation and the National Center for Asphalt Technology to pursue the use of scrap tire

material in rubber modified asphalt (a date of this project wasn’t given). To date, Alabama has

invested approximately $7,000,000 for market development and implementation of beneficial

waste tire end-use projects.

To date, Alabama has invested

approximately $7,000,000 for

market development and

implementation of beneficial

waste tire end-use projects.

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Alabama employs a vigorous “enforcement and remediation” program. The compliance

and enforcement of scrap tires in Alabama is primarily the mission of ADEM’s Materials

Management Section. The section investigates unauthorized scrap tire accumulations upon

complaints from citizens or public officials. Field inspections of these sites include observations

of site conditions, noting the amount and conditions of scrap tires, photographing the area,

using GPS to mark the area, and determining the ownership of the property.

Once the land owner or responsible party is identified, ADEM initiates enforcement

action to have the tires removed at the expense of the owner. If an owner or responsible party is

not identified, then ADEM uses funds from the Scrap Tire Fund to have approved scrap tire

contractors bid for waste tire removal. Alabama’s efforts during the 2007-2009 biennium

resulted in more than 300 complaints and over 450 enforcement actions for cleanup either by

the responsible party or property owner.

Kentucky

The Kentucky Waste Tire Program also collects a $1.00 fee on new motor vehicle

replacement tires at the point of sale; the retailer pays the Kentucky Department of Revenue

those fees monthly. The funds generated are used to implement programs such as waste tire

amnesty days, remediation programs, and grant funds to manage and develop markets for

waste tires.

Five commercial waste tire processors operate in Kentucky. In 2013 they processed 3.9

million tires into various products. The largest processor, Liberty Tires, primarily manufactures

colored playground mulch, but produces TDF as well. Two of Kentucky’s processors produce

only TDF, while another processor makes TDF and crumb rubber. The fifth processor only

produces crumb rubber. The amount of competition in the market helps drives the market and

could possible help drive innovation.

Unlike other programs studied, Kentucky has a Waste Tire Working Group, which reviews

the state’s waste tire program and provides advice to the Governor’s cabinet on proposed

changes to applicable statutes and regulations in hopes of improving the program. The group

consists of the Director of the Division of Waste Management, Manager of the Recycling and

Local Assistance Branch, Deputy Director of the Department of Agriculture, county solid waste

coordinators, a county judge, a city mayor and a tire retailer.

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Tennessee

Tennessee is in the midst of implementing a new set of procedures for its waste tire

program. The revenue will remain the same at $1.35 per new tire sold, but the funding

distribution process will change from a grant-based model to a direct-payment method (at the

county level). Of most interest to the study, Tennessee has now contracted with a private-sector

company to obtain and maintain electronic manifesting of tire sales. Districts (Counties) will

have the ability to upload manifests and download reports. However, each county will have to

negotiate its own contract with the vendor in order to use its services.

The new law requires the counties to report to their Solid Waste Planning Region the

number or weight of tires recycled and indicate the beneficial end user of the recycled tires.

Counties will also be required to “report the number or weight of tires landfilled, if any, and give

financial justification” for why landfills were used. This information will be included in an Annual

Progress Report produced by the Division of Solid Waste Management.

Mississippi

The State of Mississippi generates about

three million waste tires each year. The program is

administered by the Mississippi Waste Tire

Management Program (MWTM). The state imposes

a fee of $1.00 for each new tire sold by any person

engaging in the business of making wholesale sales

or new tires to retailers within Mississippi. The

MWTM administers the state’s rules and regulations

for the collection, transportation, storage,

processing, recycling and disposal of waste tires and

is tasked by the state legislature with promoting the

goal of statewide waste tire recycling. Like Alabama, Mississippi’s program is highly centralized,

though the state does maintain six geographically-based “areas of responsibility” to alleviate its

centralized model.

Mississippi law allows local citizens and small businesses producing ten or fewer waste

tires per week to use public collection sites; a significant increase over Arkansas’ four tires per

month. This more generous limit is possibly a reason why Mississippi, a state very similar to

Arkansas in size and demographics, has five private-sector waste tire processing facilities while

Arkansas has only one.

Mississippi law allows local

citizens and small businesses

producing ten or fewer waste

tires per week to use public

collection sites; a significant

increase over Arkansas’ four

tires per month.

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How Arkansas Compares

The comparative study reveals a range of activity taking place in other states that can be

replicated in Arkansas. However, the outcomes indicate that Arkansas is performing similarly to

the other states. “Apples-to-apples” comparisons were difficult because each state self-reports

its data, and each uses different measurement criteria. For the purposes of this study,

percentages of collected tires converted to fuel versus percentages converted to non-fuel

products were calculated. These criteria were chosen because they help determine where, along

the continuum detailed above, a jurisdiction lies.

Comparative States

*Alabama: 2012; Kentucky: 2012; Tennessee: 2013; Mississippi: 2011; Arkansas: 2012; U.S.: 2013

Because our state places a much higher percentage of tires in landfills, Arkansas does not

appear as strong as the comparison states. However, the table indicates that Arkansas is

relatively close to its counterparts in the percentage of collected waste tires turned into fuel and

non-fuel products. Alabama and Kentucky are doing much better in their efforts. Tennessee’s

State Fee per

New

Passenger

Tire Sold

Used

Tire

Fee

Land

Disposal

Percent

Converted

to Fuel

Percent

Converted

to non-

fuel

products

Number of

State

Contracted

Private-

sector

processing

facilities

Waste Tires

processed per

year*

Alabama $1.00 No 7% 52% 34% Unknown 5,000,000

Kentucky $1.00 No 13% 49% 38% 5 4,200,000

Tennessee $1.35 No N/A N/A N/A 1 N/A

Mississippi $1.00 No 5% 77% 18% 5 3,000,000

Arkansas $2.00 No 44% 34% 22% 1 2,700,000

U.S.

Averages

N/A N/A N/A 45% 31% Unknown 290,000,000

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outcomes are not available; however, as Tennessee is embarking on a new structure this year,

more measurements may be available soon. Nevertheless, one in five tires in Arkansas are

converted to non-fuel products. Mississippi continues to turn most of its tires into fuel.

Since there does not appear to be an “ideal” waste tire management program that can

be replicated for every population, Arkansas and the Inter-District should choose appropriate

examples from other states. For example, Tennessee’s new online manifest reporting structure

could be a model for Arkansas to follow. Additionally, Kentucky’s Waste Tire Working Group

should be studied for additional consideration.

To develop a program that will be considered a model throughout Arkansas and

surrounding states, the Inter-District Oversight Group must develop a strategic approach. The

Oversight Group should make as its goal to advance along the continuum described in this

document. The following recommendations, derived from comparisons with other states,

interviews with key program participants, and examinations of the market and technological

environments, will assist the Oversight Group in its pursuit.

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1

59

Arkansas Waste Tire Disposition 2012

Crumb Rubber

Electric Arc Furnace

Other

TDF

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Recommendations

As with any successful project, a clear and

unified vision among the stakeholders will be required

to advance along the waste tire continuum. A clear

vision with measurable goals and objectives will

identify direction and purpose, alert the Oversight

Group to changes that will be required, and promote

ownership through involvement that ultimately results

in more scrap tires out of the ground and into markets.

The Oversight Group needs to leverage the

District’s assets in pursuit of fulfilling the following

recommendations. The recommendations derive from statewide and multi-state comparisons,

interviews with key stakeholders, best practices, lessons learned from previous activities, and

other research methods. They are divided into three categories: Short-, Medium-, and Long-

Term solutions.

The Short-Term recommendations should be achievable with existing or easily-acquired

resources. They are designed to be implemented immediately, and should likewise produce

immediate benefits. Medium-Term activities will require additional strategic planning and

commitment from the Oversight Group. The Long-Term section provides the Oversight Group a

path to advance the District further along the continuum.

Short Term

Data Management

Inter-District staff understands that the data they have to work with are not efficiently

organized. The review finds that the PCRSWMD should improve its data collection, storage,

management, and analysis abilities. The current database management activities utilize

outdated tools and do not have enough dedicated resources, according to the study findings.

Missing or unorganized operational data result in missed opportunities and, often,

forfeiture of potential revenue. As noted above, Tennessee recognized it has a similar problem

and responded by contracting with a private sector data management company.

In order to have more confidence in its data, the District should obtain access to a

system more suited to its needs, such as Structured Query Language (SQL) databases managed

by professional Database Administrators (DBAs), rather than using Microsoft Excel and Access as

Piles of tires pose at least

two major health threats:

As breeding grounds for

disease-carrying insects and

carcinogen-laced smoke

and debris from difficult to

extinguish tire fires.

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its primary tools. Excel was not designed to be used as a database. The existing structure does

not allow for more than one person to work at a time. Nor does it record a history of changes

to the data, so there is no reliable audit trail.

This environment (one person maintaining the District’s data via Microsoft Excel

spreadsheets and MS Access database management software) is not sustainable. The District’s

data management requires multiple resources with experience in database administration, strict

data governance rules, and multiple quality control checkpoints. Such resources are likely

available at the city or county government level. If not, the district might explore partnering

with the state’s other districts, as data management costs are highly-reflective of economy-of-

scale models. In other words, all ten districts could likely obtain data management services for

the same cost as one district obtaining them for its own use.

ADEQ has a SQL server designed for such activities, but it is not utilized for waste tire

management activities. It is unknown whether ADEQ employs the DBAs required to maintain

the data.

Build on Collaborative Efforts

Research indicates the ten districts and ADEQ want to collaborate more thoroughly; they

simply have not done so. To provide continuous research and recommendations to continue to

push the Inter-District forward, a formation of a statewide group should meet on a regular basis.

Kentucky’s Waste Tire Working Group should serve as a model for this effort. The Kentucky

project team initiated early steps through its questionnaire, email, and telephone activities. The

District should take this effort and develop ways to build upon it. The Inter-District should lead

the way by initiating quarterly conference calls or in-person meetings. These meetings should

be guided by a published agenda, with SMART (Specific, Measurable, Assignable, Realistic, Time-

related) objectives.

Public Awareness and Increased Enforcement

The Inter-District made initial steps in increasing public awareness with their 2013

billboard campaign. The campaign stressed the illegality of dumping tires. One billboard can

still be seen on southbound University Avenue between Interstate 30 and the University of

Arkansas at Little Rock campus.

The Inter-District should further its public awareness efforts. One method that would

target a large group of people could be public service announcements in movie theatres across

the district. Posters and handouts describing the proper way to dispose of waste tires, with

locations of collection sites, could be given to new and used tire dealers. Hanging the posters in

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public waiting areas and giving the handouts

to each customer when buying a set of tires

would increase the amount of information

given to educate the consumer. The State of

Maryland used some of these techniques in

the early 2000s to raise their public awareness

of tire recycling and illegal dumping.

Additionally, The Inter-District would

benefit from developing a Social Media

Strategy to engage and communicate with the nine-counties in the district. The PCRSWMD

already has a Facebook page that highlights recycling events, such as elementary school trips to

Waste Management facilities or reminders for drop-off sites times and locations. Social media

outlets like Facebook, Twitter or Instagram could be useful ways for The Inter-District to build

awareness of illegal tire dumping to inform and the community in how they can help solve the

problem. The advantage of social media tools is that the services are usually free and widely

used by the public. However, the responsibility of maintaining and providing feedback will have

to be considered. Social media tools can be a quick, easy, and fun way to engage the

community.

According to the Rubber Manufacturers Association, scrap tire littering results primarily

from poor enforcement of anti-littering and anti-dumping laws. “Unlicensed tire jockeys figure

they can get away with illegal dumping because no one is enforcing the law.” Alabama

recognized this and began an enforcement and public awareness effort to address the issue.

Since cost recovery and increased operating revenues will be at the core of

recommended solutions, the report suggests the District consider increased enforcement/fines

as a possible revenue-generating solution. The project’s research and outreach efforts have

resulted in calls for increased enforcement from local, district, and state entities (including

ADEQ).

The EPA offers guidance on how to utilize enforcement and fines. For example, they

suggest keeping fines low enough to prevent legal battles, appeals, and bankruptcies, but high

enough to discourage bad behavior. In other words, the District must work with local

jurisdictions to set codes and accompanying fines. Additionally, when a person or entity is

caught and fined, the event should be publicized – let the community know that penalties exist.

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Levy Charges for Waste Tires from City and County Public Works

Departments

To date the PCRSWMD has accepted non-fee paid waste tires from local jurisdictions’

public works departments free of charge. The practice of freely accepting non-fee paid tires

from local- and county-owned vehicles and equipment should end immediately. The Oversight

Group agrees that the District should charge the jurisdictions the same disposal fees that it

would assess any other entity. The billing of local jurisdictions should begin immediately.

Medium-Term

Used Tire Dealers - Out from Under the Radar

The waste tire districts have little-to-no oversight of used tire dealers. This likely

represents an untapped source of revenue and, likewise, an uncontrollable source of expense.

The District should encourage the counties and cities in its jurisdiction to pass ordinances that

require used tire dealers to register as such. One possibility being explored is the use of special

business licenses that require dealers to maintain records on the sale of used tires similar to

those required of new tire dealers. Such actions will not completely end the era of used tire

dealers’ going unregulated, but it will accomplish two things: The ordinances will identify used

tire dealers in the District that would otherwise remain under the radar, and it will help track

used tires sales to prevent the illegal dumping of waste tires.

Obtain Regulatory Approval on Intra-District Funds

The District has expressed interest in obtaining the authority to move funds from county-

to-county as it sees a need. Population density and commercial activities differ significantly

among the counties within the Inter-District. The existing structure does not give the local

districts the necessary flexibility, especially as funds are tied to state grant sources. However,

ADEQ is understandably hesitant to adjust the existing funding structure. Its desire for

standardization among the ten districts must be considered. Therefore it is recommended that

the Inter-District continue to pursue a strategy that will allow for more flexibility while

ameliorating the State’s concerns. Since the Oversight Group represents the counties, they

should be given the authority to make such adjustments.

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Marketing Products

Kentucky and Alabama stress the marketing of

their efforts, particularly by using media campaigns to

showcase end-use products created by successful waste

tire management programs. In Arkansas, the Districts

should be doing a better job of marketing their products

as well. The motivation is to move further along the

continuum; therefore, marketing the capacity to do more

with the tires is in the Districts’ interest.

Since 2004, Kentucky has awarded more than

three hundred grants totaling $7 million, primarily to schools and municipalities, for crumb

rubber uses. The largest ground rubber applications included playground safety cushioning,

colored landscape mulch, and athletic fields. Manufacturing of ground rubber and mulch from

Kentucky tires increased from near zero in 1998 to 1,095,500 PTEs per year in 2013. One of the

major processors in Union County creates a colored mulch for outlets such as Lowes, Home

Depot and Wal-Mart. Such progress can serve as an example to the Inter-District’s partnership

with Davis Rubber Company. Davis Rubber, as the primary processor in the area, has the ability

to create crumb rubber, which could continue be purchased by the Inter-District for park and

field projects until the market develops. Kentucky, like the Pulaski Inter District, also provides

funds to transport waste tires as part of its amnesty program.

The State of Alabama encourages the use of waste tire materials for playground and

sports field applications, flooring and construction materials, rubber modified asphalt, rubber

mulch and in civil engineering applications. The ADEM Scrap Tire Marketing Program funds

these projects. The Inter-District may consider funding similar efforts, though on a smaller scale.

Since 2004, Kentucky has

awarded more than three

hundred grants totaling

$7 million, primarily to

schools and municipalities,

for crumb rubber uses.

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Long-Term

Waste Tires and Asphalt

To advance along the continuum to

the next idealized step – rubberized asphalt

– the District needs partners and advocates.

A good place to start is with the state’s

county judges. These elected officials have

the most to benefit-- a portion of their

budgets are used to pave and repave roads.

Rubberized asphalt, after initial investments,

can reduce those costs over time. The

asphalt lasts longer, reduces noise, and

makes the roads safer. Furthermore, the county judges constitute a very powerful group to

convince AHTD and the state’s asphalt and concrete producers to reexamine the product.

There are a number of studies that supports such efforts. Clemson University’s

Department of Civil Engineering is home to the Asphalt Rubber Technology Service (ARTS). This

service provides quantitative data on the benefits of rubberized asphalt. Such data will provide

an ideal starting point in the pursuit of such change. Other advocacy groups, such as the

Rubberized Asphalt Foundation (RAF) and the Rubber Pavements Association (RPA) offer white

papers and reference libraries on the subject.

Legislative Activity

Increasing the funding cap will be very difficult, especially in the current political

environment. Rather than looking for additional direct revenue through legislation, the District

should lobby for ways to obtain indirect revenue; or put another way, funds from sources other

than disposal fees. This may include increased authority to levy fines or changes to funding

structures and formulas.

Changes to legislation are inherently difficult. If the Inter-District intends to pursue this

route, it should begin its efforts immediately. The Arkansas General Assembly meets in regular

session only once every two years. The next general session begins in January 2015.

(Legislation that addresses the concerns in this report is highly unlikely to be considered during

a special or fiscal session.) Between regular sessions the District will, at a minimum, need to

outline its legislative goals, develop alliances with like-minded advocates, and begin lobbying

efforts.

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Conclusions

Pulaski County’s administration of the Inter-

District Waste Tire Program encompasses many of

the best practices used in other states. The

accomplishments under its current leadership

surpass many surrounding districts and states. Its

partnership with Davis Rubber Company in Little

Rock is a good example of a promising public-private

enterprise – one that moves an effort from a purely

government-subsidized activity to a market-driven

operation.

The Inter-District requires time, community effort, and clear leadership from the

Oversight Group in order to advance along the continuum. Communication and dedication to

the issues that present themselves to each district are improving from the time of the inception

of this program; accomplishments over the previous decade are indicative of this. Continued

communication and cooperation on all levels will sustain this program and move it beyond the

present day issues. Developing the capacity to be the premier provider of tire recycling services

in the state is not an easy process, but transforming tires into materials for sustainable products

can be achieved with innovative tools and technologies.

Commitment to developing new and better ways to communicate to the public by using

a variety of means is essential to success. The Inter-District is a leader in many aspects of the

Waste Tire Management Program, and the challenge is to continue to be innovative and more

importantly, proactive. Some of the suggested steps for improvement are not easy, and some

can be achieved fairly quickly. There seems to be a considerable amount of revenue lost in the

lack of regulation of used tires and accurate manifests. Uniformity in reporting and local or state

legislation would be of great benefit, and it would add to the revenue stream.

These recommendations are based on sound research and hours of interviews and

investigation. Most importantly, they are achievable. The report does not recommend asking

for more funds or altering significantly the rules and regulations. These recommendations are

designed to be achievable with existing resources and under current legislation (except where

legislative activity is specifically recommended).

The Inter-District is a leader

in many aspects of the

Waste Tire Management

Program, and the challenge

is to continue to be

innovative and more

importantly, proactive.

29

Some of these recommendations are stand-alone; some complementary. The Oversight

Group should view them as a package, and pursue activities described here as resources allow.

The waste tire industry continues to evolve. New technologies and new markets will create

opportunities for advancement along the continuum. The recommendations provided above

will position the Inter-District Waste Tire Management Program to take advantage of those

opportunities.

30

31

Bibliography

Alabama Department of Environmental Management. (2008, January). Scrap Tire Program -

Scrap Tires and Landfills. Retrieved from ADEM:

http://www.adem.state.al.us/programs/land/landforms/STLfills.pdf

Alabama Department of Environmental Management. (2012). Alabama Scrap Tire Program

Biennial Report 2010-2012. Montgomery, AL: Alabama Department of Environmental

Management.

Alabama Department of Environmental Management. (2014). Alabama Scrap Tire Processor List.

Retrieved from ADEM:

http://www.adem.state.al.us/programs/land/landforms/ScrapTireProcessors2613.pdf

Alabama Department of Environmental Management. (2014). Scrap Tire Program. Retrieved from

ADEM: http://www.adem.state.al.us/programs/land/scrapTire.cnt

Alabama Department of Environmental Quality. (2011). Status Report on Solid Waste

Management Facilities and Activities. Alabama Department of Environmental Quality.

Alabama Department of Revenue. (2014). Scrap Tire Environmental Fee. Retrieved from Alabama

Department of Revenue: http://revenue.alabama.gov/motorfuels/scraptire.cfm

Arkansas Department of Environmental Quality. (2012). Timeline of Historical Events of Arkansas

Solid Waste Mangement, 1971-2011. Little Rock, AR: Arkansas Department of

Environmental Quality.

Arkansas Department of Environmental Quality. (2012). Waste Tire Disposition Report. Little Rock,

AR: Arkansas Department of Environmental Quality.

Arkansas Department of Environmental Quality. (2014). Arkansas Waste Tire Program. Retrieved

from Arkansas Department of Environmental Quality:

http://www.adeq.state.ar.us/solwaste/branch_programs/tire_mgt.htm

Arkansas Department of Environmental Quality. (2014). Regional Waste Tire Management

Districts. Retrieved from Arkansas Department of Environmental Quality:

http://www.adeq.state.ar.us/solwaste/branch_programs/tire_districts.aspx

Arkansas Pollution Control and Ecology Commission. (2007, March). Regulation No. 22, Solid

Waste Management Rules. Little Rock, AR.

Arkansas Pullution Control and Ecology Commission. (2012, July). Regulation No. 14, Regulations

and Administrative Procedures for the Waste Tire Program. Little Rock, AR.

32

Environmental Law Alliance Worldwide. (2012). Health Impacts of Open Burning of Used (Scrap)

Tires and Potential Solutions (Science Memo). Retrieved from ELAW:

https://www.elaw.org/node/2764

Inter-District Waste Tire Management Program. (2013, May). Waste Tire Management Plan. Little

Rock, AR.

Kentucky Department of Environmental Protection. (2014). Crumb Rubber. Retrieved from

Energy and Environmental Cabinet:

http://waste.ky.gov/RLA/Waste%20Tires/Pages/CrumbRubber.aspx

Kentucky Department of Environmental Protection. (2014). Waste Tire Program. Retrieved from

Energy and Environment Cabinet:

http://waste.ky.gov/RLA/Waste%20Tires/Pages/default.aspx

Kentucky Department of Environmental Protection. (2014). Waste Tire Work Group. Retrieved

from Energy and Environmental Cabinet:

http://waste.ky.gov/RLA/Waste%20Tires/Pages/WasteTireWorkGroup.aspx

Kentucky Department of Environmental Protection, Division of Waste Management. (2013).

Waste Tire Program: A Report to the General Assembly.

Kentucky Energy and Environmental Cabinet. (2012). Fact Sheet: Waste Tire Management.

Retrieved from http://waste.ky.gov

Mississippi Department of Environmental Quality. (1998). Waste Tire Management Regulation.

Jackson, MS: Mississippi Department of Environmental Quality.

Mississippi Department of Environmental Quality. (2002). Guidance for Implementation of a Local

Government Waste Tire Collection Program. Jackson, MS: Mississippi Department of

Environmental Quality.

Mississippi Department of Environmental Quality. (2014). Waste Tire Management Program.

Retrieved from Mississippi Department of Environmental Quality:

http://www.deq.state.ms.us/Mdeq.nsf/page/SW_Waste_Tire_Program_Information_And_A

pplication_Forms?OpenDocument

Nelson, E. (2014). Using Access or Excel to Manage Your Data. Retrieved from Microsoft

Office.com: http://office.microsoft.com/en-us/access-help/using-access-or-excel-to-

manage-your-data-HA001042918.aspx

Rubber Manufacturers Association. (1998, November). Scrap Tire Management Council Briefing

Sheet. Rubber Manufacturers Association. Washington, D.C.

33

Rubber Manufacturers Association. (2014). About RMA. Retrieved from Rubber Manufacturers

Association: www.rma.org

Tennessee Department of Environment and Conservation. (2014). Waste Tire Program Transition.

Retrieved from Department of Environment and Conservation:

http://www.tn.gov/environment/solid-waste/solid-waste_tires.shtml

Tennessee Department of Environment and Conservation. (2014). Waste Tire Task Force.

Retrieved from Department of Environment and Conservation:

http://www.tn.gov/environment/solid-waste/solid-waste_tires-task-force.shtml

Tennessee Department of Environment and Conservation. (2014). Waste Tires in Tennessee.

Retrieved from Department of Environment and Conservation:

http://www.tn.gov/environment/solid-waste/solid-waste_tires.shtml

United States Environmental Protection Agency. (2010). Scrap Tires: Handbook on Recycling

Applications and Management for the US and Mexico. Washington, D.C.: U.S.

Environmental Protection Agency.

United States Environmental Protection Agency. (2014). Laws/Statutes. Retrieved from U.S.

Environmental Protection Agency:

http://www.epa.gov/epawaste/conserve/materials/tires/laws.htm

United States Environmental Protection Agency. (2014). Region 4: Land Cleanup and Wastes.

Retrieved from U.S. Environmental Protection Agency:

http://www.epa.gov/region4/rcra/scrapstate_links.htm

United States Environmental Protection Agency. (2014). Where You Live. Retrieved from U.S.

Environmental Protection Agency:

http://www.epa.gov/waste/conserve/materials/tires/live.htm

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