At 8:00 a.m., on a warm July morning in the far West Texas town of Clint, a line of cars stretched outside the entrance of an El Paso County Water Improvement District No. 1 collection center. Dozens of EPCWID, Texas Commission on Environmental Quality, Keep El Paso Beautiful, and Road Master Service personnel, armed in heavy gloves, or sitting atop forklifts, prepared themselves for the massive task—receiving and properly disposing of thousands of scrap tires in less than eight hours.
The accumulation of abandoned tires has been an ongoing concern in the El Paso area. Not only are these illegal dumps an eyesore and prone to harboring mosquitoes and rodents, but they’re also affecting local water usage.
Intertwined throughout the 248 square miles of the fourth largest city in Texas are close to 700 active irrigation and drainage canals, which have become prime spots for illegal tire disposal.
For local irrigation districts, staying ahead of the flow of tires has been an almost constant battle—with limited resources to almost constantly monitor the sites, let alone clean up these areas. That is why the TCEQ has partnered with these districts, the city and county of El Paso, county judges, and area law enforcement to help curb the scrap-tire problem.
As part of this effort, the TCEQ’s Small Business and Environmental Assistance Division organized an education initiative earlier this year, aimed at local businesses that deal in tires. Letters were addressed to these facilities and stores, reminding them of scrap-tire rules, and offering to provide assistance.
The TCEQ also partnered with the Texas Irrigation Council to develop strategies to address illegal tire dumping on district property. Irrigation districts and the agency worked together to conduct outreach to tire generators to ensure that they knew their responsibilities under the law. Additionally, district input will help focus investigations to discourage illegal dumping.
“This was an innovative approach, to work cooperatively to address the problem,” said TCEQ Small Business and Environmental Assistance Director Brian Christian. “The districts want to responsibly address this issue, and this approach helps them to do that.”
More than 8,000 scrap tires were received during the collection event held last summer outside of El Paso.
Elsewhere around the state, SBEA also conducted a used-tire workshop in Harlingen to help businesses understand what is required to properly manage and dispose of tires. The TCEQ teamed up with the Harlingen Irrigation District, Cameron County, and the city of Harlingen to sponsor a free, one-day workshop on regulations and issues for “good used” and scrap tires to deter illegal dumping. Approximately 50 participants also learned how to report violators, and ascertained who has the authority to fully enforce the law.
“We applaud the district’s efforts to address this challenge, and we look forward to continued partnerships with them to find ways to address this issue,” said TCEQ Border and South Central Texas Area Director, Ramiro Garcia.
The TCEQ oversees the collection, processing, storage, and recycling or disposal of scrap tires in the state. Scrap-tire transporters, processing facilities, storage sites, and end-use or disposal facilities must make an annual report to the TCEQ, showing the number of scrap tires they handled, and the form of the tire (whole or cut, bales or shreds). The agency can initiate enforcement if an annual report has not been filled out, or if the information is improperly reported.
El Paso is hardly alone when it comes to illegal scrap-tire dumping. It’s estimated that over 24 million tires are discarded each year in Texas. There are an estimated 14.2 million tires in known sites, throughout the state, that need cleanup. By law, scrap tires must be hauled by a registered transporter to an authorized facility. All facilities must maintain manifests showing the disposition of the scrap tires. Additionally, all transporters and authorized facilities must annually provide a report to the TCEQ summarizing their tire-management activities.
In 2010, out of the 24 million scrap-tire units (STUs) generated in Texas, 52 percent were processed into tire-derived fuel; 26 percent were used in land reclamation; 17 percent were converted into other beneficial forms, such as crumb rubber and tire-derived aggregate; while only 5 percent ended up in a landfill.
The TCEQ’s Border Initiative, created in 2008, has made scrap-tire management on the Texas-Mexico border one of its major priorities. Recently, the TCEQ partnered with EPA Region 6 and the environmental agency for the state of Nuevo León to conduct a binational workshop on municipal scrap-tire management. In attendance were officials from the Mexican federal environmental agency, the acting deputy regional administrator for EPA Region 6, leaders of scrap-tire programs from New Mexico and Texas, academics from both sides of the border, and representatives from six Texas cities and counties and seven Mexican cities (see sidebar).
“When we share our experiences, we learn best how to deal with the issues we face in each country, to effectively manage scrap tires,” said TCEQ Border Affairs Manager Steve Niemeyer.
According to TCEQ Environmental Crimes Unit (ECU) investigators, the fact that dumping tires is against the law doesn’t stop violators from discarding them in the city’s and county’s waterways. The agency has stepped up its efforts with a dedicated investigator in the El Paso region, who conducts reconnaissance missions along the canals, and drives along these areas, in an effort to deter dumpers. The investigator screens complaints received by the regional office to determine which of the complaints could possibly lead to criminal enforcement. This includes not only the illegal dumping of tires, but also the illegal dumping of municipal solid waste and other unauthorized discharges.
Over the last few years, several illegal-dumping investigations conducted by the TCEQ have been prosecuted through the El Paso County Attorney’s office. Fines for violations have ranged from $750 to $4,000, and most penalties have also included cleanup of the sites, community service, and probation for the offender.
The effort has recently been taken to the television airwaves. Earlier this year, the TCEQ partnered with the El Paso Police Department to produce a Crime Stoppers segment on one particular illegal tire dumpsite, located in the desert outside of the city—where more than 1,000 discarded tires were found. (See video link above.)
“The El Paso region is an expansive area to cover and actions have been taken to be more proactive in catching offenders in the act of illegal dumping, including the dumping of tires in the irrigation systems,” said ECU Manager Dan McReynolds. “The Environmental Crimes Unit is working with local government to address this egregious dumping, but asks that the community step up and notify local law enforcement if they witness any suspicious activity relating to the illegal dumping of any solid waste.”
On that particular morning in July, in the far West Texas town of Clint, hundreds of vehicles dropped off 8,027 tires at the Clint collection facility—far exceeding the organizers’ expectations. The free event, which was supposed to conclude at 4:00 p.m., had to be shut down two hours sooner, when the intake surpassed the truck space in the six tractor-trailer rigs that had been brought in to haul away the collected tires.
“We saw an amazing response from the community looking for an appropriate disposal option for scrap tires,” said TCEQ El Paso Regional Director Lorinda Gardner. “These events are just one more tool in our compliance tool box—preventing tire dumping into all areas of the desert, but particularly the irrigation canals.”
A second event is planned for next spring.
How to Report Illegal Tire Dumping
Pay attention to your surroundings and be careful. If you see something unusual happening, react but don’t confront anyone or place yourself in danger.
Use your cell phone to take a picture or video.
Get a description. Write down a description of the vehicle, including the license plate number, if possible. Write down a description of the person or persons doing the illegal dumping. Don’t depend on your memory. Report the incident to local law enforcement, or to your nearest TCEQ regional office.
Binational Technical Exchange Key to TCEQ Border Initiative
On July 27 and 28, 2011, the TCEQ hosted a binational “technical exchange” between officials from the Mexican state of Nuevo León and experts from Texas on the potential use of selected waste streams in road building. Items like scrap tires, recycled plastics, fly ash, and recycled concrete and asphalt dominated the conversation as the group traveled between universities, state agencies, and research laboratories.
This event was the third activity under the Action Plan for the Texas–Nuevo León Memorandum of Cooperation (MOC). The MOC was signed in 2010 by Commissioner Buddy Garcia of the TCEQ and Secretary Fernando Gutiérrez of the Secretariat of Sustainable Development of Nuevo León (SDS).
In addition to environmental quality, SDS oversees paving and roadway construction in the state of Nuevo León. The group of experts from Mexico included the technical secretary of SDS, the lead paving engineer of SDS, the regional technology director of Mexico’s federal transportation agency, and a civil-engineering professor from the Autonomous University of Nuevo León. Together with an interpreter, TCEQ management, and staff from UT-Austin’s LBJ School of Public Affairs, the group visited the Texas Transportation Institute at Texas A&M University in College Station, TxDOT research laboratories in Cedar Park, and research facilities at the University of Texas at Austin.
During the two-day event, distinguished research professors and government experts gave presentations on a variety of topics, including rubber-chip seal, the pros and cons of rubberized asphalt (roadway surface durability and safety benefits), adding recycled materials to concrete mixes, using geosynthetics in roadway construction, and using scrap-tire bales for slope stabilization. The technical exchange went both ways as the engineers from Nuevo León shared their experiences and discussed what lies ahead for them. Nuevo León faces the challenge of re-building numerous roads destroyed by the historic flooding after Hurricane Alex in the summer of 2010. The Mexican state recently passed progressive pavement legislation and is embarking on a significant rebuilding campaign. Sustainability and repurposing selected waste streams are a big part of this effort.
Texas and Nuevo León have worked together over the past 14 years on several environmental issues that affect the border region, including the use of ultra-low-sulfur diesel fuel for commercial trucks, the sharing of air-quality data to improve modeling, scrap-tire management, and educational campaigns to promote recycling. This binational cooperation was recently recognized by the Woodrow Wilson Center’s Awards for U.S.-Mexico Cross-Border Cooperation and Innovation.