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American Coal Ash Association Executive Director Thomas Adams affirms Ward's observation that political science holds greater sway in the RCRA hazardous

CP STAFF

American Coal Ash Association Executive Director Thomas Adams affirms Ward's observation that political science holds greater sway in the RCRA Îhazardous wasteÌ designation controversy than hard science. Nonetheless, he marshals facts to undermine even the staunchest anti-coal environmentalist stance: In 2008, utilities generated 136 million tons of coal combustion products (CCP), second only to municipal solid refuse among the largest U.S. waste streams. That year, 60 million tons or 44 percent of CCPs were recycled Û an increase of nearly 50 percent from the year 2000 recycling rate of 30 percent. From 2000 to 2008, over 117 million tons of greenhouse gas emissions have been curtailed by the use of fly ash in concrete; in 2008 alone, fly ash in concrete accounted for about a 12 million-ton GHG reduction.

Valuable as a supplementary cementitious material (SCM) for concrete mixes and raw feed for cement production, fly ash is one among several by-products comprising the CCP family. Bottom ash is used as an aggregate in some masonry products and a structural fill material for geotechnical projects. Boiler slag serves as blasting grit and a component of shingles in almost 80 percent of residential roofs nationwide, as well as a traction-control product where rock-salt costs are prohibitive. Flue-gas desulfurization (FGD) gypsum, a synthetic gypsum purer than the naturally mined mineral and a by-product of power-plant stack scrubbers, is used for 35 percent of wallboard manufactured in the U.S., plus agricultural soil-amendment applications.

While EPA publicly advocates CCP recycling through beneficial use, its statements Û particularly in support of fly ash for concrete and cement production and FGD gypsum in wallboard manufacture Û are refuted by recent actions, Adams emphasizes. After the creation in 2003 of the Coal Combustion Products Partnership (C2P2) to promote CCP recycling, the multi-agency alliance was suspended by EPA earlier this year on grounds of neutrality while the Identification and Listing rule is in progress. Moreover, in July, the agency unilaterally disabled the C2P2 website, eliminating a prime educational tool in CCP beneficial use.

In response to the threat of RCRA Subtitle C listing, warnings have sounded from multiple quarters of the industry, Adams reports. ASTM C 09 informed EPA in December 2009 that a hazardous waste advisory would be added to the C618 standard and likely prove detrimental to fly ash use in concrete. The ACI 318 committee may consider removal of fly ash from the Building Code, whose primary function is to protect public safety and, therefore, by definition, cannot include a hazardous substance. AASHTO's Materials Committee emphasizes the prospective loss of fly ash's performance-enhancing benefits, especially improved durability and ASR resistance. In addition, utility companies indicate that they may not allow CCP release to markets, since disposal costs are recoverable in the rate structure, whereas fees for defense against creative litigation, including tort activity and class action suits, are not.

Today, the stigma of a hazardous waste designation is not merely hypothetical. In at least three industries, advertising campaigns for competitive, non-CCP-containing brands already have trumpeted: Our products don't contain hazardous wastes. Do yours? EPA's contention that the marketplace will not be affected is clearly wrong, and they haven't even come to a final rule yet, Adams asserts.