M. Blastow, D. Marsh
National Precast Concrete Association Director of Technical Services Claude Goguen offered results of a July-August survey of the group's 900 member companies. Over 50 percent use SCMs, chiefly fly ash. Largely confirming trends suggested by NRMCA survey data, NPCA producer respondents indicated:
- 84 percent would continue fly ash use even under Subtitle C listing for CCR for reasons of job specifications and cost savings.
- 64 percent perceived potential liability in using fly ash for precast production if CCR carries a Îhazardous materialÌ designation. Some commented that liability, however, would fall heavier on specifiers and project owners.
- 52 percent anticipated implications of Subtitle C designation for handling of fly ash at the plant. Cited as possible consequences were higher insurance costs, plus spill containment and cleanup measures, spurred by OSHA requirements.
- 67 percent thought hazardous waste designation could stigmatize fly ash-containing precast products and jeopardize their use in specifications. Respondents questioned whether specifying engineers and architects would take note of distinctions within the rule, i.e., beneficial use of fly ash is not subject to hazardous waste regulation, and if state- and federally funded projects would continue to use fly ash in their specifications.
- 80 percent thought EPA could reduce the impact of stigma associated with a fly ash hazardous waste designation, e.g., by mandating a percentage of use on federally funded projects, plus education via thoroughly informed agents.