The cloud of proposed Environmental Protection Agency regulations governing the handling and disposal of coal combustion residuals (CCR), including construction-grade fly ash, prompted an American Road & Transportation Builders Association Transportation Development Foundation (ARTBA-TDF) report to forecast potential economic impacts on the subtraction of ASTM C 618 product from the transportation infrastructure supply chain.
In “The Economic Impacts of Prohibiting Coal Fly Ash Use in Transportation Infrastructure Construction,” (see sidebar) ARTBA Senior Economist Alison Premo Black estimates that the loss of fly ash as a supplementary binding agent would increase the cost of road and runway pavements, plus bridges, by $104.6 billion over the next 20 years. The excess $5.23 billion annual direct cost she calculates includes a $2.5 billion increase in the price of materials and an additional $2.73 billion in pavement and bridge repair work due to the shorter pavement and service life of other portland cement blends. “Without the availability of fly ash, American taxpayers would ultimately bear the burden, either paying more for the same level of transportation improvements, or dealing with the consequences of a scaled back improvement program,” says Black.
“The study’s findings should be a real eye-opener for members of Congress and other federal policymakers,” adds Bill Gehrmann, president of Headwaters Resources, Inc., whose group commissioned the report. “Without coal ash, concrete will become more expensive, and the environmental footprint of the transportation sector will only increase. There is nothing ‘green’ or sustainable in such a scenario.”
The EPA continues to review comments to a rule formally proposed in June 2010 that would subject CCR to one of two Resource Conservation & Recovery Act classifications. The more stringent proposal would see any disposal facility-bound CCR—construction- or nonconstruction-grade—labeled a “hazardous waste.” Federal and state transportation officials, along with major groups representing concrete and cement producers, have cited prospects for greatly diminished use of ASTM C 618 product as a supplementary cementitious material should any CCR be labeled hazardous waste. Industry and agency stakeholders await a modified EPA proposal or final rule modeled on the June 2010 document.