Environmental - Fly Ash - Hurting Titan America Concrete Companies while Damaging the Environment

Titan America’s position is to oppose any hazardous waste classification for coal combustion residuals (CCR) such as Fly Ash

Background: In December 2008, 1 billion gallons of fly ash sludge spilled into the Emory River and other waterways from a retention pond located at the Tennessee Valley Authority power plant in Kingston, TN. The spill gained the attention of the Environmental Protection Agency (EPA) and spurred EPA to examine new regulations for the disposal of CCRs, including labeling fly ash as a hazardous waste material. On June 21st, 2010 EPA published its proposed rule aimed at better handling and containing Fly Ash when destined for disposal. The proposed rule suggested two different options to achieve this goal:

1. The first option, known as a Subtitle C classification, would regulate Fly Ash as hazardous waste effectively giving the federal government control and enforcement over their disposal in special hazardous waste landfills.
2. The second option, known as a Subtitle D classification, would set more stringent minimum standards for the way CCR’s are currently disposed. The enforcement however, would be left up to the states, and civil suits filed by individuals and/or groups.

How does Fly Ash Affect Titan America? In 2008 alone, the US concrete industry used 15.8 million tons of fly ash in the manufacturing of ready mixed concrete; making it the most widely used supplemental cementing material (SCM). The Total amount of Fly Ash produced in a year equals approximately 60 million tons. The difference – 45 million tons – goes to landfills all over America. This amount going to the landfills is bad enough, but without Fly Ash usage by concrete companies, it would be 25% worse. Additionally, Titan America’s concrete operations use Fly Ash to enhance the quality of the concrete we supply. Fly Ash reduces our production costs by replacing 20+% of the cement for a mix. By using less cement, we reduce the CO2 emissions of our cement plants in Virginia and Florida. Remember Titan America is in the Fly Ash business at Separation Technologies.

How is Fly Ash beneficial to the environment and industry? Fly ash works in combination with Portland cement to impart beneficial qualities to concrete and is then encapsulated itself. Supplementary materials, such as fly ash, contribute both to concrete’s exceptional performance and sustainability. When combined with cement in concrete Fly Ash improves durability, strength, constructability and economy.

 In the case of highways, streets, parking areas, and ocean-side structures, durability is the number one concern. Fly ash is used to enhance the durability of concrete by decreasing permeability and cracking. Fly Ash helps block migration of chloride ions (from deicing chemicals or seawater) to reinforcing steel, the most common cause of corrosion.

 In the case of buildings, Fly Ash helps to create high strength concrete used to build some of the tallest buildings in the world. For homes, fly ash concrete provides an economical and durable alternative for foundations, patios and driveways. The environmental benefits of using these industrial byproducts in concrete results in longer lasting structures and reductions in the amount of waste materials sent to landfills, raw materials extracted, energy required for production, and air emissions, including carbon dioxide.

EPA’s primary goals should be to reduce the amount of fly ash wasted and to ensure that whatever fly ash is wasted is managed properly. A hazardous waste designation, such as Subtitle C, would undermine the primary goal. Some states forbid the beneficial reuse of hazardous wastes, which could create a “Catch 22” situation that prevents shedding the hazardous waste designation through reuse.

How does Option C hurt Titan America? The adverse impact of a Subtitle C classification on the U.S. economy could be enormous. Concrete is used for nearly all forms of construction, including homes, buildings, highways, airports, domestic water systems, local roads, dams, and power generation structures. Inappropriate regulation of fly ash would render the product difficult to manage, transport and store, even for environmentally beneficial purposes, thus rendering the use of fly ash too expensive and risky to justify. It would also be devastating on the concrete industry and Titan America’s Concrete Operations. The industry supplements nearly 20% of the cementing materials in concrete with fly ash. Eliminating the availability of fly ash in any way would result in cost increases that could render concrete non-competitive resulting in loss jobs and closed plants.

The use of fly ash in concrete is safe. Once chemically bound in concrete, fly ash does not pose any environmental or health threat. Any ruling that would designate fly ash as hazardous in any form would result in a public perception that fly ash concrete is hazardous. This would result in project owners refusing to accept concrete with fly ash in the mixture. It would in effect kill the demand for fly ash in concrete. Fly ash that was once used in a beneficial way would end up in landfills.

Although both proposed classifications maintain an exemption for Fly Ash destined for beneficial use, such as an ingredient in ready mixed concrete, Titan America is still evaluating the impacts both options on the industry. Preliminary assessments of the rule’s effect on the industry have suggested higher priced fly ash regardless of the classification, and possibly worse; restricting or ending the use of fly ash in concrete in certain municipalities and types of projects altogether. Given the breadth, the complexity of the dual proposal and the potential impacts on the industry, Titan and our industry along with other CCR stakeholders has requested a 120-day extension to the current 90-day comment period to wholly assess these issues.

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General Information:
To view EPA’s proposed rule please click here.
For more information on EPA’s proposal, including Public Listening Sessions please click here.

Industry Action:.
To learn more about industry opposition, other activated organizations, or to become involved please view these links:

American Coal Ash Association: http://www.acaa-usa.org/

Citizens for Recycling First: http://www.recyclingfirst.org/index.php

Regulate Coal Ash Right: http://www.regulatecoalashright.com/Pages/default.aspx

Coal Ash Facts: http://www.coalashfacts.org/

Utility Solid Waste Activities Group: http://www.uswag.org/

TVA Studies:
To view the Tennessee Department of Health’s “Public Health Assessment” please click here.
To view the “Baseline Medical Screening Results” by Oak Ridge Associated Universities please click here.

House Small Business Committee Hearing:

To view NRMCA Small Business Subcommittee Testimony on Fly Ash, July 22, 2010 please click here.
To view EPA’s Small Business Subcommittee Testimony on Fly Ash, July 22, 2010 please click here.
 To view EPA’s testimony question answers please click here.