Survey of AGC Members on Proposed Rule to Regulate Fly Ash and Other Coal Combustion Residuals

Assuming that EPA designates CCRs as a “special” waste that will be regulated under Subtitle C (for hazardous wastes) but such designation is not applicable to fly ash used in certain beneficial uses—such as mixed in concrete—please respond to the following questions by August 16, 2010:

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* 1. What type of construction does your firm primarily perform?

Highway

Building

Utility

Heavy

Specialty Contractor

Supplier

Service Provider

Other (please specify)

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* 2. Will you continue to use fly ash or materials that contain fly ash?

Yes

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* 3. Do you see any "stigma" that might be associated with materials containing fly ash from the general public or users of those materials?

Yes

Please explain

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* 4. Do you see any potential liability to you as a supplier and/or user of materials containing fly ash?

Yes

Please explain (include backup data and analysis if available)

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* 5. Are there options or methods that EPA could take to reduce any impact of a "stigma" associated with materials containing fly ash?

Yes

Please explain

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* 6. Do you envision any implications for the handling, storage and use of fly ash to incorporate into building materials or already contained in those materials?

Yes

Please explain

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* 7. Do you envision any implications for the disposal of fly ash containing materials that were returned from a project and disposed of?

Yes

Please explain

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* 8. Do you envision any implications for the ultimate disposal of fly ash containing materials after the demolition of structures at the end of service life?

Yes

Please explain

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* 9. Are there any actual instances where "stigma" has adversely affected the beneficial use of CCRs?

Yes

Please explain