The American Concrete Association (ACI) is conducting a survey among interested parties so that it can comment to the EPA on its proposal to regulate coal combustion residuals (CCR's), including fly ash, under the Resource Conservation and Recovery Act (RCRA).
Ron Burg, Executive Vice President of ACI, issued a memo to interested parties on August 18, seeking participation in a survey ACI is conducting. He points out that EPA has provided two "co-proposals," one of which would treat CCR's like municipal wastes and one of which would treat them as hazardous wastes. While disposal of CCR's is most at issue, there is concern, both in ACI and among protective coatings industry persons, about the impact of the new rule on beneficial use of certain CCR materials.
In addition to conducting the survey, ACI also is eliciting comments directly to EPA, which ACI is facilitating through its website www.flyash.concrete.org.
For a description of the proposed rule and its potential impact on protective coatings, see the article, "Why EPA's Proposed Rule on Coal Wastes Could Affect Industrial Paint Work," by Alison B. Kaelin in JPCL, August 2010