r/EPA
  United States
  Environmental Protection
  Agency
   Methodology for Evaluating Beneficial
   Uses of Industrial Non-Hazardous
   Secondary Materials
   Office of Resource Conservation and Recovery
   Office of Solid Waste and Emergency Response
   Washington, DC 20460
EPA530-R-16-011
   April 2016

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials


Disclaimer:
This document describes a methodology developed for evaluating the beneficial use of industrial
non-hazardous secondary materials ("secondary materials") by the United States  Environmental
Protection Agency ("EPA" or "the Agency") Office of Land and Emergency Management. The
methodology is intended to be useful to those conducting or reviewing beneficial  use evaluations
and other interested stakeholders, including states, local governments, tribal authorities, regulated
communities, and the general  public. The methodology  is based on the Agency's current
understanding of the range  of  issues and circumstances involved "with  the beneficial use of
secondary materials.  It is not intended to address the combustion of non-hazardous secondary
materials for energy or use/reuse of municipal solid "waste. Use of this methodology is voluntary,
and the methodology does not change or substitute for any federal or state statutory or regulatory
provisions or requirements. This document does not preclude  the use of any  other available
approaches. Nothing  in this document is intended to establish binding requirements on EPA or
any other entity. Accordingly, EPA may revise or depart from this methodology at any  time,
without prior notice.

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials

Table of Contents
Introduction	Error! Bookmark not defined.
Phase I - Planning and Scoping	4
Phase II - Impact Analysis	5
  Step 1 - Existing Evaluations	5
  Step 2 - Comparison with Analogous Product	6
  Step 4- Screening Analysis	7
  Step 5 - Risk Modeling	9
Phase III - Final Characterization	9
Further Information	10
References	11

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
Introduction
Industrial non-hazardous secondary materials ("secondary materials") are any materials that are
not the primary products from manufacturing and other industrial sectors. Examples can include
scrap and residuals from production processes and products that have been recovered at the end of
their useful life. Virtually all industrial sectors generate some form of secondary material during
the course of normal operations. Some of these secondary  materials can be generated in large
quantities. For example:
 •  Steam electric utilities generated nearly 130  million tons of coal combustion residuals
    during the 2014 calendar year (ACAA, 2014).
 •  The metal casting sector generates approximately 9.4 million tons of spent foundry
    sands each year (AFS, 2007).
 •  The construction and demolition sector generated approximately 530 million tons of
    building-related construction and demolition materials in 2013 (U.S. EPA, 2015).
Once generated, secondary materials are often sent  directly for disposal, but some have the
potential to be beneficially used instead. Beneficial use involves the substitution of these secondary
materials, either as generated or following additional processing, for some or all of the virgin, raw
materials in a natural or commercial product (an "analogous product") in a "way that provides a
functional benefit, meets product specifications, and does not pose concerns to human health or
the environment. State, tribal and territorial regulatory bodies make the determinations "whether
to allow a given beneficial use  under a "wide variety of programs. A survey of beneficial use
programs in the United States conducted by the Association of State and Territorial Solid Waste
Management Officials in 2006 found that, although the number of requests for determinations is
increasing, "insufficient information to determine human or  ecological impacts of use rather than
disposal" has been a major barrier for states "when reviewing proposed beneficial uses (ASTSWMO,
2007). The United States  Environmental Protection Agency ("EPA" or "the Agency") Office of
Land and Emergency Management developed this document to help address this barrier.

This methodology can be used to determine "whether the potential for adverse impacts to human
health and the environment from a proposed beneficial use is comparable to or lower than from
an analogous product, or at or below relevant health-based and regulatory benchmarks. Use of this
methodology is voluntary and does not change or substitute  for existing laws, regulations, or any
beneficial use determinations that govern the management of individual "wastes on either a federal
or state level. EPA encourages those individuals or entities "who use the methodology to consult
"with relevant regulatory bodies to ensure that the application of this methodology is scientifically
sound and accounts for any additional considerations required by these regulatory bodies. While
protection of human health and the environment  is a critical component of beneficial use
determinations, EPA recognizes that  additional considerations  (e.g., existing state  and federal

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
requirements,  public  opinion,  the existence  of  a market)  may also factor into the  final
determination for a particular use.

This document builds on the steps first outlined in the Methodology for Evaluating Encapsulated
Beneficial Uses of Coal Combustion Residuals (U.S. EPA, 2013a), "which underwent independent
external peer review documented in Responses to External Peer Review Comments: Methodology
for Evaluating Encapsulated Beneficial Uses of Coal Combustion Residuals (US EPA, 2013b) and
"was applied in Coal Combustion Residual Beneficial Use Evaluation: Fly Ash Concrete and FGD
Gypsum Wallboard (U.S. EPA, 2014). The updated methodology presented in this document is
intended to provide further clarification on the analytical steps and to ensure relevance for the
widest range of secondary materials used in encapsulated and unencapsulated beneficial uses.1 The
updated methodology is divided into three phases: planning and scoping, impact analysis, and final
characterization.  Each beneficial use evaluation conducted using this methodology "will progress
through these three phases, but there is flexibility in how each is applied. This document provides
an introduction to each phase and is intentionally broad in order to present a balanced discussion
of the different aspects of the methodology. A summary flowchart of the three phases is presented
on the following  page in Figure 1. A more detailed discussion of the specific considerations that
may arise in a particular evaluation, as well as a list of existing resources and tools that can assist
"with these evaluations, can be found in the Beneficial Use Compendium: A Collection of Resources
and Tools to Support Beneficial Use Evaluations (U.S. EPA, 2016).

Many  opportunities exist to beneficially use these secondary materials (e.g., coal fly ash as a
replacement for cement in concrete, spent foundry sands as road subbase). Some of the potential
benefits associated  "with the use of secondary materials include  preservation of natural virgin
resources, reduced  air and  water pollution from extraction activities, reduced greenhouse gas
emissions, reduced production costs, and avoided use of landfill space. Because of the potential for
numerous environmental, economic and performance benefits, the appropriate beneficial use of
secondary materials can advance the goals of EPA's Sustainable Materials Management program,
"which emphasizes a materials management approach that aims to reduce impacts to human health
and  the environment associated  "with  materials over their  entire life  cycle  (e.g., extraction,
manufacture, distribution, use, disposal).
1) Encapsulated beneficial uses are those where the secondary material is bound in a solid matrix that minimizes
   mobilization into the surrounding environment. Examples of encapsulated uses include, but are not limited
   to: aggregate in concrete; a replacement for, or raw material used in production of, cementitious components
   in concrete or bricks; filler in plastics, rubber, and similar products; and raw material in the manufacture of a
   product (e.g., wallboard).

   Unencapsulated beneficial  uses are those where  the secondary material is used in a loose or unbound
   particulate or sludge form and involves the direct placement of the secondary material on the land.  Examples
   of these applications include: structural fills; use in agriculture as a soil amendment; and aggregate.

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
               Develop an initial conceptual model that captures the adverse effects to human health and the
             environment that might result from the beneficial use. Identify the questions to be answered by the
               beneficial use evaluation and the information required to answer them. Data that will be used to
             answer these questions can be assembled from the literature or generated for the evaluation. Further
                 data collection can also be conducted in the next phase if it is found that available data are
             	insufficient to support conclusions.	

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Figure 1. Summary Flowchart of the Beneficial Use Methodology

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials

Phase I - Planning and Scoping
This is the initial phase for beneficial use evaluations conducted using this methodology. The
objective is to identify the questions that "will be answered by the evaluation and the information
required to answer  them.  Because of the substantial variability  in  the  secondary materials
generated, the range of potential uses for these materials, and the data available to characterize
each, there is no single structure best suited for every evaluation. Therefore, careful planning is
essential to ensure that the scope of the evaluation is well-defined, realistic, and ultimately forms
a sound basis for the subsequent beneficial use determination.

The scope of the evaluation is primarily defined by how "widespread the intended use "will be and
the composition of beneficial use during the relevant stages of its life cycle. This information places
bounds on the adverse impacts that may occur by  defining the possible chemical constituents and
other stressors  (e.g., particulate matter) released,  environmental media affected, and nearby
receptors exposed. The scope will, in turn, dictate the data needed to answer the questions posed
by the evaluation.

Data can be assembled from the existing sources  or generated for the evaluation. The benefit of
generating new data is that it allows the quality and quantity of data to be tailored to the specific
needs of the evaluation. Yet the planning, sampling and analysis necessary to generate new data
can be a resource-intensive process. Therefore, this option can be reserved until a later stage of the
evaluation, if it is found that existing data are insufficient. Because it can be difficult to know the
exact amount of data required before the analysis  is underway, the collection and analysis of data
is often an iterative process. While the evaluation may not ultimately rely on all the collected data
in the analyses, it is important to provide documentation of all the data sources considered and the
rationale for exclusion of any data.

The ultimate goal  of the evaluation is to  reduce uncertainties enough that well-substantiated
conclusions can be drawn about the beneficial use.  However, some uncertainty  may  remain,
regardless of the amount of data available. There is an opportunity during planning and scoping to
manage uncertainty through the selection of analytical methods that "will either minimize it or
deliberately bias it in a known,  protective direction. The most suitable methods may  not always
be the most sophisticated. The added complexity of some methods might not add value "when less
complex methods are sufficient,  and may actually exacerbate the amount of uncertainty present in
the evaluation. It can be helpful to seek input from experts to help identify and implement the
most suitable methods.

Hypothetical Application of Phase I
A secondary material is proposed for use as subsurface structural fill statewide as generated. One
example of an adverse impact that may occur during use is an increased risk of cancer in receptors
"who ingest the chemical constituents released into  ground "water. Consideration of potential
impacts during storage may also  be "warranted if the beneficial use "will be staged outdoors in a "way
that is exposed to "wind and rain for any considerable time prior to use.

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
In this hypothetical, there are few limitations placed on "where this secondary material could be
used. This makes it difficult to develop representative distributions for distances to residential
"wells, "water bodies, and other receptors that "would be needed for a refined, probabilistic analysis.
As a result, a large-scale evaluation for this use  may be limited in complexity to a screening
analysis. If such a screening shows the potential for concern, then it  may be more practical to
refine the scope of the evaluation to pursue demonstrations on a more  site-specific basis. But the
actual demonstration "whether this beneficial use is appropriate, either as initially proposed or "with
additional conditions, is accomplished in the  next phase of the methodology.

Phase II - Impact Analysis
In the second phase the objective is to answer the questions posed during planning and scoping
through a combination  of quantitative and qualitative  analysis. This phase is presented as  four
distinct steps of increasing  complexity. There is flexibility in how these steps are applied in an
evaluation. Individual steps can be omitted or used in the order that makes the best use of available
data, so long as the analyses conducted are supported by sound science. If at any point during the
analysis sufficient information is  available  to  reach "well-substantiated conclusions about the
beneficial use, then the evaluation can proceed to the third and final phase.

Step 1 - Existing Evaluations
This step consists of a literature review to identify any existing evaluations that are of sufficient
quality to rely upon in the beneficial use evaluation. The purpose of this step is to avoid duplication
of effort by  building on previous "works.  Examples of existing evaluations include  previous
beneficial use evaluations, peer-reviewed studies, or technical reports that have been published by
government agencies, academic institutions, trade association and other sources. Many of these
existing evaluations "will likely be identified  during other data collection efforts in planning and
scoping.

Relying on the findings of other evaluations also incorporates any uncertainties present in those
evaluations. Therefore, it is important to review the quality of data and analyses relied upon to
ensure that the findings are valid and can be  extended to the particular beneficial use  under
evaluation. Specifically, this review determines "whether the findings are applicable to a particular
secondary material and its beneficial use, supported by sound science, adequately capture sources
of variability, subjected to sufficient external review, and transparently documented "with enough
detail and  clarity to allow replication.  If this  review determines an existing  evaluation is of
sufficient quality, its findings may be used  to  draw conclusions about the beneficial use.  The
findings may be  drawn from multiple existing evaluations to address different constituents or
exposure routes. If an existing evaluation supports the conclusion that the potential for adverse
impacts is comparable to or  lower than from  an analogous product, or  at or below relevant
regulatory and health-based benchmarks, then no further evaluation "would be necessary. Potential
adverse impacts that are not sufficiently addressed by these findings "would  "warrant further
consideration through additional steps.

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
Hypothetical Application of Step 1
A secondary material is proposed for beneficial use as generated. During review of the literature,
it is discovered that an international health agency has previously studied the leaching behavior
of three heavy metals from a number of materials, including the secondary material. The study
found that even the highest leachate concentrations observed from the materials did not result in
exposures to contaminated ground or  surface "water above European benchmarks. Thorough
review of the study identifies  no significant data gaps or other concerns and determines that
exposures are also  below all relevant  benchmarks  defined by the  state government  agency
responsible for the beneficial use determination.  Based on these findings, the leaching of these
three constituents "would not warrant further evaluation. However, if there are additional release
routes for these three constituents other than leaching to ground and surface water, or if there are
additional constituents associated "with leachate from the beneficial use beyond these three, then
the additional release routes and constituents "would remain to be addressed in subsequent steps of
the beneficial use evaluation.

Step 2 - Comparison with Analogous Product
This step consists of a comparison between the beneficial use and an analogous product made "with
virgin materials. The objective is  to determine  "whether the potential for  adverse impacts is
comparable to or lower than from an analogous product. This comparison assumes that the  same
receptors will be exposed, regardless of whether the analogous product or beneficial use is present.
It also assumes that  the characteristics, behavior and sensitivity of these receptors do not change.
Thus, any differences in exposure  rates and potential for adverse impacts are driven only by
changes to the stressor levels present in environmental media.

A direct comparison of concentrations at the point of exposure  may involve some amount of fate
and transport modeling if field data are not available. This can greatly increase the complexity of
this step. However,  it is often possible to use a surrogate in place of exposures in this comparison
to reduce the computational burden. For the purposes of this methodology, a surrogate is data on
one variable (e.g., bulk concentration, release rate) that can  be used to reliably approximate the
magnitude of another (e.g., exposure point concentration) and, as a result, can substitute for the
other variable in the comparison. It is important to be aware of any differences in the chemical or
physical composition of the beneficial use and analogous product (e.g., organic carbon content,
density) because these variables can affect releases and subsequent exposures in ways that are not
easily predicted based on individual surrogates. The stronger the link that can be  documented
between the surrogate and exposures, the greater confidence there is in the comparison results.

It is  important to be aware that the processes that generate secondary materials can introduce
constituents not typically found in nature. When use of a secondary material introduces chemical
constituents or other stressors into  the beneficial  use that are wholly absent from any analogous
product,  this would be sufficient  information to demonstrate  that  the beneficial use is not
comparable  and that further evaluation is "warranted. Conversely,  if there are  constituents

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
associated "with the analogous product that are "wholly absent from the beneficial use, this "would
be sufficient information to demonstrate that exposures are lower and do not require further
comparison.

It is important to consider the full range of potential variability in this comparison, not only in the
composition of the products, but also in environmental conditions that affect fate and transport.
Statistical tests are one common and powerful tool that can be used to compare full  datasets.
However, statistical tests are only as accurate as available data allows them to be. The presence of
small datasets, high detection limits, and other sources of uncertainty can result in erroneous
conclusions. Thus, "where available, other comparisons and sources of information are encouraged
to corroborate statistical results. If the comparison can demonstrate that exposures to constituents
that result from the  beneficial use are comparable to or lower than those from an analogous
product, then no further evaluation "would be necessary. Any exposures found to be higher "would
"warrant further consideration through additional steps.

Hypothetical Application of Step 2
A secondary material is proposed for use as a replacement for the clay in bricks. The secondary
material contains an  inorganic compound that may volatilize and escape into indoor air. Bricks
also contain this compound. Thus, the same  exposures are possible from both products. Available
literature shows both a strong and consistent linear relationship between the concentration of this
constituent in the  products and the emission rate from the products. Because changes in the
emission rate are driven primarily by changes in the concentration of the constituent present in
the products, it is possible to conduct a comparison of bulk constituent concentrations in the two
products. Controlling for the effects of temperature and other  environmental factors that may
influence releases, a statistical test conducted on the range of constituent concentrations reveals
there is no appreciable difference between  concentrations in the two products. Based  on these
findings, releases of this constituent to indoor air "would not "warrant further evaluation.

Bricks also contain an inorganic constituent that may leach out and escape into ground "water.
However, there is no  reasonable  expectation that this constituent would be present in the
beneficial use based on knowledge of the generation and subsequent handling of the secondary
material. Documentation of the basis for this conclusion "would be sufficient to demonstrate that
concentrations are lower than in the analogous product. Additional collection of data to attempt a
quantitative comparison for this constituent "would not typically be "warranted.

Step 3 - Screening Analysis
This step characterizes the potential for adverse impacts from  the beneficial use through a
comparison "with screening benchmarks. A screening benchmark is a discrete value, typically a
concentration in environmental media, set at a level below "which exposures are not anticipated to
pose concern. The objective is to identify individual constituents or entire exposure pathways that
can be eliminated from further consideration "with a high degree of confidence prior  to more
intensive modeling. This is accomplished "with a combination of data and simplifying assumptions

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
on beneficial use composition, environmental conditions, and/or receptor characteristics that
result in a point estimate of exposures that ranges anywhere from a reasonable upper bound to a
"worst case scenario.

The benchmarks that are most relevant to an evaluation "will be determined by the constituents,
exposure routes, and receptors present. Federal, state and non-governmental organizations develop
and maintain benchmarks for various regulatory and non-regulatory purposes, "which may be
relevant to an evaluation. Benchmarks can also be calculated for an evaluation.  This allows the
screening benchmarks to capture any considerations specific to an evaluation, such as the presence
or absence of specific receptors.  In all cases,  it is important to understand and disclose any
assumptions built into the screening benchmarks to demonstrate that they are applicable and
sufficiently protective.

There is flexibility in how the degree of protectiveness is incorporated into calculated exposures.
At the most extreme, constituent concentrations at the point  of release can be compared directly
to screening benchmarks. Alternately, simplifying assumptions and screening models can be used
to estimate concentrations at the  point of exposure by accounting for some of the dilution and
attenuation that occurs during transport through  the environment. If the exposures are found to
be below levels of concern based on any of these comparisons "with screening benchmarks, then
no further evaluation  "would  be necessary.  However,  those found  to  be above screening
benchmarks after reasonable refinement of the screening "would "warrant further evaluation.

Hypothetical Application of Step 3
A beneficial use is proposed for use statewide  as an agricultural amendment mixed into subsurface
soils. Previous steps have shown that all exposures are comparable to those from the analogous
product, except for those from ingestion of  impacted ground water.  Of the potential receptors
identified, nearby residential receptors are determined to be the highest exposed population. The
constituent concentration measured at the  point of release is found to  exceed the screening
benchmark for residential receptors. A screening model "was then used to estimate dilution and
attenuation during transport through both the subsurface soils and underlying aquifer. Some of
the assumptions incorporated into the model to ensure that the model results do not underestimate
potential exposures include  that  the soil is  highly permeable and  that the closest residential
receptors live across the street from the location of the beneficial use. Initial model runs indicate
that  constituent  concentrations  are far  greater  than relevant benchmarks.  While further
incremental refinements are possible "within  available screening models, it  is unlikely that these
changes "will  appreciably change  the estimated exposures. Therefore, it is better to carry this
constituent forward to the next step. However, given that the exposures estimated in the screening
are biased high, it is  important to emphasize that the results of this  step are not intended to be
precise or even realistic. Therefore, an exceedance of screening benchmarks at this step does not
necessarily mean that the beneficial use "will pose concern.  However, if more refined analyses
cannot be performed and other sources of information are not available, this does indicate that
uncertainties are too great to demonstrate whether the beneficial use is appropriate as proposed.

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials

Step 4 - Risk Modeling
This step consists of a refined, quantitative and qualitative characterization of the potential for
adverse impacts from the beneficial use. The objective is to reduce remaining uncertainties enough
to permit "well-substantiated conclusions about the proposed use. This is accomplished by applying
more realistic data and models that refine the estimates of release, fate, transport and exposure that
are used to estimate the actual risks to receptors.

Prior to calculating risks, it is recommended that the assumptions and point estimates used in the
screening  are updated "with distributions that better reflect real-world conditions in order to
generate more realistic inputs for the models. However, assumptions that reflect an upper bound
or "worst case can be retained "where desired as a factor of safety, so long as they do not interfere
"with the ability to draw conclusions from model results. Once the models have been run, the media
concentrations generated by the models are combined "with information about potential receptors
and constituent toxicity to characterize the resulting risks. Quantitative characterization of these
risks provides the most useful information; however, "where available data are insufficient to
calculate risks, a qualitative characterization based on available information can still be helpful. If
the risks associated "with  all the  remaining exposures fall below levels of concern, then  the
beneficial use "would be considered appropriate. However, if one or more risks exceed standards,
then the beneficial use would not be considered appropriate as proposed.
Hypothetical Application of Step 4
The previous three steps of the evaluation screened out all complete exposure pathways, except for
ingestion of a constituent in ground water contaminated by leachate. The fourth step begins by
reviewing the data and assumptions used to calculate high-end exposures in previous steps and
replacing them "with probabilistic distributions that better reflect the real-world variability in
beneficial use composition, environmental parameters, and receptor characteristics. The selected
model is run using these updated data to generate more realistic constituent concentrations at the
point of exposure.  The adjusted  high-end estimate of  ground "water concentrations at  the
hypothetical downgradient "wells is then used to calculate the associated cancer and non-cancer
risks. The resulting risks are found to all be "well below levels of concern. Therefore, no additional
analysis is "warranted and the evaluation can proceed to the final phase of the  evaluation.

Phase III - Final Characterization
This is the final phase for beneficial use evaluations conducted using this methodology. The aim is
to integrate  key findings,  assumptions, limitations  and uncertainties identified throughout  the
evaluation into final conclusions about the potential impacts to human health and the environment
associated "with the proposed beneficial use. The emphasis of this phase is on providing context for
the results of the beneficial use evaluation in a transparent, clear, consistent and reasonable manner
to inform decision-makers and other relevant audiences, such as the general public.

If the evaluation shows that the beneficial use may  pose concern, this does not necessarily mean
that  the use of this secondary material is inappropriate under all circumstances. The concerns

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
identified may be  driven  by a  smaller  subset of constituent  levels,  beneficial  use design,
environmental conditions, or other factors considered in the evaluation. This phase can be used to
highlight the conditions under "which risks are below levels of concern or any additional steps that
can be taken to ensure that the use is appropriate. Based on these results, decision-makers may
choose to allow the beneficial use, either as proposed or with some additional conditions. Such
conditions might include  limitations on the amount of  a  secondary material that can be
incorporated into the beneficial use or on the constituent concentrations in the secondary material
used.

Hypothetical Application of Phase III
Modeling performed in the  previous phase found that the proposed use of a secondary material as
fill for road embankments across a state has the potential to adversely impact the health of nearby
residents.  Further review of the model results shows  that the identified risks are  driven by a
relatively  small subset of the secondary materials "with extremely high levels of one  chemical
constituent. Based on this information, the proposed use may be appropriate under the condition
that this subset is isolated and excluded from use. Alternatively, if this subset can be treated prior
to use to reduce the risks below levels of concern, then the beneficial use may be appropriate as
proposed.  If neither of these approaches  is viable, the  party conducting the  evaluation  may
consider altering the composition of the beneficial use to reduce the bulk concentration or to
eliminate  conditions  favorable  for releases.  However, altering  the  physical  or  chemical
composition of the beneficial use may result in the need  for additional data and analysis to
demonstrate that the amended beneficial use no longer poses concern.

Further Information
The purpose of this document is to describe the individual phases and steps of the EPA's beneficial
use methodology. This methodology is designed to be applicable to the widest range of secondary
materials and associated beneficial uses possible. Further information and tools that can assist "with
specific evaluations can be found in the Beneficial Use Compendium: A Collection of Resources
and Tools to Support Beneficial Use Evaluations (U.S. EPA,  2016). Those individuals or entities
who rely on these two documents should also coordinate with state regulatory bodies to ensure
that the application of the  methodology  is scientifically sound and  accounts for any additional
considerations required by state, tribal and territorial regulatory bodies. This coordination can help
facilitate beneficial use determinations.
                                                                                      10

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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
References
ACAA (American Coal Ash Association). 2015. 2014 Coal Combustion Product (CCP) Production
   & Use Survey Report Last accessed on January 21, 2016. Available online at: http://www.acaa-
   usa.org/Publications/ProductionUseReports.aspx

AFS  (American  Foundry Society).  2007.  Foundry Industry Benchmarking Survey: Industry
   Practices Regarding the Disposal and Beneficial Reuse of Foundry Sand - Results and Analysis.
   Last accessed on January 21, 2016. Available online at:
   http://www.afsinc.org/files/AFS/EHS/afs beneficial reuse %20survey07.pdf

ASTSWMO (Association  of  State and Territorial  Solid Waste Management Officials).  2007.
    ASTSWMO 2006 Beneficial Use Survey Report. Washington, DC. November.

United States  Environmental  Protection Agency (U.S.  EPA). 2013a. Methodology for Evaluating
   Encapsulated Beneficial Uses of Coal Combustion Residuals. EPA530-R-13-005. Office of Solid
   Waste and Emergency Response. Washington, DC. September.

U.S. EPA. 2013b. Responses  to External Peer Review Comments: Methodology for Evaluating
   Encapsulated Beneficial Uses of Coal Combustion  Residuals. Office of Solid  Waste and
   Emergency Response. Washington, DC. September.

U.S. EPA. 2014. Coal Combustion Residual Beneficial Use Evaluation: Fly Ash Concrete and FGD
   Gypsum  Wallboard.  EPA530-R-14-001. Office of Solid Waste and Emergency Response.
   Washington, DC. February.

U.S. EPA. 2015. Advancing Sustainable Materials Management: Facts and Figures 2013; Assessing
   Trends in Material Generation, Recycling and Disposal in the United States. EPA530-R-15-
   002. Office of Solid Waste and Emergency Response. Washington, DC. June.

U.S. EPA. 2016. Beneficial Use Compendium: A Collection of Resources and Tools to Support
   Beneficial Use Evaluations. Office of Solid Waste and Emergency Response. Washington, DC.
   May.
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Methodology for Evaluating the Beneficial Use of Industrial Non-Hazardous Secondary Materials
                                                                &EPA
                                                                    United States
                                                                    Environmental Protection
                                                                    Agency



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