February
2008

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U.S. Environmental Protection Agency
Beneficial Reuse of
Industrial Byproducts in the
Gulf Coast Region
Final
February 2008
Prepared for:
U.S. Environmental Protection Agency
Office of Policy, Economics, and Innovation
Sector Strategies Division
Prepared by:
ICF International
9300 Lee Highway
Fairfax, VA 22031
(703) 934-3000

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Executive Summary	ES-1
1.0 Introduction	1
1.1	Objectives	1
1.2	Research Scope and Boundaries	1
1.2.1	Definition of Beneficial Reuse	1
1.2.2	Sectors Addressed in This Analysis	2
1.2.3	Byproducts Addressed in This Analysis	3
1.3	Data Sources and Methodology	4
1.4	Organization of the Report	4
2.0 State Beneficial Reuse Programs and Regulations	5
2.1	Beneficial Reuse Regulations and Programs in the Gulf Coast States	5
2.1.1	Alabama	5
2.1.2	Florida	7
2.1.3	Louisiana	9
2.1.4	Mississippi	10
2.1.5	Texas	12
2.1.6	Summary	13
2.2	Federal Programs Encouraging State Program Improvements	13
3.0 Sector Traits and Trends, Drivers and Barriers in Current Beneficial Reuse	15
3.1	Cement Manufacturing (NAICS 327310)	 15
3.1.1	Beneficial Use Traits and Trends in the Cement Sector	16
3.1.2	Beneficial Reuse Drivers and Barriers in the Cement Sector	23
3.1.2.1	Cement Kiln Dust	25
3.1.2.2	Alternative Fuels and Raw Materials from Other Industries
Used in the Cement Industry	26
3.2	Chemical Manufacturing (NAICS 3251, 3252, 3253)	28
3.2.1	Beneficial Reuse Traits and Trends in the Chemical Manufacturing
Sector	28
3.2.2	Beneficial Reuse Drivers and Barriers in the Chemical Manufacturing
Sector	30
3.3	Construction and Demolition (NAICS 236, 23891)	 31
3.3.1	Beneficial Reuse Traits and Trends in the Construction and Demolition
Sector	31
3.3.2	Beneficial Reuse Drivers and Barriers in the Construction and
Demolition Sector	33
3.3.2.1	General C&DByproducts	35
3.3.2.2	Asphalt Shingles	37
3.3.3.3	Concrete	39
3.3.3.4	Wood	39
3.3.3.5	Gypsum Wallboard	40
3.4	Electric Power Generation at Fossil Fuel Plants (NAICS 221112)	41
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3.4.1	Beneficial Reuse Traits and Trends Electric Power Generation at
Fossil Fuel Plants	41
3.4.2	Beneficial Reuse Drivers and Barriers in Electric Power Generation at
Fossil Fuel Plants	45
3.4.2.1	Fly Ash	46
3.4.2.2	FGD Gypsum	50
3.5	Forest Products: Pulp, Paper, and Paperboard (NAICS 3221)	 50
3.5.1	Beneficial Reuse Traits and Trends in the Forest Products Sector	51
3.5.2	Beneficial Reuse Drivers and Barriers in the Forest Products Sector	52
3.5.2.1	General Forest Products Beneficial Reuse	55
3.5.2.2	Wastewater Treatment Plant Residuals	55
3.5.2.3	Boiler Ash	56
3.5.2.4	Causticizing Residues	57
3.6	Iron and Steel Mills (NAICS 3311)	58
3.6.1	Beneficial Reuse Traits and Trends in Iron and Steel Mills	58
3.6.2	Beneficial Reuse Drivers and Barriers in Iron and Steel Mills	60
3.6.2.1	Slag	61
3.6.2.2	Electric Arc Furnace (EAF) Dust	62
3.6.2.3	Spent Pickle Liquor	63
3.7	Metal Casting - Foundries (NAICS 3315)	64
3.7.1	Beneficial Reuse Traits and Trends in Foundries	65
3.7.2	Beneficial Reuse Drivers and Barriers in Foundries	66
3.7.2.1 Foundry Sands	67
3.8	Oil and Gas Extraction (NAICS 211111, 211112, 212111, 213112;	70
3.8.1	Beneficial Reuse Traits and Trends in Oil and Gas Extraction	70
3.8.2	Beneficial Reuse Drivers and Barriers in Oil and Gas Extraction	71
3.8.2.1	Drill Cuttings	72
3.8.2.2	Nonhazardous Tank Bottoms	73
3.9	Petroleum Refining (NAICS 32411)	 73
3.9.1	Beneficial Reuse Traits and Trends in Petroleum Refining	74
3.9.2	Beneficial Drivers and Barriers in Petroleum Refining	74
3.9.2.1 Sulfidic Caustics	75
4.0 Discussion and Findings	76
4.1	Economic/Market Drivers and Barriers	76
4.2	Regulatory/Programmatic Drivers and Barriers	80
4.3	Environmental Effects	83
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region	ii
February 2008

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List of Tail#*
Table ES-1: Gulf Coast Manufacturing Sectors Addressed in This Analysis
Table ES-2: Byproducts Selected for Analysis, and Their Cross-Sector Beneficial Reuses
Table ES-3: Drivers and Barriers Affecting Cross-Sector Beneficial Reuse
Table 1-1: Gulf Coast Manufacturing Sectors Addressed in This Analysis
Table 2-1: Summary of Gulf Coast State Regulatory Program Features
Table 3-1: Number of Cement Manufacturing Facilities in the Gulf Coast States as
Characterized by Cement America's North American Cement Directory
Table 3-2: Utilization of Fly Ash and Blast Furnace Slag in Cement Clinker and Portland
Cement Production (1999 - 2005)
Table 3-3: Byproducts from Cement Manufacturing (NAICS: 327310) Selected for Analysis
Table 3-4: Chemical Manufacturing Industry in Gulf Coast States in 2006 as Characterized
by the American Chemistry Council
Table 3-5: Number of Chemical Manufacturing Facilities in Gulf Coast States as
Characterized by U.S. Census 2004 County Business Patterns
Table 3-6: Number of Construction and Demolition Establishments in Gulf Coast States as
Characterized by U.S. Census 2004 County Business Patterns
Table 3-7: Byproducts from Construction and Demolition (NAICS: 236 (Construction of
Buildings), 23891 (Site Preparation Contractors)) Selected for Analysis
Table 3-8: Number of Fossil Fuel Burning Electric Power Generation Facilities in Gulf Coast
States as Characterized by U.S. Census 2004 County Business Patterns
Table 3-9: Coal Combustion Products Beneficial Reuses in the Gulf States in 2004
Table 3-10: Byproducts from Electric Power Generation at Fossil Fuel Plants (NAICS: 2211)
Selected for Analysis
Table 3-11: Number of Pulp, Paper, and Paperboard Mills in Gulf Coast States as
Characterized by U.S. Census 2004 County Business Patterns
Table 3-12: Byproducts from Forest Products Manufacturing Process(es) (NAICS: 3221)
Selected for Analysis
Table 3-13: Number of Iron and Steel Mills in Gulf Coast States as Characterized by EPA and
U.S. Census
Table 3-14: Byproducts from Iron and Steel (NAICS: 3311) Selected for Analysis
Table 3-15: Number of Foundries in Gulf Coast States as Characterized by U.S. Census 2004
County Business Patterns
Table 3-16: Beneficial Reuses of Foundry Sands According to American Foundry Society
Survey
Table 3-17: Byproducts from Metal Casting - Foundries (NAICS: 3315) Selected for Analysis
Table 3-18: Byproducts from Oil and Gas Extraction (NAICS: 211111, 211112, 213111,
213112) Selected for Analysis
Table 3-19: Number of Petroleum Refineries in Gulf Coast States as Characterized by U.S.
Census 2004 County Business Patterns
Table 3-20: Byproducts from Petroleum Refining (NAICS: 32411) Selected for Analysis
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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List of Figures
Figure 3-1: Cement Clinker Production Gulf State Region (2005)
Figure 3-2: Cement Kiln Dust Use in Clinker and Portland Cement Production in the U.S.
Figure 3-3: Coal Combustion Products Used in Producing Clinker and Portland Cement in the
U.S.
Figure 3-4: Utilization of Iron and Steel Sector Slag in Cement Clinker Production in the U.S.
(1999-2005)
Figure 3-5: Coal Combustion Products Produced by Coal-Fired Power Plants Located in the
Gulf States in 2004 (metric tons)
Figure 3-6: Coal Combustion Products Production and Beneficial Reuse in the Gulf Coast
States in 2004
Figure 3-7: U.S. Domestic Production of Steel and Pig Iron
Figure 4-1: Geographic Distribution and Density of Establishments in Seven Industry Sectors
as Characterized by US Census 2004 County Business Patterns
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
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iv

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mm
AASHTO
American Association of State Highway and Transportation Officials
ACAA
American Coal Ash Association
ACC
American Coal Council
ADEM
Alabama Department of Environmental Management
ADOT
Alabama Department of Transportation
AFS
American Foundry Society
AISI
American Iron & Steel Institute
AMD
Acid mine drainage
API
American Petroleum Institute
ASTM
American Society for Testing and Materials
BOF
Basic oxygen furnace
BOG
Basic oxygen process
BMRA
Building Materials Reuse Association
BTU
British thermal unit
BUD
Beneficial Use Determination (Mississippi)
C&D
Construction and demolition
C2p2
Coal Combustion Products Partnership (EPA)
CAA
Clean Air Act
CAIR
Clean Air Interstate Rule
CCP
Coal combustion product
CKD
Cement kiln dust
CMRA
Construction Materials Recycling Association
C02
Carbon dioxide
CSI
Cement Sustainability Initiative (World Business Council for Sustainable

Development)
DOE
U.S. Department of Energy
DOT
Department of Transportation (federal or state)
EAF
Electric arc furnace
EERC
Energy and Environmental Research Center (University of North Dakota)
EGU
Electric generating unit
EIA
Energy Information Administration (DOE)
EJ
Environmental justice
EPA
U.S. Environmental Protection Agency
EPP
Environmentally Preferable Purchasing
EPRI
Electric Power Research Institute
FAA
Federal Aviation Administration (DOT)
FAQMP
Fly Ash Quality Monitoring Program (Texas)
FEMA
Federal Emergency Management Agency (U.S. Department of Homeland

Security)
FDOT
Florida Department of Transportation
FGD
Flue gas desulfurization
FHWA
Federal Highway Administration (DOT)
FIRST
Foundry Industry Recycling Starts Today
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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FL DEP
Florida Department of Environmental Protection
FR
Federal Register
GGBFS
Ground granulated blast furnace slag
GHG
Greenhouse gas
GRI
Gypsum Recycling International Company
HAP
Hazardous air pollutant
HMA
Hot-mix asphalt
HWC
Hazardous waste combustor
ITP
Industrial Technologies Program (DOE)
LA DEQ
Louisiana Department of Environmental Quality
LEED
Leadership in Energy and Environmental Design
LOI
Loss on Ignition
LPPA
Louisiana Pulp and Paper Association
MACT
Maximum Achievable Control Technology
MassDEP
Massachusetts Department of Environmental Protection
MMT
Million metric tons
MS DEQ
Mississippi Department of Environmental Quality
MSW
Municipal solid waste
MW
Megawatts
OPEI
Office of Policy, Economics, and Innovation (EPA)
OSM
Office of Surface Mining (U.S. Department of Interior)
OSW
Office of Solid Waste (EPA)
NAICS
North American Industrial Classification System
NCASI
National Council for Air and Stream Improvement
NCEI
National Center for Environmental Innovation (EPA)
NESHAP
National Emissions Standards for Hazardous Air Pollutants
NPDES
National Pollutant Discharge Elimination System
NSA
National Slag Association
PCA
Portland Cement Association
PCB
Polychlorinated biphenyl
PE
Professional engineer
RCC
Resource Conservation Challenge
RCRA
Resource Conservation and Recovery Act
RENEW
Resource Exchange Network for Eliminating Waste (Texas)
RMDB
Recycling Market Development Board (Texas)
RMRC
Recycled Materials Resource Center
RRC
Railroad Commission of Texas
SCA
Slag Cement Association
S02
Sulfur dioxide
SQG
Small quantity generator
SRI
Steel Recycling Institute
TAC
Texas Administrative Code
TAPPI
Technical Association of the Pulp and Paper Industry
TCAUG
Texas Coal Ash Utilization Group
TCEQ
Texas Commission on Environmental Quality
TCLP
Toxicity Characteristic Leaching Procedure
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TPH
Total petroleum hydrocarbons
TxDOT
Texas Department of Transportation
USACE
U.S. Army Corps of Engineers
USBCSD
U.S. Business Council for Sustainable Development
USGBC
U.S. Green Building Council
USD A
U.S. Department of Agriculture
USGS
United States Geological Survey (U.S Department of the Interior)
WBCSD
World Business Council for Sustainable Development
WGBC
World Green Building Council
WWTP
Wastewater treatment plant
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
vii

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H^mut	^Jyji ^ns* ifli^^ n^i ^isim^
We would like to thank the following organizations, their staff, and members for their input to
review and comment on draft versions of this report:
Kimberly Cochran, USEPA
Dave Goss, American Coal Ash Association (ACAA)
Brad Guy, Building Materials Reuse Association (BMRA)
Timonie Hood, USEPA
Mike Lindner. Texas Council on Environmental Quality (TCEQ)
Lyn Luben, USEPA
Randy Mountcastle, Alabama Department of Transportation (ADOT)
Lynn Roper, Alabama Department of Environmental Management (ADEM)
Jerry Schwartz, American Forest and Paper Association (AF&PA)
Bijan Sharafkhani, Louisiana Department of Environmental Quality (LADEQ)
Richard Tedder, Florida Department of Environmental Protection
(FDEP)
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008

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Executive Summary
Almost everything we do leaves something behind,
from household trash - often referred to as municipal or
solid waste - to industrial waste. Industrial waste,
which includes both nonhazardous materials and
hazardous waste, is a major component of landfills. In
fact, for every ton of municipal solid waste there are
more than 30 tons of industrial waste in the nation's
landfills.1
Industries are finding new ways to use materials that
would otherwise be discarded. Facilities are reusing
byproducts or waste materials in their own operations or sending them elsewhere for reuse as a
substitute raw material or as a fuel. This is known as beneficial reuse - turning would-be waste
into a valuable commodity.
The concept of beneficial reuse is quite simple; however, in some areas there is very little reuse
occurring. When asked at conferences and discussion forums, most stakeholders agree that reuse
of industrial material is a great idea. Businesses like beneficial reuse because it reduces their
waste costs and in some cases provides a new viable product to sell. EPA and environmentalists
like the idea because safe, environmentally sound use of industrial materials reduces demand for
natural resources and reduces the load on landfills. Is this a gold mine or fool's gold? If
beneficial reuse of industrial materials is such a great idea, why isn't more of it happening?
Beneficial reuse is very much a geographic issue. In most cases, the biggest economic obstacle
is that companies cannot afford to ship byproducts further than their immediate region. By
concentrating this analysis on the Gulf Coast, we hope to make a contribution to the ongoing
issue of waste management in the region following the devastating hurricanes of 2005. We
believe that lessons learned for the Gulf Coast may provide useful insights for other regions of
the country.
Objective
The objective of this analysis is to assist the U.S. Environmental Protection Agency (EPA) in
developing strategies to promote greater rates of beneficial use of industrial materials in the Gulf
Coast region and elsewhere. It is intended to increase understanding of byproducts and beneficial
reuse opportunities in several major industries, and assess drivers and barriers to their reuse.
Approach
We selected nine sectors for analysis based on their affiliation with EPA's Sector Strategies
Program (eight of the nine sectors are part of the Program) and the amount and type of their
byproducts (or wastes). We examined Census economic data, researched literature, and
Nine Industrial Sectors Examined in This Report
•	Cement Manufacturing
•	Chemical Manufacturing
•	Construction and Demolition
•	Electric Power Generation at Fossil Fuel Plants
•	Forest Products: Pulp, Paper and Paperboards
•	Iron and Steel Mills
•	Metal Casting - Foundries
•	Oil and Gas Extraction
•	Petroleum Refining
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
ES-1

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conducted interviews for information on facilities, byproducts generated, byproduct reuses and
the potential for further reuse. The sectors and materials we analyzed are shown in Table ES-1.
Table ES-1: Gulf Coast Manufacturing Sectors and Byproducts Addressed in This Analysis
Sector (NAICS)
Materials Generated by Industry and Selected
for Analysis
Materials Reused by Industry and Selected for
Analysis
Cement Manufacturing
(NAICS 327310)
ฆ Cement Kiln Dust (CKD)
ฆ	Wood Waste (fuel)
ฆ	Fly Ash (Coal Combustion Product, CCP) and Flue
Gas Desulfurization (FGD) Gypsum (raw material)
ฆ	Bottom Ash (CCP)
ฆ	Forest Product Causticizing Residue (raw material)
ฆ	Granulated Blast Furnace Slag (raw material)
ฆ	Other Blast Furnace Slag, Steel Slag, and Electric
Arc Furnace (EAF) Dust/Sludge from EAF Gas
Cleaning & Collection (raw material)
ฆ	Foundry Sand (raw material)
ฆ	Petroleum Refining Sulfidic Caustics (fuel)
Chemical Manufacturing
(NAICS 3251, 3252,
3253)
ฆ Focus on Dow Byproduct Synergy projects
Construction and
Demolition (C&D) (NAICS
236, 23891)
ฆ	Asphalt Shingles (from demolition and roof
replacement)
ฆ	Concrete (from demolition)
ฆ	Wood (from demolition and construction)
Gypsum Wallboard (from demolition and
construction)
ฆ	Foundry Sand (raw material)
ฆ	Iron and Steel Slag (raw material)
Electric Power
Generation at Fossil Fuel
Plants (NAICS 221112)
ฆ	Fly Ash
ฆ	FGD Gypsum
ฆ Wood Waste (fuel)
Forest Products: Pulp,
Paper and Paperboards
(NAICS 3221)
ฆ	Wastewater Treatment Plant (WWTP) Residuals
(Wood Fibers, Minerals and Microbial Biomass)
ฆ	Boiler Ash (Noncombustible Materials Left after
Burning of Coal, Wood, Other Fuel)
Causticizing Residues (i.e., lime mud, lime slaker
grits, and green liquor dregs)

Iron and Steel Mills
(NAICS 3311)
ฆ	Slag (Slag from Basic Oxygen Furnace (BOF)
and EAF Mills (Steel Slag); Blast Furnace Slag;
Ground Granulated Blast Furnace Slag
(GGBFS); other)
ฆ	EAF Dust/Sludge (from EAF Gas Cleaning and
Collection)
ฆ	Spent Pickle Liquor

Metal Casting -
Foundries (NAICS 3315)
ฆ Foundry Sand

Oil and Gas Extraction
(NAICS 211111,211112,
213111,213112)
ฆ Drill Cuttings
Nonhazardous Tank Bottoms (sediments and
water)

Petroleum Refining
(NAICS 32411)
ฆ Sulfidic Caustics
Nonhazardous Tank Bottoms

We limited the scope of our analysis to the exchange of materials within the nine industries. We
did not look at reuses of materials within a single facility.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
ES-2

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We looked at government programs and regulations that affect industrial materials reuse in each
of the Gulf coast states. We then investigated how these government programs as well as
economic and environmental considerations serve as drivers for or barriers to reuse of the
materials. After identifying sector-specific drivers and barriers, we examined common themes
that recur among the sectors.
Findings
"Overarching" drivers and barriers. The common factors that play significant roles in driving
or discouraging reuse of industrial byproducts are summarized below.
o Geographic distribution and associated costs of transportation. A barrier associated with
many of the sectors is the long distance between byproduct generators and potential end
users. Factors affecting the possibility of byproduct exchanges between distant facilities
include access to transportation (highway, rail) and material hauling costs.
o Relative convenience and lower cost of landfilling. Cheap disposal costs inhibit beneficial
reuse. Unless a material has an inherent market value, a generator is more likely to dispose of
it in the nearest landfill. Landfill tipping fees tend to be low in the southeastern states, where
land is relatively cheap and landfills are plentiful. When tipping fees increase and become
expensive enough for generators to consider alternatives to disposal, beneficial reuse should
become a more desirable option.
o Inconsistent quantity and composition of byproducts due to relative size of sector facilities.
Beneficial reuse projects often require a minimum quantity of material and a specific
composition and consistency to make reuse in a manufacturing process feasible. Most of the
sectors we examined have numerous small- to medium-sized facilities, making accumulation
of significant amounts of byproduct challenging. Materials generated from one or even a few
facilities may be insufficient for beneficial reuse in certain processes. Transportation of one
large shipment can be much more cost effective than pickup and transportation of multiple
small shipments. The prevalence of small generators may also contribute to inconsistent
physical and chemical compositions of byproducts. Although consolidation and blending of
byproducts could address these barriers, establishing a network to accomplish this task can be
daunting.
o Standards and specifications. Availability of manufacturing specifications can be a driver or
barrier. The absence of specifications for reused materials can create a barrier because
manufacturers may be unwilling to stake the quality of their product on an uncertain input
material. Published manufacturing specifications for input of reused materials diminishes the
uncertainty.
o Awareness and marketing. Lack of awareness of the connections between generators and
potential end users creates another barrier to beneficial reuse. Material generators may not be
aware that potential end users are located nearby, and end users may not know that
byproducts can be used in their manufacturing process. Matching up generators and end users
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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can be a challenging process; generators incur marketing costs to find end users or third
parties who will broker their byproducts to potential end users. Several industry trade
associations and beneficial reuse organizations have led awareness and marketing efforts to
address this barrier.
o Core competency. Beneficial reuse is not a core competency for many manufacturing
facilities because it is not in their primary line of business. Overcoming misperceptions about
the time and cost involved to beneficially reuse materials can be challenging. The cement
sector is an example of an industry that has made reuse of materials from other sectors part of
its core competency, meeting and even exceeding industry goals for beneficial reuse.
o State requirements. State regulations in Florida, Alabama, Texas, Louisiana, and Mississippi
vary in their complexity, their levels of allowable material reuses, and their mechanisms for
approval. Some state regulations contain provisions that encourage reuse of byproducts,
whereas others lack such drivers. For example, Alabama allows mixing or blending of certain
byproducts to facilitate reuse, while others do not. Inconsistent state regulations and approval
processes can inhibit reuse when generators in one state and end-users in another state must
be compliant with different sets of regulatory requirements.
o Government resources. Limited money and staff are available for state and local
governments to run beneficial reuse programs. Median income levels in the Gulf Coast states
are lower than in many other areas of the country, which limits the tax revenue available for
non-mainstream environmental programs. Although government agencies may not have
adequate resources to support beneficial reuse programs, some industry organizations have
stepped in to fill this need, conducting research and education on beneficial reuse
opportunities.
Driv d Barriers, Sector-by-Sector
Table ES-2 summarizes the economic/market, regulatory/programmatic, and environmental
barriers to reuse of each sector's byproducts.
Economic/market considerations include such factors as geographic dispersion of facilities and
associated transportation and disposal costs; generation of byproduct of a consistent quality and
quantity; specifications or desired byproduct characteristics; price of virgin material compared to
the byproduct; and awareness and marketing efforts.
Regulatory/programmatic elements focus on state regulations, programs and resources, as well
as federal regulations, programs, and resources.
Environmental effects represent the potential positive and negative impacts from beneficial
reuse. Environmental considerations, while often not barriers or drivers for individual firms
decisions, can factor into establishment of beneficial reuse programs and regulations.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
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ES-4

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Some economic, regulatory, or environmental barriers may be viewed as both major and minor,
depending on individual facility perspectives, or have had mixed effects; we indicate these
entries with a "mixed" in the table.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
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ES-5

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Table ES-2: Barriers Affecting Cross-Sector Beneficial Reuse

Economic/Market
Regulatory/Programmatic
Environmental Effects
Byproduct
Lack of
Education/
Awareness
for
Generators
and End
Users
Lack of Usable
Quantities
and/or
Inconsistent
quality
High Geographic
Dispersion and/or
Excessive
Transportation
Costs
Lack of
Specifications
or Desired
Characteristics
Industry
Lacks Core
Competency
Low Cost of
Landfilling or More
Convenient to
Landfill
Stringent and/or
Unclear State
Programs and
Resources
Stringent and/or
Unclear Federal
Regulations,
Programs, and
Policies
Concern about potential
negative effects
Cement Industry
Cement Kiln Dust
Minor
Major
Major

Minor

Major
Minor
Major
Alternative Fuels Used
in Cement Production
Minor



Minor

Major
Mixed
Mixed
Chemical Industry
Manufacturing
Byproducts
Minor





Major
Major
Minor
Construction and Demolition
Asphalt Shingles
Minor
Major
Major
Mixed


Major

Major
Concrete
Minor

Major



Major

Minor
Wood
Minor
Major
Major



Major

Mixed
Gypsum Wallboard

Major




Major

Mixed
Electric Power Generation
Fly Ash
Minor


Mixed


Mixed
Mixed
Major
FGD Gypsum


Mixed
Major


Mixed
Minor
Minor
Forest Products: Pulp, Pa
per and Paperboard
Wastewater Treatment
Plant Residuals
Minor


Major


Major
Mixed
Major
Boiler Ash
Minor
Major




Major

Major
Causticizing Residues
Minor
Major

Major


Major


Iron and Steel Mils
Slag
Minor
Major

Major


Major

Minor
EAF Dust






Major
Major

Spent Pickle Liquor

Major




Major
Major
Minor
Metal Casting-Foundries
Foundry Sands
Major
Major
Major
Mixed
Major
Major
Major
Minor
Mixed
Oil and Gas Extraction
Drill Cuttings

Major
Major
Major


Major
Major
Major
Nonhazardous Tank
Bottoms

Major

Major


Major
Minor
Minor
Petroleum Refining
Sulfidic Caustics


Mixed



Major
Minor
Minor
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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1.0	Introduction
1.1	Objectives
EPA's Sector Strategies Division in the Office of
Policy, Economics, and Innovation commissioned
this analysis to meet the following objectives:
o Facilitate a general understanding of byproduct generation in major industries and beneficial
reuse opportunities in the Gulf Coast region, specifically Texas, Louisiana, Mississippi,
Alabama, and Florida.
o Assess economic, market, regulatory, and programmatic drivers and barriers to beneficial
reuse of selected byproducts within the major industries of interest.
o Determine common themes affecting beneficial reuse in the Gulf Coast region.
This analysis focuses on the Gulf Coast region, because the devastating impacts of Hurricanes
Katrina and Rita on infrastructure created new challenges and opportunities for beneficial reuse.
This report is an analytical document. It does not convey EPA policy decisions. The report's
findings and conclusions are based on the data used in this analysis. EPA hopes this report will
enlighten discussion of material reuse issues between EPA, state and local governments, and
industry stakeholders.
1.2	Research Scope and Boundaries
1.2.1 Definition of Beneficial Reuse
"Beneficial reuse" is a term that can hold various meanings and can be broadly defined as
turning would-be waste into a valuable commodity. For the purposes of this paper, beneficial
reuse is more narrowly defined as: the reuse of byproducts from one manufacturing process in
another manufacturing process. To further refine the scope of analysis per this definition of
beneficial reuse, this paper:
o Focuses on reusing byproducts from one sector by another sector and therefore excludes
beneficial reuse of byproducts within the same facility. We want to establish collaborative
relationships among sectors. Furthermore, a reuse that could occur within a facility is more
likely to be identified and implemented than potential exchanges of materials between
facilities in different sectors. We decided to focus on opportunities that need the most
encouragement.
o Excludes reuse of commodities with a strong market in place, such as metals that are
recovered from scrap metal, petroleum coke, and other byproducts. The valuable nature of
these byproducts presents less of a challenge for beneficial reuse, as there is a clear economic
incentive to recover and sell the materials for financial gain.
Chapter 1.0 Introduction
1.1	Objectives
1.2	Research Scope and Boundaries
1.3	Data Sources and Methodology
1.4	Organization of the Report
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1.2.2 Sectors Addressed in This Analysis
The scope of this paper is limited to industries in Alabama, Florida, Louisiana, Mississippi, and
Texas. To select industry sectors for analysis, we first analyzed North American Industrial
Classification System (NAICS) codes from the 2002 Census to determine the top manufacturing
industries in each state by number of establishments, revenue, and number of employees. Once
we identified the top manufacturing sectors, we then examined the types and quantities of
byproducts generated in each sector, and the potential for beneficial reuse of each byproduct
based on the quantity and types of reuse presently occurring across the United States and in other
countries.
Using this information, we selected nine sectors for analysis, displayed in Table 1-1. Eight of
these sectors are participating in EPA's Sector Strategies Program: cement, specialty batch
chemicals (within broader chemical manufacturing), construction (including construction and
demolition), forest products (pulp, paper, and paperboard manufacturing), iron & steel, metal
casting, oil and gas extraction, and petroleum refining.
Table 1-1: Gulf Coast Manufacturing Sectors Addressed in This Analysis
Sector
NAICS
Cement Manufacturing
327310
Chemical Manufacturing
3251, 3252, 3253 [with a focus on beneficial reuse in the Dow
Byproduct Synergy proiectsl
Construction and Demolition (C&D)
236, 23891
Electric Power Generation at Fossil Fuel Plants
221112
Forest Products: Pulp, Paper and Paperboards
3221
Iron and Steel Mills
3311
Metal Casting - Foundries
3315
Oil and Gas Extraction
211111, 211112, 213111, 213112
Petroleum Refining
32411
Additional sectors that we evaluated and deemed outside of the scope of this analysis include:
o Metal Mining (NAICS 2122) and Support Activities (NAICS 213114). Preliminary
research indicates that processing tailings are mainly reused to recover metals for profit.
o Automotive Debris. Although automotive debris is a concern in the EPA Regions, currently
95 percent of all scrapped cars are recycled, and markets exist for materials recovered from
cars. It appears that this is the case in the Gulf Coast region.
o Architectural and Structural Metals Manufacturing (NAICS 3323) and Machine Shops
(3327). The many small machine shops that are prevalent in Gulf Coast states appear to
already reuse scrap metals, spent coolant, and waste oil. Architectural and structural metals
manufacturers reuse scrap metal within the same facility or sell it to other manufacturing
facilities.
o Printing and Related Support Activities (NAICS 3231). Research indicates that most print
shops reuse solvents and rags within their own shops.
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1.2.3 Byproducts Addressed in This Analysis
Each of the nine sectors produces numerous byproducts. We examined all byproducts generated
by each of these sectors and then selected specific "byproducts of interest" for in-depth analysis
using the following criteria, more than one of which may apply to each sector. If a byproduct did
not meet all of the criteria, it was not necessarily excluded from the analysis. Rather, we
developed these criteria as general guidelines to set the scope of the paper and examine potential
reuses.
1.	Is the byproduct produced in sufficient quantities (tons) to facilitate beneficial reuse in
manufacturing processes? Byproducts of interest should be produced in quantities large
enough to facilitate beneficial reuse in other manufacturing processes. Moreover, the
materials should have beneficial reuse opportunities that could curb significant waste
disposal and environmental impacts.
2.	Is there potential for increased beneficial reuse of the byproduct? If the byproduct is
being reused already at significant levels (i.e., more than 85 percent), then we determined
that a market either already exists or the material is close enough to acceptance in the
marketplace that further study is unwarranted. Several byproducts examined for this paper
can be reused as fuel and can also be reused as inputs in place of raw materials. Although
use of byproducts as fuel for energy recovery may be economically preferable, use as an
ingredient is often the preferred environmental outcome. Therefore, the analysis includes
byproducts of interest that are currently reused as fuel but have significant potential for other
types of beneficial reuse.
3.	Can the byproduct replace virgin materials in manufacturing? If the material is only
replacing another recycled material, then the environmental outcome of reducing the demand
on natural resources is not achieved.
4.	Does byproduct generation or reuse occur within sectors of interest for the analysis?
Our interest in this analysis is to encourage cross-sector collaborations, using industries in
EPA's Sector Strategies Program as a starting point given our well-established contacts and
connections in those sectors. Byproducts of interest for this paper are being reused across or
within sectors where the generator and/or end user are in our nine sectors of interest.
Beneficial reuses on-site at the same facility are generally not included in this analysis
because these reuses do not include the mechanisms and challenges associated with cross-
sector beneficial reuse.
5.	Does byproduct generation or reuse occur across other sectors, even beyond the nine
sectors included in this analysis? In order to provide a clear and accurate picture of cross-
sector reuse, we also selected byproducts of interest where the end user is not in one of the
nine sectors of interest for this analysis.
6.	Is the byproduct a result of manufacturing or is it a post-consumer byproduct?
Beneficial reuse of post-consumer products (such as scrap tires) is very important. However,
the reuse of those materials has different collection and reuse mechanisms than
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manufacturing byproducts. We decided to limit the analysis to potential material exchanges
between manufacturing sectors.
1.3	Data Sources and Methodology
This analysis relies on the best available and most recent data from the following sources:
o Websites and publications on beneficial reuse associated with EPA's Sector Strategies
Program, Office of Solid Waste, and the Resource Conservation Challenge.
o State publications and regulations pertaining to beneficial reuse, with follow-up calls to
specific contacts.
o Contacts with associations addressing beneficial reuse of industrial byproducts.
o Other federal agencies, including the U.S. Geological Survey and U.S. Department of
Energy.
o Contacts in academia with specific expertise in beneficial reuse of industrial byproducts.
This analysis also incorporates data and findings from previous Sector Strategies publications,
including the 2006 Sector Strategies Performance Report and the 2007 Energy Trends in
Selected Manufacturing Sectors: Opportunities and Challenges for Environmentally Preferable
Energy Outcomes. The most recent published data for the sectors are for 2004 or 2005, which
generally represents the sectors in 2007. One exception is the construction and demolition
industry in the Gulf Coast states, which has seen a good deal of change since Hurricanes Katrina
and Rita in late 2005.
1.4	Organization of the Report
The major sections of this report are organized as follows:
o Chapter 2, State Beneficial Reuse Programs and Regulations, examines the state regulatory
and programmatic features addressing beneficial reuse of industrial byproducts in Alabama,
Florida, Louisiana, Mississippi, and Texas. The chapter analyzes drivers and barriers arising
from state regulations and programs.
o Chapter 3, Sector Traits and Trends, Drivers and Barriers in Beneficial Reuse, characterizes
the nine industrial sectors' manufacturing processes, byproduct production, and potential for
materials reuse. The chapter looks at traits and trends related to beneficial reuse in each
sector and examines the drivers and barriers for reuse of each selected byproduct.
o Chapter 4, Discussion and Findings, summarizes the drivers and barriers to beneficial reuse
and provides our conclusions from this analysis.
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2.0 State Beneficial Reuse Programs and Regulations
Well crafted regulations combined with sufficient
implementation outreach can positively affect the
extent of beneficial reuse within and across sectors
by providing assurance to generators and end users
that the beneficial reuse is safe and legal.
Assuming that the state has credibility for
protecting the environment, regulations can help
mitigate any negative stigma and liability issues
associated with reuse of a material that was once
considered a regulated waste stream. Highly stringent regulations, however, can have the
opposite effect. Although intended to protect human health and environment, stringent
regulations can inhibit reuse if compliance is too costly or time consuming. A lack of beneficial
reuse regulations can have a similar discouraging effect. Some might argue that a lack of
regulations might encourage end users by leaving reuse options open and minimizing compliance
burden. However, in conversing with generators and end users, we have found that a lack of
regulations could also discourage beneficial reuse by not providing a level of security for
generators and end users to address their liability concerns.
Chapter 2 first provides a detailed overview of each of the Gulf Coast states' programs and
regulations and then details how each state's regulations and program lowers or raises barriers to
beneficial reuse. In some cases, programs may even drive beneficial reuse by addressing
economic/market concerns, such as connections between generators and end users.
2.1 Beneficial Reuse Regulations and Programs in the Gulf Coast States
Five states are included in this regional analysis: Alabama, Florida, Louisiana, Mississippi, and
Texas. Three states, Alabama, Florida, and Mississippi, are in EPA Region 4, while two states,
Louisiana and Texas, are in EPA Region 6. The following discussion of each state's regulations
and program is organized by six major program features:
o Program structure;
o Siting/location restrictions;
o Level of state review;
o State response;
o Initial sampling and testing; and
o Ongoing sampling, testing, and recordkeeping.
2.1.1 Alabama
The state of Alabama does not have an organized beneficial reuse program for industrial
byproducts. According to contacts at the Alabama Department of Environmental Management
(ADEM), the agency has received inquiries from industry expressing the need for a central
system or clearinghouse to match generators with end users and track reuse activities.2 At this
time, however, no such central management system exists.
Chapter 2.0 State Beneficial Reuse
Programs and Regulations
2.1	Beneficial Reuse Regulations and
Programs in the Gulf Coast States
2.2	Drivers and Barriers Arising from State
Beneficial Reuse Regulations and
Programs
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ADEM regulations establishing the state's solid waste program, however, specify requirements
for the reuse of foundry sand through its "Requirements for Management and Disposal of Special
Waste" in Chapter 335-13-4.26 (3).
Program Structure
Alabama has a single-tiered waste classification structure for foundry sands. Foundry sands that
exhibit less than 50 percent of toxicity characteristic (TC) levels for metals as defined by EPA's
Toxicity Characteristic Leaching Procedure (TCLP) may be beneficially reused. If foundry sands
do not meet this requirement, they must be managed at an approved recycle/reuse facility or a
landfill approved and permitted for the disposal of foundry sands. For beneficial reuse of
industrial wastes other than foundry sand as a fill material, Alabama applies the foundry sand
criteria (less than 50 percent of toxicity characteristic (TC) levels for metals as defined by EPA's
TCLP) to the waste before allowing reuse. If the reuse activity is something other than fill
material, then the state uses a case-by-case approach to review and approve or deny the reuse.3
Siting/Location Restrictions
Alabama's regulations also specify location restrictions for foundry sand reuse activities.
Beneficial reuse activities are restricted from floodplains, wetlands, residential zones, and areas
less than five feet above the uppermost aquifer.
Level of State Review
To initiate beneficial reuse, Alabama requires analysis and certification of the foundry sand
waste composition. To certify the foundry sands, the generator submits a completed Solid and
Hazardous Waste Determination Form and a TCLP analysis for metals. Once the state receives
this information from the generator, the state reviews the documentation. ADEM reviews the
constituent concentration levels, but does not review the generator's proposed beneficial reuse
activity.
ADEM staff explained that the foundry sand regulation was developed to allow foundries to use
their sand as fill material either onsite or offsite. ADEM staff stated that they have received
inquiries from foundries about other potential beneficial reuses. For example, a foundry recently
contacted ADEM to inquire about reuse of sands as road base. The state acknowledged that as
long as the project complies with the existing rule requirements, then the beneficial reuse is
allowable. Therefore, although the regulation was originally designed to cover one beneficial
reuse activity (fill material), ADEM applies the regulatory requirements to other proposed
beneficial reuse activities.
State Response
Although the regulation does not specify that ADEM send a written response to generators,
ADEM staff clarified that the beneficial reuse approval process does include a written reply from
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the agency. The agency sends a certification letter to the applicant, approving of the generator's
Solid and Hazardous Waste Determination Form and TCLP analysis.
Initial Sampling and Testing
Alabama's Administrative Code specifies maximum allowable constituent thresholds, based on
Resource Conservation and Recovery Act (RCRA) TC levels, to determine if a waste is
beneficially reusable. To be determined reusable, foundry sands must demonstrate constituent
levels less than 50 percent of the TC levels for metals. The TCLP analysis must be submitted to
ADEM along with a Solid and Hazardous Waste Determination Form. The form must provide
the name of the generator and describe the waste generating process, the physical state, and
whether the sand will be used as a fill material.
Additionally, the generator must contact the Water Division of ADEM to obtain any necessary
General Stormwater and/or National Pollutant Discharge Elimination System (NPDES) permits
for the reuse sites.
Ongoing Sampling, Testing, and Recordkeeping
Alabama requires quarterly testing of foundry sands to ensure that the waste continues to meet
the required constituent concentration levels. The generator must also report the results to
ADEM. In Chapter 335-13-4-.26(3)(c), the regulations state that a Solid and Hazardous Waste
Determination Form and a TCLP analysis be submitted to ADEM quarterly or whenever the
production process changes in such a manner that would significantly alter the test results.
According to ADEM, all generators that are reusing foundry sand must comply with the
quarterly testing and reporting requirements, regardless of the volume being reused.
The regulations also require that each foundry maintain related records at the manufacturing
facility. These records include a description of the site where beneficial reuse occurs, the site's
location within a specific township and range, and the volume of sand at the location. When
multiple foundries send sand to a particular reuse location, these sands may be mixed together
and reused as long as each foundry maintains proper documentation and recordkeeping.
2.1.2 Florida
Florida also does not have an organized beneficial reuse program for industrial byproducts.
However, the Florida Department of Environmental Protection (FL DEP) provides some
information on beneficial reuse on their website.4 FL DEP acknowledges receiving numerous
requests to use various solid waste materials as products or raw materials in the manufacturing of
other products rather than disposing of the byproducts in landfills.5 Some of the proposed
byproducts include recovered screen material from processing construction and demolition
debris, coal ash from power plants, and wood ash.
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Program Structure
According to FL DEP, beneficial reuse requests are generally handled on a case-by-case basis.
A contact at FL DEP explained that staff conducting the case-by-case reviews may use Florida's
statutory industrial byproducts exemption as a guiding principle when reviewing beneficial reuse
proposals. The industrial waste proposed for reuse does not need to meet the exemption
requirements outlined in Section 403.7045(l)(f). Rather, Florida developed the exemption as a
part of the Florida Air and Water Pollution Control Act. Nonetheless, the industrial byproducts
exemption provides established criteria that the FL DEP has found useful when reviewing
proposed beneficial reuse activities. The statute states that industrial byproducts are not regulated
under the Florida Air and Water Pollution Control Act if:
"1. A majority of the industrial byproducts are demonstrated to be sold, used, or
reused within 1 year.
2.	The industrial byproducts are not discharged, deposited, injected, dumped, spilled,
leaked, or placed upon any land or water so that such industrial byproducts, or any
constituent thereof, may enter other lands or be emitted into the air or discharged
into any waters, including groundwater, or otherwise enter the environment such
that a threat of contamination in excess of applicable department standards and
criteria is caused.
3.	The industrial byproducts are not hazardous wastes as defined under s. 403.703
and rules adopted under this section."
Siting/Location Restrictions
The state does not have any formal siting or location restrictions. The state might impose siting
conditions on a case-by-case basis, depending on the industrial byproduct or beneficial reuse
activity.
Level of State Review
The FL DEP collects information regarding the proposed beneficial reuse activity and industrial
byproduct from the generator and conducts a case-by-case review.
State Response
For each proposed beneficial reuse activity, the FL DEP responds in writing to the generator. If
the FL DEP approves of the reuse activity, the state's letter will officially authorize the reuse
activity and may outline conditions of reuse.
Initial Sampling and Testing
To assess whether the industrial byproduct exemption criteria are met, the state generally
requires a generator to analyze the industrial waste for contaminants and provide information
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regarding the proposed reuse activity. FL DEP staff may apply an existing set of standards that
the state developed for soil cleanup activities. In reviewing proposed beneficial reuse activities,
the FL DEP may use its Soil Cleanup Target Levels to benchmark constituents and acceptable
concentration levels. Chapter 62-777, Table II provides a listing of contaminants and
concentration limits which apply to soil cleanup projects in Florida. The FL DEP explained that
these guidelines are not used in every beneficial reuse case, but state officials may refer to them
when reviewing beneficial reuse proposals for industrial byproducts.
Ongoing Sampling. Testing, and Recordkeeping
In its authorization of beneficial reuse activities, the FL DEP may require conditions such as
ongoing sampling, testing, and recordkeeping requirements. Because the state does not have a
formal beneficial reuse program, these conditions are applied on a case-by-case basis.
Occasionally, the state may require generators to regularly test the industrial waste bound for
reuse and keep records associated with the testing and reuse activities. In other cases, the state
may not require ongoing testing and recordkeeping.
FL DEP provides some guidance documents for particular byproducts (water treatment plant
sludge, street sweepings, catch basin sediments, storm water system sediments, and recovered
screen material from construction and demolition (C&D) debris).
2.1.3 Louisiana
The Louisiana Department of Environmental Quality (LA DEQ) revised its solid waste
regulations in June 2007. One of the actions taken in the new rule text is to repeal the beneficial
reuse regulations and replace them with new language that will not require permitting for
beneficial reuse activities.6
Program Structure
In Title 33, Part IV, Subpart 1, Section 1105, the regulations outline how solid waste may be
beneficially reused. Generators must submit an application to LA DEQ before initiating
beneficial reuse of an industrial byproduct. This application must include a wide variety of
information, such as the applicant's contact information, the origin of the solid waste proposed
for beneficial reuse, the chemical and physical characteristics of the material to be beneficially
reused, and a demonstration that the end use of the material is protective of public health, safety,
and the environment. These elements of the application are reviewed on a case-by-case basis.
Siting/Location Restrictions
Louisiana's regulations do not specify siting or location restrictions for beneficial reuse
activities. However, the state will impose siting or location restrictions on a case-by-case basis if
the LA DEQ believes they are necessary.
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Level of State Review
The LA DEQ reviews the generator's application to decide whether the beneficial reuse activity
is allowable. The state reviews applications on a case-by-case basis rather than applying a set of
criteria to the proposed beneficial reuse activity.
State Response
New regulatory language states that the LA DEQ approves applications for beneficial reuse.
Once approved, the material must be handled, processed, stored, and managed in accordance
with the proposed plan outlined in the application.
Initial Sampling and Testing
The LA DEQ requires generators to provide "the chemical and physical characteristics of the
material to be beneficially used." The regulation does not provide guidelines on what
contaminants to test for or what concentration levels are acceptable.
Ongoing Sampling, Testing, and Recordkeeping
In the regulations, the LA DEQ requires generators to describe in their application how periodic
testing for quality control will be employed. The LA DEQ will impose ongoing sampling,
testing, and recordkeeping requirements on a case-by-case basis if it believes they are necessary.
In addition, the Louisiana Pulp and Paper Association (LPPA) and LA DEQ have an established
agreement on beneficial reuse of materials produced by the pulp and paper industry. Under the
proposed rule language, this agreement will be incorporated into the regulations under an
appendix. The agreement allows the pulp and paper industry to pursue pre-approved reuse
activities in lieu of submitting a beneficial reuse plan to the state (i.e., the application). The pre-
approved byproducts are wood-fired boiler ash, coal-fired boiler ash, lime and lime mud, slaker
grit, boiler gravel, wood fiber, recycled fiber, and mixtures of these materials. The pre-approved
reuse activities involving these byproducts include beneficial reuse as ingredients, raw materials,
or feedstocks in industrial processes to make products; effective substitutes for commercial
products; and land application reuses. This program is similar to Pennsylvania's General Permit
program, which addresses beneficial reuse for all industries.
2.1.4 Mississippi
The Mississippi Department of Environmental Quality (MS DEQ) adopted a regulatory program
in June 2005 called "Beneficial Use of Nonhazardous Solid Waste."
Program Structure
According to the regulations, a generator, distributor or supplier, or end user of a byproduct must
submit a Beneficial Use Determination (BUD) application to the state. The applicant must prove
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that the material and its beneficial use are safe, suitable (chemically and physically), and
nonhazardous, and that the material is being used as a replacement of another product.
Siting Location Restrictions
MS DEQ's regulations do not specify any siting or location restrictions for beneficial reuse
activities.
Level of State Review
The Mississippi regulations include four basic categories of beneficial reuse activities: (I)
standing uses; (II) construction use (highways, roads); (III) soil amendments (nutrients, etc.); and
(IV) miscellaneous/other. MS DEQ reviews the
application and then issues a BUD. If approved,
beneficial use is a conditional exclusion, which means
the material is excluded as solid waste and is instead
considered a product. For potential beneficial reuses
that do not have a demonstrated reuse and/or market,
called unproven uses, MS DEQ requires a site-specific
demonstration project, which can take as long as three
years. For engineered construction or other civil
engineering uses, a professional engineer (PE) must
certify that the byproduct has physical or chemical properties suitable for the proposed use. For
soil amendment uses, the Mississippi Department of Agriculture and Commerce must also
certify the proposed reuse.
State Response
The MS DEQ responds to the applicant in writing with their determination. If the application is
consistent with Mississippi's regulations, then the MS DEQ issues a BUD to the applicant, and
the reuse activity may commence. The MS DEQ also notifies the applicant in writing if the
agency denies the applicant's proposed reuse activity.
Initial Sampling and Testing
Industrial byproducts that fall within Categories II - IV require initial sampling and testing as
part of the application process. The regulations contain constituents and concentration limits that
must be met in order for a byproduct to qualify for reuse.
Ongoing Sampling, Testing, and Recordkeeping
Mississippi's program also requires an annual report from each registrant that has received a
BUD. The annual report must include the quantity of byproduct used within the past year, a
physical and chemical characterization of the approved byproduct, and any other information
that the MS DEQ specified as a reporting requirement within the BUD.
"Standing Use Determination" means a
Beneficial Use Determination approved by
MS DEQ for a specific by-product/use
combination or for a category of by-
product/use combinations that are contained
or conducted in such a manner that does
not offer potential for adverse environmental
or public health impacts. Uses with standing
determinations do not require a use specific
application nor review and approval by the
Department under these regulations.
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2.1.5 Texas
Texas does not have a general regulatory program to encourage beneficial reuse of byproducts.
However, the state reviews and approves beneficial reuse activities for various byproducts
through its industrial waste recycling program.7 As discussed in more detail in relevant parts of
Section 3, Texas regulations and specifications also specifically address beneficial reuse of
asphalt shingles and coal combustion products (CCPs).
Program Structure
Texas conducts case-by-case reviews of proposed beneficial reuse activities. The generator of the
industrial byproduct and the proposed end user of the byproduct must submit notification forms
to the Texas Commission on Environmental Quality (TCEQ) for their review. These forms
disclose several facts about the beneficial reuse activity. The generator's form must include the
location of the reuse activity, the recycling method (i.e., feedstock/ingredient, road base,
alternative daily cover, soil amendment), and supplemental information to completely describe
the process. The end user's form must include the type of material to be recycled, how the
byproduct will be stored, how the material will be recycled, and the purpose/function the reused
material serves.
Siting/Location Restrictions
The TCEQ does impose siting or location restrictions on industrial waste recycling activities.
These restrictions are stated in regulation and on the end user's notification form. The TCEQ
states that: "Materials which are recycled remain subject to the General Prohibitions of 30 TAC
335.4. As described in this Section, recyclable materials may not (1) threaten the waters of the
state, or (2) cause a nuisance, or (3) endanger human health and/or welfare."
Level of State Review
Once the state receives the notification forms from the generator and the end user, TCEQ closely
reviews the information. The state must confirm that each constituent in the reused material must
also normally be found in the raw material it is replacing. If not, the byproduct must not present
an increased risk to human health, the environment, or waters of the state.
State Response
The TCEQ responds to the generator and end user after completing their review of the proposed
reuse activity. If necessary, in their response letter, the TCEQ may tell the generator and end user
that they need a permit before initiating the reuse activity.
Initial Sampling and Testing
As required by the generator's notification form, the generator must fully describe the recycled
material. This would include a characterization of the constituents found in the industrial
byproduct proposed for reuse.
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Ongoing Sampling. Testing, and Recordkeeping
The TCEQ does not require generators or end users to conduct ongoing sampling and testing of
the recycled material. In addition, the state does not impose ongoing recordkeeping requirements
on the generators or end users.
In addition to the industrial waste recycling program, since 1988, TCEQ has implemented a
program called Resource Exchange Network for Eliminating Waste (RENEW), which is a
marketing channel for industries, business, and governmental units that want to sell surplus
materials, byproducts, and wastes to users who will reclaim or reuse them. TCEQ acts as a
facilitator, not a regulator; there are no regulations for this program. Twice a year, TCEQ
publishes a catalog, which is mailed out to subscribers (membership is free) and posts the catalog
on the TCEQ website, which contains links for the following: materials available, materials
wanted, and waste management services and products. The website also provides information
about reducing waste, increasing business productivity, determining if industrial or hazardous
waste can be reused or recycled, and participating in the RENEW program.
2.1.6 Summary
Table 2-1 summarizes each state's beneficial reuse program for industrial byproducts.
Table 2-1: Summary of Gulf Coast State Regulatory Program Features
State
Program
Structure
Siting or
Location
Restrictions
State
Response
Initial
Sampling
and/or
Testing
Ongoing
Sampling,
Testing,
Recordkeeping
Alabama
Waste
Classification
(Foundry Sand
only)
Yes
(Foundry Sand
only)
Yes
(Foundry
Sand only)
Yes
(Foundry Sand
only)
Yes
(Foundry Sand
only)
Florida
Case-by-Case
Reviews
Not mandated
Yes
Not mandated
Not mandated
Louisiana
Case-by-Case
Reviews
Not mandated
Yes
Yes
Recordkeeping
Mississippi
Waste
Classification
Not mandated
Yes
Yes
Yes
Texas
(CCPs have
separate
regulatory
program)
Case-by-Case
Reviews
Yes
Yes
Yes
Not mandated
2.2 Federal Programs Encouraging State Program Improvements
Several federal programs are encouraging beneficial reuse of byproducts and, in many cases,
bringing together federal and state governments with industry stakeholders to address the issue.
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•	EPA's Sector Strategies Program, with cooperation from industries in numerous sectors, is
pushing to increase reuse of byproducts.
•	EPA has worked with several federal agencies to develop and implement Environmentally
Preferable Purchasing (EPP) guidelines, which help procurement officials consider the
environmental aspects of purchasing materials and equipment, including those that
incorporate beneficial reuse in the manufacturing process. The federal government
Comprehensive Procurement Guidelines encourage the use of concrete containing fly ash,
blast furnace slag, and other CCPs.
•	EPA's Resource Conservation Challenge (RCC) is a national effort to conserve natural
resources and energy by managing materials more efficiently and has, as one of its four main
goals, the recycling of industrial materials. The program's Industrial Materials Recycling
effort focuses on three industrial non-hazardous wastes: coal combustion products,
construction and demolition byproducts, and foundry sands.
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3.0 Sector Traits and Trends, Drivers and Barriers in
Current Beneficial Reuse
Beneficial reuse within and across sectors is shaped
by certain factors, deemed drivers and barriers in this
paper:
o Drivers are market characteristics, regulations,
policies, guidance, and other factors that lead or
can lead to increased beneficial reuse of
byproducts.
o Barriers are market characteristics, regulations,
policies, and other factors that inhibit or
discourage beneficial reuse of byproducts.
An understanding of industry characteristics and
beneficial reuse opportunities is essential to fully
understand what factors are encouraging or
discouraging reuse within or across sectors. Sections
3.1 through 3.9 discuss each industry's geographic and size characteristics, industrial processes,
beneficial reuse traits and trends (where data are available), and drivers and barriers to reuse.
3.1 Cement Manufacturing (NAICS 327310)
The cement production process begins with finely ground raw materials such as limestone, clay,
shale, sand and may include beneficial reuse materials such as fly ash, bottom ash, blast furnace
slag, and steel slag that substitute for virgin materials. Raw materials are fed into the high end of
a cylindrical rotary cement kiln either in solid form in a dry process kiln or as a slurry in a wet
process kiln. Conventional fuels such as coal, petroleum coke, and natural gas are fed into the
low [opposite] end of the rotary kiln. Beneficial reuse also takes place in the form of using scrap
tires or liquid waste as alternative fuels in the cement production process. The rotary kiln is
heated to temperatures in excess of 2,700 degrees Fahrenheit, causing the raw materials to
calcine into cement clinker. Cement clinker is the principal raw material in Portland cement,
which also includes gypsum and other solid materials. A byproduct of the cement production
process is cement kiln dust (CKD), which is created when clinker is formed in the rotary kiln and
is exhausted from the kiln with the exhaust gas. CKD is captured from the exhaust gas with
electrostatic and bag filters and is generally recycled back into the rotary kiln as a raw material.
A more detailed study of the alternative fuels and raw materials is under development at EPA in
the Office of Policy, Economics, and Innovation and a report is expected in Spring, 2008.

Chapter 3.0 Sector Traits and Trends,

Drivers and Barriers in Current

Beneficial Reuse
3.1
Cement Manufacturing
CM
Chemical Manufacturing
3.3
Construction and Demolition
3.4
Electric Power Generation at Fossil Fuel

Plants
3.5
Forest Products: Pulp, Paper, and

Paperboards
3.6
Iron and Steel Mills
3.7
Metal Casting Sector: Foundries
3.8
Oil and Gas Extraction
3.9
Petroleum Refining
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3.1.1 Beneficial Use Traits and Trends in the Cement Sector
As shown in Table 3-1, the cement industry in the Gulf Coast states is comprised of 24 Portland
cement manufacturing facilities. While this is a small number of facilities, these facilities still
present a significant opportunity for the beneficial reuse of manufacturing byproducts within the
cement industry and reuse of byproducts from other industry sectors in the cement
manufacturing process, whether as raw materials or as fuels.
Table 3-1: Number of Cement Manufacturing Facilities in the Gulf Coast States as Characterized by
Cement America's 2005 North American Cement Directory8
State
Cement Manufacturing Facilities
Alabama
5
Arkansas*
1
Florida
6
Louisiana
0
Mississippi
1
Texas
11
Total
24
* Arkansas is included in the table because one facility is located within 100 miles of Shreveport, LA.
The discussion of traits and trends in the Gulf Coast states' cement industry is divided into three
parts to address the issues most relevant to the sector:
o Cement kiln dust.
o Alternative raw materials from other industries used in the cement production process
(including coal combustion products (CCP) and iron and steel byproducts).
o Alternative fuels from other industries used in the cement production process.
Cement Kiln Dust (CKD)
The principal byproduct of cement clinker production is cement kiln dust. The amount of CKD
generated at a facility is a function of the amount of cement clinker produced, which is trending
up according to U.S. Geological Survey (USGS) data. According to the USGS, U.S. cement
clinker production has steadily increased from 1995 through 2005: 69.98 million metric tons
(MMT) in 1995; 77.337 MMT in 1999; 86.66 MMT in 2004; and 87.405 MMT in 2005.9'10
Figure 3-1 presents 2005 cement clinker production data obtained from Cement Americas 2005
North American Cement Directory for states in the Gulf Coast region. There is evidence that the
correlation between CKD generation rates and clinker generation rates is changing. Cement
facilities are using technology and operating practices to minimize generation and/or reuse CKD
on-site.
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Figure 3-1: Cement Clinker Production Gulf State Region (2005)11
Texas (11 plants)
Florida (6 plants)
Alabama (5 plants)
Arkansas (1 plant)
Mississippi (1 plant)
0	2	4	6	8	10	12
Production (million metric tons - MMT)
* Arkansas is included in the table because one facility is located within 100 miles of
Shreveport, Louisiana. There are no facilities in the scope of interest in Louisiana.
Cement manufacturing plants have three options for CKD generated during the cement
production process: (1) recycle CKD as a raw material back in the cement production process,
(2) landfill CKD (either on-site or off-site), or (3) make CKD available for beneficial reuse by
other sectors.
Depending on process conditions and market conditions, individual cement plants can avoid
having to landfill CKD either by increasing the amount of CKD reused on site and/or by
providing CKD to other sectors for beneficial reuse.
Increasing reuse of CKD on site is a result of changes to cement manufacturing operations. As
shown in Figure 3-1, the amount of CKD recycled onsite in cement production is trending up
according to USGS data, which indicate the amount of CKD being recycled increased almost 80
percent from 1999 to 2005. USGS has reported, based on informal data from cement
manufacturers, that 60 to 70 percent of CKD generated at is reused on site, corresponding to 7 to
8 MMT of the 12 to 15 MMT per year CKD generated; 10 percent of CKD generated is used for
other purposes; and the remainder is landfilled.12 According to PC A data, the cement sector
recycles on site approximately 75 percent of the CKD generated.13
Historically, most CKD produced by cement kilns in the U.S. is recycled directly back into the
cement kiln; nearly 8 million tons/year (75%), which reduces the need for limestone and
conserves energy.14 Data reported by the PC A indicate the amount of CKD landfilled has
decreased from 2.6 MMT in 1990 to 1.25 MMT in 2006 (after reaching a high of 3.25 MMT tons
in 1995). In 1990, U.S. cement kilns landfilled 60 kilograms of CKD per metric ton of cement
clinker produced; by 2006, the amount landfilled decreased to less than 15 kilograms of CKD per
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
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metric ton of cement clinker produced.15 This significant reduction in the amount of CKD
landfilled per ton of cement clinker produced is attributable to the increased amount of CKD
reused in cement kilns and to the increased beneficial use of CKD by other sectors.
This reduction resulting in part from the U.S. cement industry adopting a voluntary 60 percent
reduction target (from a 1990 baseline) in the amount of CKD disposed per ton of clinker
produced by 2020.16 According to 2006 data published by the PC A, the cement sector has
already exceeding the reduction target (73 percent from the 1990 baseline).
Figure 3-2: Cement Kiln Dust Use in Clinker and
Portland Cement Production in the U.S.17
900 	
800 		
ซ 700	_ 	
c
-2 600 		 —
1 500	_				 H —
| 400 M _	 			
8 300 		 	 			 	 —
3
ฃ 200 		 	 	 	 	 	 —
100		 	 	 	 	 	 —
0 -|—		i—	—i—	—i—	—i—	—i—		i—		
1999 2000 2001 2002 2003 2004 2005
~ Clinker ฆ Cement |
As discussed in the case study in the text box, a
cement plant (one of many) is actually providing
CKD to other industry sectors from both ongoing
generation and from an onsite CKD stockpile. This
dual approach could potentially increase the amount
of CKD available for beneficial use. The amount of
CKD potentially available from onsite stockpiles at
cement plants will, of course, depend on site-specific
and market conditions. However, PC A reports that in
2006, over 1.1 million metric tons of CKD were
removed from the kiln systems and used for soil
stabilization and consolidation, waste stabilization
and solidification, and mine reclamation.18
Case Study: CKD Available for Beneficial
Reuse In Other Manufacturing Sectors
PCA reported that the St. Lawrence Cement
plant in Hagerstown, Maryland, is providing
CKD for use as an agricultural lime material
and as a material for stabilization of wastes
generated by other industrial facilities. CKD
from the St. Lawrence Cement plant is also
being blended into specialty cement sold in
the local construction market. As a result,
the plant is beneficially reusing 100 percent
of the CKD it is generating and is now also
removing the CKD from its existing CKD
stockpile to support these beneficial uses
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Alternative Raw Materials from Other Industries Used in the Cement Industry
In addition to CKD, alternative raw materials used in cement production include: (1) coal
combustion products (including fly ash and bottom ash); and (2) iron and steel byproducts
(including ground granulated blast furnace slag (GGBFS), steel slag, other blast furnace slag, and
other types of slag). Slag is being reused as a raw material at five plants in Texas, three plants in
Alabama, and three plants in Florida (3).19 Fly ash and/or bottom ash are being reused as raw
material at two plants in Texas, four plants in Alabama, and seven plants in Florida (7).20 These
industrial byproducts may be introduced as raw materials into cement kilns or may be blended
with clinker produced by cement kilns.
Coal Combustion Products
The amount of fly ash and bottom ash generated from coal-fired electric power plants has been
increasing by several percent per year over the past 10 years because of increased coal utilization
in electric power production and as a function of changes in the quality of the coal being used.
In fact, the amount of fly ash generated increased from 49.2 million metric tons (MMT) in 1995
to 64.3 MMT in 2004. Of these amounts, 25 percent (12.3 MMT) was reused in all industry
sectors in 1995, increasing to 40 percent (25.5 MMT) reused in 2004.
The amount of bottom ash generated by coal-fired power plants increased from 13.2 MMT in
1995, to 15.6 MMT in 2004 (after reaching 18 MMT in 2002). Of these amounts, 35 percent (4.6
MMT) was reused in all industry sectors in 1995, increasing to 47 percent (7.4 MMT) in 2004.
Fly ash generated from coal combustion is used as a raw material in cement kilns and as an
additive to the cement clinker. According to USGS data, most fly ash is used as a raw material in
cement production and bottom ash is only used as a raw material in cement production (not as an
additive to the cement clinker).
Figure 3-3 presents data from the American Coal Ash Association on coal combustion products
use in clinker and Portland cement production. As evident the graph, the use of CCPs as raw
materials in clinker and Portland cement production has increased substantially, from 1,113
thousand metric tons in 2001 to 3,824 thousand metric tons in 2005. Fly ash comprised the most
significant portion of this CCP beneficial reuse from 2001 through 2005.
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Figure 3-3: Coal Combustion Products Used in Producing
Clinker and Portland Cement in the U.S.21
4,000
2001	2002	2003	2004	2005
ฆ Fly ash ~ Bottom ash ~ FGD Gypsum ฆ Boiler Slag
National data from PC A for 2006 indicated that, of the 115 operating Portland cement plants
reporting in the PC A report, 55 plants used blast furnace or iron slag as a raw material and more
than 50 plants used fly ash or bottom ash from electric power plants.22
The potential for beneficial reuse of fly ash and bottom ash in cement production is partly a
function of the amount of cement clinker produced, which is trending up according to USGS
data. As previously noted, total cement clinker production has increased from approximately
69.98 MMT in 1995 to 87.41 MMT in 2005.23 24 However, the amount of bottom ash and fly ash
being beneficially reused in cement production has actually been increasing faster than the
amount of cement clinker produced. Clinker production increased by 13 percent from 1999 to
2005, while the amount of fly ash used in cement production increased 93 percent during this
period, and the amount of other ash, including bottom ash, increased 59 percent over this period.
Iron and Steel Sector Byproducts
Iron and steel byproducts include GGBFS, steel slag, other blast furnace slag, and other types of
slag. The cement production process can use iron and steel byproducts as raw materials in
cement kilns and as additives to cement clinker. USGS data for 2005 indicate that:
o Steel slag is only used as raw material in cement clinker production.
o Ground and unground granulated blast furnace slag are used as raw materials in cement
clinker production and as an ingredient in Portland cement (post-kiln production).
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o Other blast furnace slag is only used as a raw material in cement clinker production.
o Other slags (a category not further disaggregated in the USGS data) are used as raw materials
and additives in the cement production process.25
USGS trend data for GGBFS, other blast furnace slag, steel slag, and other slag are shown in
Figure 3-4 and Table 3-2. All of the byproducts, except steel slag, show a marked increase in
beneficial reuse from 1999 to 2005. Steel slag shows an 11 percent decrease during the same
time period.
According to USGS data, the total amount of iron and steel sector byproducts beneficially reused
in cement production (of which GGBFS is a subset) was relatively flat between 1999 and 2004,
at approximately 1.1 MMT per year, but increased to approximately 1.5 MMT per year in 2005 -
an approximate 40 percent increase in one year. However, based on the discussion of data in the
USGS Minerals Yearbook, these published USGS data may not be fully representative of iron
and steel sector byproduct utilization in cement production. The cement clinker production data
and slag utilization data reported by the USGS do not include the direct use of GGBFS as a
component of "slag cement." Slag cement does not contain cement clinker and represents a small
fraction of total cement production, according to USGS.26 USGS reported that some slag used to
manufacture GGBFS for use as a component of slag cement is imported, and some is
domestically produced. According to USGS, there are two pathways by which GGBFS is used:
15 percent of the total GGBFS sold in 2005 was used by cement producers and the remaining 85
percent was sold as a "substitute" for Portland Cement as "slag cement."27
Figure 3-4: Utilization of Iron and Steel Sector Slag in
Cement Clinker Production in the U.S. (1999-2005)28
(/)
c
o
o
E
~G
C
a
at
3
O
1,200
1,000
800
600
400
200
1999	2000
ฆ Steel slag
~ Other slags
2001	2002	2003	2004
~	Other blast furnace slag
~	Granulated blast furnace slag
2005
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Table 3-2: Utilization of Fly Ash and Blast Furnace Slag in Cement Clinker and Portland Cement
Production (1999 - 2005)29
Raw Material
Thousand Metric Tons
1999
2000
2001
2002
2003
2004
2005
Fly Ash [for Portland Cement
Production]
85
88
70
64
39
77
153
Fly Ash [for Cement Clinker
Production]
1,521
1,679
1,600
1,960
2,250
2,890
2,950
Granulated Blast Furnace
Slag [Portland Cement
Production]
349
303
300
369
333
345
521
Granulated Blast Furnace
Slag [Cement Clinker
Production]
-
-
-
60
17
104
144
Total
434
391
370
433
372
422
673
Historically, the Mid-Atlantic and North Central states have reused most iron and steel slag in
the vicinity of iron and steel mills. In 2001, the last year USGS published these data, 87 percent
of the blast furnace slag reused was reused in these states with the remaining 13 percent of the
material used in the South (Alabama, Kentucky, and Mississippi) and West (California and
Utah). This is a function of the material transportation costs. Approximately 80 percent of the
iron and steel slag reused in 2001 was transported by truck.30
Alternative Fuels from Other Industries Used in the Cement Industry
Historically, cement plants have used conventional fossil fuels (coal, petroleum coke, fuel oil,
natural gas) in cement kilns. In 2006, according to data in the U.S. and Canadian Labor-Energy
Input Survey published by the Portland Cement Association, U.S. cement plant energy
consumption consisted of 76 percent coal and petroleum coke, 9 percent waste (including scrap
tires and various forms of liquid and solid waste) 3 percent natural gas, 1 percent petroleum
products, and 11 percent electricity (from operating machinery, etc.). One apparent trend
regarding fuel use in cement production is that alternative fuel use in cement kilns has increased
substantially over the past 10 years. These alternative fuels include waste oils, hazardous waste,
solid waste, wood waste/waste paper, and scrap tires.31
In 2006, according to the U.S. and Canadian Labor-Energy Input Survey, 65 of 97 cement plants
included in the survey reported using alternative waste fuels (with some plants reporting use of
more than one type of alternative waste fuel). The use of alternative fuels was distributed as: 48
plants using scrap tires; 16 plants using waste oil; 10 plants using solvents; 25 plants using solid
waste; and 15 plants using other unspecified types of waste. The 65 plants reporting alternative
waste fuel use in 2006 represents an increase from the 54 cement plants reporting alternative
waste fuel use in 2000.32 In 2007, PCA reported that scrap tires are being reused as fuel at six
plants in Texas, three plants in Alabama, and two plants in Florida.33
USGS reports data on the utilization of "solid waste" (other than scrap tires) and "liquid waste"
(including waste oils and hazardous waste) in cement kilns but does not disaggregate these data
by the industry sector(s) generating the waste. Therefore, solid and liquid wastes may include
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industrial wastes generated from sectors beyond the focus of this report (e.g., post-consumer
waste).
Utilization of solid waste (other than scrap tires) in cement kilns is variable but still relatively
low: 90,000 metric tons in 1993; 74,000 metric tons in 1994; 317,000 metric tons in 2003; and
125,000 metric tons in 2004. Several cement plants reported using wood waste and/or scrap
paper/cardboard as alternative fuel; but no trend data were available on the utilization of these
alternative fuels. At a July 2005 EPA/PCA Workshop, one cement plant in California and one in
Michigan were identified as using wood waste from forest products as a supplemental fuel. One
cement plant in Iowa reported using scrap paper and cardboard waste as a supplemental fuel.34
Liquid waste utilization in cement kilns shows a variable but increasing trend from
approximately 745 million liters in 1993 to approximately 999 million liters in 2004.35'36USGS
reported that approximately 1 billion liters (approximately 900,000 metric tons) of liquid waste
were used as alternative fuels in cement kilns in 2004, while approximately 1.5 billion liters of
liquid waste were used in cement kilns in 2005.
The chemical, petrochemical, and petroleum refining industries are significant sectors in the Gulf
Coast region. These sectors generate a significant quantity of liquid organic waste, which could
be used as alternative fuels in cement kilns. Increased utilization of alternative fuels from these
sectors in the Gulf Coast region could replace conventional fuels and decrease the amounts of
coal, petroleum coke, and fuel oil used in cement kilns in the Gulf Coast region.
Historically, cement plants have not used significant quantities of construction and demolition
(C&D) debris material in cement clinker production or Portland cement production. The
presence of large quantities of C&D debris will continue to be an ongoing issue, however, as
hurricanes and tropical storms strike the Gulf Coast in the future. These events create significant
amounts of C&D debris, which could be used as alternative fuels in cement kilns. Depending on
circumstances, C&D debris could be retrieved from landfills for use in the kilns. Such debris
would need to be segregated and processed prior to utilization in cement kilns to provide
material of consistent quality (e.g., British thermal unit (BTU) content). Transportation issues
would need to be addressed in such a reuse scenario, because as shown in Table 2-1, there are
relatively few cement plants in the Gulf Coast states.
3.1.2 Beneficial Reuse Drivers and Barriers in the Cement Sector
As discussed in Section 3.2.1, the cement sector has implemented a number of measures that
have led to successful beneficial reuse of byproducts from other industrial sectors, as well as
tremendous beneficial reuse of CKD in other sectors. The cement production process can
beneficially reuse a number of byproducts from other industries. However, the materials chosen
for this analysis are produced in the greatest volumes and have the greatest potentials for
beneficial reuse. Table 3-3 lists the cement industry byproducts selected for analysis in this
paper, along with the rationale for their selection. The following sections describe the drivers that
have contributed to this success, barriers that the cement sector has addressed in order to increase
cross-sector beneficial reuse, and barriers that the industry will need to address as facilities
increase their beneficial reuse of byproducts, whether as raw materials or as fuels in cement
kilns.
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Table 3-3: Byproducts from Cement Manufacturing (NAICS: 327310) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
Cement Kiln Dust
(CKD)
•	Waste solidification/soil stabilization
•	Hydraulic barrier in a landfill/liner cover
•	Land application as agricultural soil amendment
•	Flowable fill (also called Controlled Low-
Strength Material), is a mixture of Portland
cement, coal combustion fly ash, sand, and
water that flows as a liquid and sets as a solid
•	Mineral filler in hot-mix asphalt (HMA) paving
•	Mine reclamation37
•	Fertilizer manufacturing
•	Road construction sub base
•	Waste treatment
Reuses within same sector:
•	CKD can be recycled on site as a raw material
for cement clinker production (raw material feed
to cement kiln)
•	Replacement for Portland cement (in concrete
block manufacturing)
•	Replacement for Portland cement (in redi-mix
concrete)
•	Produced in quantities significant
enough for beneficial reuse
•	Potential for more reuse to occur:
748,000 metric tons used in
production of cement and clinker in
200538 and about 2 MMT was sent
to landfills in 2005 (vs. 3.25 MMT in
1995);39 40 In 2006 about 1.1 MMT
CKD was used for off-site beneficial
uses including soil stabilization and
mine reclamation and about 1.3
MMT CKD was landfilled.41 75
percent of CKD generated is
recycled/reused onsite42
•	Can be reused across sectors for
nonfuel purposes
Byproducts from Other Sectors Used in Cement Manufacturing
From Construction and Demolition
Wood Waste
• Note here that C&D debris is different from
wood waste under Forest Products
See C&D for rationale
From Electric Power Generation
Fly Ash (CCP)
•	Raw material for Portland cement production
•	Portland cement additive
See Electric Power Generation for
rationale
Bottom Ash (CCP)
• Raw material for Portland cement production
See Electric Power Generation for
rationale
FGD Gypsum
•	Raw material for Portland cement production
•	Portland cement additive43
See Electric Power Generation for
rationale
From Forest Products
Causticizing
Residue
• Raw material for Portland cement production
See Forest Products for rationale
Wood Waste
• Alternative fuel for Portland cement production
See Forest Products for rationale
From Iron and Steel Mills
Granulated Blast
Furnace Slag
•	Raw material for Portland cement production
•	Portland cement additive
See Iron and Steel Production for
rationale
Other Blast
Furnace Slag
• Raw material for Portland cement production
See Iron and Steel Production for
rationale
Steel Slag
• Raw material for Portland cement production
See Iron and Steel Production for
rationale
EAF Dust/Sludge
from EAF Gas
Cleaning &
Collection
• Raw material for Portland cement production
See Iron and Steel Production for
rationale
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Table 3-3: Byproducts from Cement Manufacturing (NAICS: 327310) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
From Metal Casting - Foundries
Foundry Sand
• Raw material for Portland cement production
See Metal Casting for rationale
From Petroleum Refining
"Sulfidic caustics"
• Alternative fuel for Portland cement production
See Petroleum Refining for rationale
Other byproducts from petroleum refining are beneficially reused by the cement sector but do not meet criteria for
selection.


3.1.2.1 Cement Kiln Dust
Economic/Market Drivers and Barriers
Organizations such as PCA, World Business Council for Sustainable Development (WBCSD),
the Cement Sustainability Initiative (CSI), and the EPA Sector Strategies Program are working in
a collaborative manner to educate generators and users of CKD about markets and possibilities
for reuse. Numerous studies have been performed on the physical, chemical, and engineering
properties of CKD and its suitability for reuse in road construction, flowable fill, soil
amendment, and other reuses. Therefore, construction managers are more likely to accept use of
the material. Indeed, as mentioned in Section 3.2.1, the cement industry has far exceeded its goal
for reduced landfill disposal of CKD.
On a more regional basis, there are challenges to cross-sector beneficial reuse in the Gulf Coast
states. Of the 115 cement plants in the U.S., most are concentrated in the Eastern, Midwestern,
and Pacific Coast States, which could present a barrier to cross-sector beneficial reuse in the Gulf
Coast states. Twenty percent of U.S. cement kilns are in the Gulf Coast states, corresponding to
approximately 20 percent of U.S. cement clinker production capacity. This limits the quantities
of CKD generated by cement kilns available for beneficial reuse in the Gulf Coast region.
According to the PCA, cement plants currently reuse approximately 75 percent of CKD
generated on site as raw material feed for cement clinker production (USGS estimates between
60 to 70 percent), and the amount of CKD landfilled per ton of cement clinker produced has been
trending down. Increased recycling of CKD on site limits the availability of CKD for offsite
markets. Data on the amount of CKD generated by the cement kilns in the Gulf Coast states and
data concerning the amount of CKD being beneficially used in these states are not available due
to protection of confidential and proprietary business information. National data may not be
representative of CKD generation and use in the Gulf Coast.
Regulatory/Programmatic Drivers and Barriers
CKD disposal is largely controlled by state regulations and, as a result, the wide variation in state
regulatory requirements may present barriers to exchange of materials across state lines. Certain
states, such as Texas, allow cement plants to dispose of CKD on their own property without a
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state permit. Other states, such as Alabama, regulate CKD under generic solid waste rules;
therefore, any landfill in the state could accept CKD for disposal. These low regulatory barriers
for disposal lower the economic incentive for offsite beneficial reuse of the CKD. However,
offsite landfill disposal costs would still be a driver for cement plants to increase the amount of
CKD recycled on site as a raw material into the cement kilns.
Environmental Effects
Certain cement kilns, including cement kilns in Texas, burn hazardous waste as supplemental
fuel. This practice potentially increases the analytical testing requirements for offsite beneficial
use of the CKD. Otherwise, CKD is considered a low-hazard material that is not regulated as a
RCRA hazardous waste. Requirements to obtain and maintain a hazardous waste combustor
(HWC) Maximum Achievable Control Technology (MACT) permit include monitoring,
reporting, and recordkeeping requirements and periodic comprehensive performance testing of
the cement kiln and byproduct materials.
3.1.2.2 Alternative Fuels and Raw Materials from Other Industries Used in
the Cement Industry
Economic/Market Drivers and Barriers
Development of innovative, and proprietary, technologies can lower barriers to beneficial reuse
for the technology owners, but may create barriers to beneficial reuse by other facilities. Cement
kilns in Texas are using patented proprietary technologies (e.g., CemStar™, developed by TXI)
to beneficially reuse electric arc furnace (EAF) steel slag and fly ash in their cement products.
44'45 TXI discovered, and patented in the CemStar™ process, that the steel slag does not require
fine crushing and grinding in order to be used as a raw material in the cement kilns. The use of
only coarse crushing of the slag removed a significant cost barrier to increased utilization of steel
slag as a raw material in cement kilns.46 The TXI cement plant in Midlothian, Texas, is using
approximately 90,000 tons per year of steel slag as a raw material for clinker production and has
the capacity to use 135,000 tons per year.47 USGS reported that the CemStar™ technology can
increase cement clinker production by up to 10 percent with a commensurate reduction in cement
plant CO2 emissions.48
The fact that the CemStar™ technology is patented and proprietary has been a barrier to other
cement companies adopting the technology. Other users of the technology are required to pay a
licensing fee to TXI based on the amount of byproduct used in the cement production process.
However, as a representative of the National Slag Association (NSA) noted, cement companies
are typically reluctant to report production data directly to a competitor. Recent establishment of
a third-party licensing mechanism may lessen this barrier.49
A cement plant in Florida is testing a proprietary technology to use processed fly ash material
from a coal-fired power plant in cement production. The potential capacity is 60,000 tons per
year of processed fly ash material.50 This technology is potential transferable to other cement
kilns located in the Gulf Coast region and elsewhere, which could significantly drive beneficial
reuse.
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Education and research are critical to increasing beneficial reuse and developing technologies to
address the issue. Organizations such as PCA, WBCSD, CSI, and EPA's Sector Strategies
Division are working in a collaborative manner to educate generators of materials about markets
and possibilities for beneficial reuse in cement production. Beneficial use of fly ash, bottom ash,
blast furnace slag, steel slag, and other types of slag in cement production have been
demonstrated and process test data for these beneficial use applications are available. The
availability of these data can lower barriers for entry into beneficial reuse.
Finally, byproduct quantities can drive or inhibit beneficial reuse. Cement kilns are "high
throughput," continuous operations. From an economic/market perspective, cement plants are
most interested in byproduct generators that can supply a large quantity of material of consistent
quality over an extended period (e.g., a steel mill or a coal-fired power plant), rather than
material generated on an intermittent basis or in smaller quantities. Cement kilns may use
quantities of material on the order of 20,000 cubic yards per year. However, certain beneficial
use materials (e.g., foundry sand) are generated in relatively small quantities by a relatively large
number of generators, and the quality of the material varies by generator. Therefore,
consolidation and blending of the material is desirable in order to provide cement kilns with a
steady supply of consistent quality material. Some state regulations prohibit consolidation and
blending or impose expensive testing requirements for consolidated material.51 Alabama is one
state that allows such blending or mixing from multiple facilities.
Regulatory/Programmatic Drivers and Barriers
Amendments to the federal National Emissions Standards for Hazardous Air Pollutants
(NESHAP) for mercury that apply to the Portland cement manufacturing industry ban the use of
fly ash from utility boilers as a cement kiln raw material if the mercury content of that fly ash has
increased as a result of certain utility mercury emission controls (such as activated carbon
injection), unless a facility can demonstrate that use of the fly ash will not increase its mercury
emissions. Approximately 34 cement manufacturing facilities are currently using utility boiler fly
ash as a feedstock (71 FR 76522).52 The ban on utilization of fly ash with elevated mercury
content generated from sorbent-injection systems may limit feasibility of utilization of fly ash
from some coal-fired boilers in cement kilns. EPA indicated in the preamble to the NESHAP
Final Rule that the Agency does not believe this ban will significantly affect the ability of cement
kilns to use fly ash, for several reasons:53
o EPA does not anticipate widespread use of sorbent injection in the utility industry until 2010
or later.
o Utility boiler operators that decide to use sorbent injection have the option of collecting the
fly ash from the sorbent injection system separately from the rest of the facility fly ash (e.g.,
using Electric Power Research Institute (EPRI's) TOXECON control system).
o Technology is being developed that would allow utilities to separate the high carbon/high
mercury portion of the fly ash from the rest of the facility fly ash.
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o Cement kilns have the option of conducting testing to assess whether mercury emissions will
increase above the baseline when using fly ash generated by sorbent injection systems.
3.2 Chemical Manufacturing (NAICS 3251, 3252, 3253)
The chemical manufacturing sector is enormously complex and varied in terms of the number
and types of industrial processes, which can include manufacture of plastics, agricultural
chemicals, and organic and inorganic chemicals. However, beneficial reuse of byproducts in the
chemical manufacturing sector and from facilities in the sector is promising given the number of
facilities in the sector, their distribution throughout the Gulf Coast states and the U.S., their level
of economic output, and the types and quantities of byproducts generated throughout the
production process. Rather than provide a detailed analysis of the myriad manufacturing
processes and byproducts in the chemical manufacturing sector, this section provides economic
and environmental data on the chemical industry and a general overview of its beneficial reuse
opportunities and barriers, highlighting a specific beneficial reuse project of the Dow Chemical
Company in the Gulf Coast area.
3.2.1 Beneficial Reuse Traits and Trends in the Chemical Manufacturing Sector
The American Chemistry Council (ACC) provides useful industry descriptive statistics to
characterize the chemical manufacturing sector in the Gulf Coast States. As presented in Table 3-
4, Texas and Louisiana rank first and second in the U.S. in terms of value of output in 2006. In
comparison to other Gulf Coast states, Texas has more than four times as many establishments
and more than double the value of output. In 2006, the Gulf Coast States collectively
represented approximately 14 percent of chemical establishments in the U.S. and accounted for
approximately 29 percent of the value of output for the U.S. chemical industry.
Table 3-4: Chemical Manufacturing Industry in Gulf Coast States in 2006 as
Characterized by the American Chemistry Council54
State
Number of
Establishments
Value of Output
($ mill)
Value of Output
State Rank
Alabama
194
$ 8,557
18
Florida
548
$ 8,521
19
Louisiana
251
$ 39,912
2
Mississippi
104
$ 4,832
27
Texas
1,121
$ 90,170
1
Gulf Coast Total
2,114
$ 147,160
-
U.S. Total
15,383
$ 516,000
-
To further define the industry and maintain a manageable scope for this analysis, we focused on
three NAICS codes in the chemical manufacturing sector: Basic Chemical Manufacturing
(NAICS 3251), Resin, Synthetic Rubber, and Artificial Synthetic Fibers and Filaments (NAICS
3252), and Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing (NAICS 3253).
We excluded Pharmaceutical and Medicine Manufacturing (NAICS 3254) due to the
involvement of Food and Drug Administration (FDA) regulations and approvals, as well as
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Paints, Coatings, and Solvents (NAICS 3255), because our research showed that much of the
beneficial reuse occurring in this category is from consumers dropping off paints at collection
centers, a recycling mechanism that is outside the scope of this paper.
As shown in Table 3-5, the three NAICS codes selected for this paper comprised almost 1,000
manufacturing facilities in the chemical industry in 2004. The sheer large number of facilities in
this sector may present significant opportunities for beneficial reuse of other industries'
byproducts within the sector, as well as reuse of chemical manufacturing byproducts by other
industries. However, the wide ranging nature of chemical processes and resulting byproducts
may create challenges in terms of matching up generators and potential end users.
Table 3-5: Number of Chemical Manufacturing Facilities in Gulf Coast States as Characterized by U.S.
Census 2004 County Business Patterns55
State
Basic Chemical
Manufacturing
(NAICS 3251)
Resin, Synthetic Rubber,
and Artificial Synthetic
Fibers and Filaments
Manufacturing
(NAICS 3252)
Pesticide, Fertilizer, and
Other Agricultural
Chemical Manufacturing
(NAICS 3253)
Total
Alabama
61
20
19
100
Florida
52
31
71
154
Louisiana
98
26
19
143
Mississippi
26
19
6
51
Texas
289
112
92
493
Total
526
208
207
941
Examining hazardous waste data that are available for NAICS code 325 gives an overall view of
hazardous waste quantity and management by the chemical industry. The Hazardous Waste
Report, also known as the Biennial Report (BR), must be submitted by large quantity generators
(LQGs)56 and treatment, storage, and disposal facilities (TSDFs) every two years. These
facilities are required to provide EPA with waste generation and management information
biennially.57
According to 2005 BR data, the chemical manufacturing sector nationally manages about 6
percent of its hazardous waste by reclamation or recovery. Most of this beneficial reuse occurs
at the chemical facilities where the materials are generated, either through creation of new
manufacturing feedstock (e.g., acid regeneration, organics recovery, etc.) or through energy
recovery at the site as fuel. Some of this reused volume (approximately 1% of all hazardous
waste generated) is used in fuel blending for off-site energy recovery. Although the reuse of
these byproducts as fuel occurs primarily at chemical facilities, opportunities exist for cross-
sector fuel use as well, particularly in cement manufacturing plants. For example, the TXI
cement manufacturing facility in Midlothian, Texas, has permits to burn hazardous waste in its
wet kilns and therefore could be a recipient of byproducts from chemical manufacturers in that
58
region.
Since 2005, the Dow Chemical Company has engaged in a major beneficial reuse project in the
Gulf region. Dow's Byproduct Synergy project, co-sponsored by DOE's Industrial Technologies
Program (ITP), has examined opportunities for the reuse of nonchlorinated wastes generated at
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six of their Gulf Coast manufacturing facilities (four in Texas and two in Louisiana). Using the
byproduct synergy process developed by the U.S. Business Council for Sustainable Development
(USBCSD), Dow examined a total of 40 manufacturing processes at these facilities, each of
which produced more than 1 million pounds of non-chlorinated byproducts per year. The
Byproduct Synergy process consisted of two very important initial steps: (1) assessing the
byproducts produced and potential beneficial reuses for the byproducts as feedstocks in
manufacturing and (2) obtaining the cooperation and collaboration of end users. The project
identified six categories of potential byproduct reuse: hydrocarbons and spent solvents, sodium
hydroxide byproduct, sulfuric acid waste, Methocel waste, ortho-toluenediamine (oTDA), and
hydrogen byproduct.59
In the first phase of this long-term project, Dow and USBCSD identified opportunities to reuse
as feedstock an estimated 155 million pounds of non-chlorinated byproducts each year, resulting
in a potential annual cost savings of $15 million to Dow. They also identified beneficial reuse
opportunities that could reduce fuel use by 900,000 million BTUs (MMBtu) per year and reduce
carbon dioxide (C02) emissions by 108 million pounds per year.60
3.2.2 Beneficial Reuse Drivers and Barriers in the Chemical Manufacturing
Sector
As a very large chemical manufacturing corporation, Dow had an advantage of being able to
look for beneficial reuse opportunities within its own large and diverse corporate structure. This
factor facilitated cooperation and agreement among generators and end users within the
corporation, and mitigated concerns that Dow might have about sharing byproducts that could
reveal proprietary information about manufacturing inputs and processes. In addition, Dow has
spent considerable time and effort assessing byproducts reuse opportunities, including
anticipated return on investment. This assessment process in the pilot program certainly was a
necessary step, but one that represents a significant up-front resource investment.
Dow has the requisite resources, expertise, and internal corporate 'customer' base to successfully
implement beneficial reuse among its facilities in the Gulf region. However, this type of project
may not be directly applicable to other chemical manufacturing operations, especially small- to
medium-sized chemical companies. Smaller chemical manufacturers without multiple facilities
may not be able to find appropriate end-users. This problem could be due to a lack of
information on possible end uses, or to concerns about sharing byproducts that could reveal
proprietary information about manufacturing inputs and processes.
Small and medium-sized chemical manufacturing firms may also lack the financial resources or
expertise to be able to assess reuse opportunities for their byproducts, or to obtain the necessary
approvals for off-site transfers. These information and resource factors may be significant
barriers to increased beneficial reuse of byproducts by all but the very largest firms in the
chemical manufacturing sector.
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3.3 Construction and Demolition (NAICS 236, 23891)
Construction and demolition (C&D) byproducts (also frequently known as C&D materials) are
produced during new construction, renovation, and demolition of existing structures.61
Construction byproducts result from the building of new structures and the renovation of existing
structures while demolition byproducts results from renovation and demolition of existing
structures. Typical byproducts from both activities include asphalt shingles, concrete, wood,
gypsum wallboard, insulation, plumbing and electrical fixtures, vinyl siding, and masonry.
3.3.1 Beneficial Reuse Traits and Trends in the Construction and Demolition
Sector
We analyzed the construction and demolition industry by focusing on NAICS 236, which
includes establishments that construct buildings, and NAICS 23891, called "site preparation
contractors," which includes firms that demolish buildings. To refine the scope of the analysis,
we focused on home and commercial building construction and demolition. Transportation and
infrastructure C&D, which have processes that differ significantly from building C&D, were not
included in the analysis.
As shown in Table 3-6, there were more than 35,000 firms engaged in C&D in the Gulf Coast
states in 2004. However, construction and demolition activities take place in locations that can
vary greatly in distance from the location of company offices, which is the basis for the Census
data. Therefore, Table 3-6 is not a true representation of the locations and amount of C&D
activity, nor the locations of byproduct generation from the industry. US EPA has estimated
that, nationally, more than 135 million tons of building-related C&D debris are generated
annually.
Table 3-6: Number of Construction and Demolition Establishments in Gulf Coast States as Characterized
by U.S. Census 2004 County Business Patterns62
State
Construction of Buildings
(NAICS 236)
Site Preparation Contractors
(NAICS 23891)
Total
Alabama
2,912
466
3,378
Florida
13,495
1,772
15,267
Louisiana
2,311
349
2,660
Mississippi
1,356
301
1,657
Texas
10,580
1,621
12,201
Total
30,654
4,509
35,163
Beneficial reuse in the sector can be challenging due to the fact that when demolition occurs,
most materials are not separated, which is an essential step that must occur before beneficial
reuse can take place. Although construction materials have fewer concerns associated with
asbestos or lead-based paint, sources indicate that commingling and lack of separation are even
more prevalent during construction. Several trends in the C&D industry show that firms are
addressing this challenge and are likely to positive affecting future beneficial reuse of byproducts
generated by the sector. First, "designing for deconstruction," a concept that is becoming more
fully recognized in the industry, takes into account potential reuse of materials by ensuring that
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buildings are designed and constructed so that materials can be more easily separated when
buildings are dismantled. This type of design and construction enhances the building materials'
reuse potential, thereby lessening the need to mine, forest, and extract the materials needed to
construct buildings (such as gypsum for gypsum wallboard, trees for lumber, and petroleum for
asphalt shingles).63 Deconstruction is becoming more prevalent in the industry, and it leads to
many potential reuses of C&D materials as building materials. However, the concept does not fit
within the scope of cross-sector beneficial reuse and is therefore not discussed in detail in this
paper.
Leadership in Energy and Environmental Design (LEED) certification is another trend that can
lead to an increase of beneficial reuse in the C&D industry. The U.S. Green Building Council
(USGBC) and the LEED rating system consider material selection in construction, among other
criteria, to rate energy efficiency and environmental benefits. Since its inception in 2000, LEED
certification is creating a paradigm shift in beneficial materials use and how green construction is
perceived. In addition, USGBC is helping drive the use of building materials with less impact to
the environment, manage and reduce waste from construction, and reduce the amount of
materials needed overall.64 In fact, a study of beneficial reuse in North Central Texas concluded
that although renovating under LEED waste minimization standards cost slightly more than
traditional methods, the methods were able to divert up to 75 percent of waste by volume from
landfills.65
Closely related to LEED efforts by the USGBC, the World Green Building Council (WGBC) is
promoting green building and architecture. In this emerging field, which embraces
deconstruction and LEED certification, architecture and construction include "the practice of
creating healthier and more resource-efficient models of construction, renovation, operation,
maintenance, and demolition."66
In the U.S., there has also been a change in how C&D byproducts are perceived, and research is
ongoing to discover reuse potentials. This change was brought about through the concepts listed
above, as well as economic reasons such as decreased land availability for landfills, higher
tipping fees for C&D landfills, bans on certain materials in landfills, lower quantities of high
quality virgin products, and the ability to generate more revenue by selling byproducts to reuse
markets. These concepts are discussed in further detail in Section 3.4.2.
According to Mike Taylor, Executive Director of the National Demolition Association (NDA),
about 115 million tons of demolition debris are generated each year in the U.S. Of this total,
about 70 percent, or 80.5 million tons, is reused, according to NDA. According to NDA, 100
percent of scrap steel is being recycled, as is a large percentage of concrete as aggregate
(particularly in South Florida where concrete aggregate is said to be of poor quality) and wood
debris as a fuel supplement, sludge-drying agent, or raw material for new wood products such as
particleboard.67
Supply side trends show a steady, and perhaps even increasing, supply of byproducts from C&D.
As infrastructure is aging in the United States, it will need to be demolished and updated,
resulting in tons of potentially reusable byproducts. The Gulf Coast states present a particular
supply trend, as Hurricanes Rita and Katrina created a significant number of damaged homes and
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other buildings that required demolition. Although this seems to present the potential for
beneficial reuse of thousands of tons of building materials, most accounts indicate that buildings
were demolished and debris was swept into piles without regard for separation for potential
beneficial reuse. Some information indicates that, in EPA Region 6, some separation and reuse
were occurring, especially at landfills. As the Gulf Coast states are a hurricane-prone region,
there will be future events that might lead to similar situations. Proactive planning and
cooperation between the Federal Emergency Management Agency (FEMA) and EPA might
create an alliance that could address potential beneficial reuse of materials from such an event.
Rebuilding in the area presents opportunities for building and design with deconstruction in
mind.
Conclusions on demand trends for C&D materials can be drawn based on resources from the
Building Materials Reuse Association (BMRA) and the Construction Materials Recycling
Association's (CMRA's) www.drywallrecvcling. org. www.concreterecvcling.org, and
www.shinglerecvcling.org. As awareness of beneficial reuses for shingles, drywall, wood, and
concrete increases, demand for the byproducts will increase. Ongoing, well-organized outreach
programs at the state, regional, and local levels can contribute to such awareness. The Gulf Coast
region presents another important opportunity that could affect demand of C&D materials. In
southeast Louisiana, more than 100 square miles of marsh and wetlands that were turned into
open water by Hurricanes Katrina and Rita; as discussed in sections below, C&D materials can
be used for restoration of these areas.68
One additional local factor that can affect the supply and demand for wood byproducts is the
proliferation of pests that can infest building materials. For example, the Formosan termite
infests wood in the Deep South, limiting its reuse outside of the area for fear of spreading
infestation. This factor encourages local reuse of wood byproducts from C&D, which will most
likely occur as combustion (i.e., C&D materials will be used as a fuel source) to curb spread of
the infestation.
3.3.2 Beneficial Reuse Drivers and Barriers in the Construction and Demolition
Sector
Table 3-7 lists the C&D byproducts selected for analysis in this paper, along with the rationale
for their selection. As displayed in the table, various organizations are pursuing a number of
creative beneficial reuse of C&D byproducts, and C&D firms are utilizing byproducts from
foundries and iron and steel mills for fill and concrete made at construction sites.
As described in Section 3.4.1, the construction and demolition industry has seen some growth in
levels of beneficial reuse, but still faces a number of challenges in cross-sector beneficial reuse.
Several industries have found innovative uses for C&D byproducts and byproducts such as
foundry sands and slag have been successfully used in C&D, mostly for site preparation
activities such as fill and ready-mix concrete. The following sections describe the drivers that
have contributed to successful beneficial reuse of C&D byproducts as raw materials, and
sometimes fuel, in other industrial sectors. We also detail the barriers to beneficial reuse that the
industry will face as they move forward in reusing industrial byproducts in construction and
providing C&D byproducts for use in other sectors. The use of foundry sands in home
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construction is discussed in Section 3.8 and the use of slag in concrete production is discussed in
Section 3.3.
Table 3-7: Byproducts from Construction and Demolition (NAICS: 236 (Construction of Buildings),
23891 (Site Preparation Contractors)) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
Asphalt Shingles
(from demolition
and roof
replacement)
•	Hot and cold mix asphalt
•	Aggregate base
•	Used as fuel source in Europe69
Does not meet definition of beneficial reuse for this
paper:
•	Recycled into new roofing materials with
minimum 20 percent content of asphalt
•	Produced in quantities significant
enough for beneficial reuse; 11 M
tons into U.S. landfills each year; in
top 4 debris streams by quantity in
C&D sector (estimated 1-10
percent)70
•	Typically 95 percent of asphalt
shingle waste ends up in landfills; if
only 2 percent of the 500 M tons of
asphalt produced each year was
composed of recycled asphalt
shingles, then all shingle waste
could be beneficially reused71
•	Can be reused across sectors for
fuel and nonfuel uses
Concrete (from
demolition)
•	Erosion control
•	Shoreline protection72
•	Aquatic habitat restoration
Does not meet definition of beneficial reuse for this
paper:
•	Road base, general fill, drainage media,
pavement aggregate
•	Produced in quantities significant
enough for beneficial reuse; top
debris stream by quantity in C&D
sector (40-50 percent)
•	Potential for more reuse: studies
estimate that 50 to 57 percent is
currently reused.73
•	Can be reused across other sectors
for nonfuel purposes
Wood (from
demolition and
construction of
structures)
•	Fuel source for electricity generation (mostly
wood from truss manufacturers, log home
suppliers, and modular home manufacturers) in
boilers or electric utilities
•	Mulch and compost
•	Pulp for particle board, chip core, laminates,
animal bedding, paper products, rayon, laundry
detergent, camera film, tires, and transmission
belts 4
•	To reduce coastal erosion
Does not meet definition of beneficial reuse for this
paper:
•	Recovered lumber for flooring
•	Produced in quantities significant
enough for beneficial reuse; in top 4
C&D byproducts by quantity (20 to
30 percent)
•	In 2002, 35.7 MMT of wood waste
was generated with 29.2 MMT
available for recovery; possibly only
2.7 MMT was being actually
recovered in new construction75
•	Reuses occurring across sectors of
interest and other sectors for fuel
and nonfuel purposes
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Table 3-7: Byproducts from Construction and Demolition (NAICS: 236 (Construction of Buildings),
23891 (Site Preparation Contractors)) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
Gypsum
Wallboard (from
demolition and
construction)
•	Support for spray-on gunite (spray-on concrete)
•	Cement manufacturing
•	Agriculture and soil amendment76'77
•	Amendment for composting systems
•	Stucco additive
•	Sludge drying agent (option undergoing
research)
•	Wastewater treatment to settle particles (option
undergoing research)
•	Manure treatment
•	Animal bedding (in combo with wood shavings)
•	Athletic field line marker
•	Possible uses as preventative application for
road salt leaching, component in flea powders,
and Grease absorption agent78
•	Paper backing sold to paper mills or recycled
into more paper backing
Reuse within same sector:
•	Gypsum wallboard can be recycled to make
new gypsum wallboard;79 80 a pilot program is
being operated in Boston, Massachusetts81
•	Produced in quantities significant
enough for beneficial reuse; in top 4
C&D byproducts by quantity (5 to 15
percent)
•	Over 14 M tons of gypsum
wallboard waste are generated
each year, with 64 percent from
new construction, 14 percent
demolition, 12 percent
manufacturing scrap, and 11
percent remodeling;82 potentially all
of the new construction and
manufacturing wastes can be
reused using current technology;
although there are technological
barriers to recycling demolition and
remodeling scrap, recycling facilities
operating using these materials83
•	Reuses occurring across sectors of
interest and other sectors for
nonfuel purposes
Byproducts from Other Sectors Used in C&D
Foundry Sands
• Fill
See Metal Casting for rationale
Slag (From Iron
and Steel)
• Aggregate in concrete mixed on-site
See Iron and Steel for rationale; slag is
included as a byproduct reuse for C&D
as well as cement production, because
concrete is used in construction
3.3.2.1 General C&D Byproducts
Economic/Market Drivers and Barriers
Beneficial reuse can be driven by byproducts that are less expensive than virgin materials.
Recognizing this, some companies will sell gypsum manufacturers recycled gypsum powder at a
price lower than that for virgin gypsum powder.84 Education and research efforts can also drive
reuse, such as efforts by organizations like the BMRA, CMRA, the Recycled Materials Resource
Center (RMRC), EPA's WasteWi$e, Resource Venture, and the Turner-Fairbank Highway
Research Center. In addition, the trend towards green building can drive reuse of construction
and demolition byproducts.
Having sufficient C&D processing capacity to handle reusable materials in an efficient,
economical manner lowers barriers to cross-sector beneficial reuse. For examples, Florida has 40
materials recovery facilities that process most of the C&D waste in the state. However, according
to NDA, development of a C&D recycling facility can be expensive in terms of the necessary
equipment, land, fuel, and labor needed, in addition to landfill disposal for the non-reusable
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materials that come through the facility. Also, according to NDA, the profit margins on these
beneficial reuse facilities is often very low, therefore making the impacts of regulatory or
programmatic barriers even more significant, because profits might not outweigh the time and
costs necessary to comply.85 Despite this challenge, a study of C&D waste minimization
strategies in North Central Texas found that the total cost per ton to process material at materials
recovery facilities was within the range of landfill tipping fees in the North Central TX region.
The study also concluded that co-locating the materials recovery facility with an existing
municipal solid waste (MSW) landfill offers several benefits.86 When C&D facilities are faced
with a beneficial reuse option that costs about the same as landfill disposal and requires no more
transportation than disposal in the adjacent landfill, the facilities are much more likely to provide
their materials for beneficial reuse through the facility.
Although there are economic and market drivers for beneficial reuse of C&D byproducts, several
barriers also exist:
o The quantities of C&D materials available for reuse depend upon economic conditions,
weather, disasters, special projects, and local
regulations.
o Separation and proper storage of C&D materials are
essential for beneficial reuse. The time and cost of
separating co-mingled materials may make
beneficial reuse more costly than disposal.
o Hurricanes and other disaster situations can lead to
a large amount of mixed debris generation in a short
amount of time, leading to a lack of staging areas
for sorting and a lack of available processing
facilities to handle large amounts of debris.
o Historically the population densities in Alabama,
Mississippi, and Louisiana are small and with lower
median incomes than the average U.S. state. Texas
and Florida have consistently ranked second and
fourth in population, respectively, however the
large geographic area of Texas also results in lower
population densities.87 These factors result in a
history of abundant land availability in all of the
states except Florida, which could lead to an
abundance of landfills due to lower costs.
However, this barrier to beneficial reuse is mitigated in practice because landfills can be
difficult to site due to public opposition and landfill regulations. In fact, when Florida
instituted C&D landfill regulations requiring groundwater monitoring in the mid-1990s, the
number of C&D landfills in that state dropped.88
Bans on C&D Disposal Increase Quantity
of Byproducts for Reuse
State and local bans on disposal of C&D
materials increase the supply of byproducts
available for reuse. Bans may be enacted to
address concerns about land availability and
landfill capacity or specific health concerns.
For instance, in 2005, Massachusetts
Department of Environmental Protection
(MassDEP) amended 310 CMR 19.017 to
add C&D materials, including asphalt
pavement, brick, concrete, metal, and wood
to the list of items prohibited from disposal,
transfer for disposal, or contracting for
disposal. Internationally, Vancouver, British
Columbia, Canada, banned disposal of
gypsum wallboard in landfills in 1984.
As more localities enact these types of
bans, the supply of C&D byproducts
available for reuse will increase. As landfill
space becomes scarcer, especially in
metropolitan areas like New Orleans, where
landfills have even raised environmental
justice concerns, beneficial reuse may grow
in importance as an alternative to disposal.
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Regulatory/Programmatic Drivers and Barriers
Some Gulf Coast state programs are lowering barriers to beneficial reuse of C&D byproducts.
Florida provides low interest rate loans through the Recycling Loan program to businesses that
develop innovative recycling programs.89'90 Texas provides a property tax abatement for facilities
that purchase pollution prevention equipment, permit exemptions for some recycling generators,
and has developed a recycling market development board.91
According to NDA, state regulations and programs are creating barriers to the beneficial reuse of
C&D materials. According to the organization, states like Texas charge large fees for recycling
site permits and licenses, have not developed statewide permits for mobile recycling plants that
could facilitate beneficial reuse, have regulations that severely limit project-site recycling, and
have attempted to promote local economic development by establishing flow-control
ordinances.92
According to its Strategic Plan, the Alabama Department of Environmental Management
(ADEM) was recommended to impose a state-wide per ton tipping fee on waste disposal, in
addition to promoting the department's image. These recommendations seem to imply that
Alabama does not have per ton tipping fees that are imposed by the state agency, the lack of
which may make disposal much cheaper than beneficial reuse. If a state-wide surcharge were
added to tipping fees, they could serve as a driver for beneficial reuse by increasing the cost of
disposal and, even further, by funding beneficial reuse programs in the state.
Mississippi's Task Force on Recycling found the following barriers to recycling/reuse in its
state: lack of funding for environmental recycling, education, or beneficial reuse programs and
an abundance of inexpensive land, resulting in cheaper costs of disposal and less incentive to
reuse materials.93
Environmental Effects
Beneficial reuse of C&D debris can have environmental or human health impacts in certain
situations. For example, if the materials are contaminated with hazardous waste, as was the case
in some Hurricane Katrina debris, reuse of such materials would not be advisable due to greater
exposure risks compared to landfilling the contaminated materials. In addition, C&D debris with
lead-based paint (i.e., painted wood), asbestos, and treated wood can not be readily reused, even
for use as a fuel supplement, because of the human health and environmental impacts.94
3.3.2.2 Asphalt Shingles
Economic/Market Drivers and Barriers
Shingles are adhered to roofs, which can create a challenge for beneficial reuse because the
adhesive can cause quality control issues when the shingles are reused in asphalt production. The
stock of shingles to be beneficially reused may be also contaminated by fasteners, flashing,
fiberglass reinforcement, and asbestos.95 While the fasteners, flashing, and fiberglass are not
necessarily issues for cement kilns, asbestos can pose challenges. However, this is a declining
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barrier, because asbestos was only used in asphalt shingles made prior to the 1970s. In fact, for
one project that consolidated asphalt shingles for beneficial reuse in Massachusetts, less than 1
percent of asphalt shingles contained asbestos. To address this small percentage, the State of
Massachusetts imposed testing requirements to screen out the asbestos-containing shingles.96
While there are barriers to reuse of asphalt shingles, organizations such as Asphalt Institute,
Asphalt Alliance, and the Asphalt Recycling and Reclaiming Association are working to educate
and research possibilities for beneficial reuse and drive the market for these opportunities. The
Construction Materials Recycling Association (CMRA) hosts, along with EPA and FHWA, the
web site www.shinglerecvcling.org. which provides generators and end users with tools and
resources to help them pursue beneficial reuse of asphalt shingles. Another driver for beneficial
reuse is tied to fuel prices: asphalt shingles can be reused as a fuel source when traditional fuel
source prices are high.
Regulatory Drivers and Barriers
Alabama and Texas have state programs that are driving beneficial reuse of asphalt shingles.
Section 429 of the Alabama Department of Transportation (DOT) code allows up to 40 to 50
percent recycled asphalt pavement in base and binder layers; however, the code does not specify
whether shingles are included in this percentage.97 Alabama DOT allows 5 percent total weight
of asphalt shingle waste from manufacturers in the pavement mix and 3 percent total weight of
asphalt shingle waste from post-consumers in the pavement mix.98 These types of specifications
can lower barriers to beneficial reuse of the byproduct by bringing important clarity to both
generators in the C&D industry and end users in other sectors. Alabama DOT has been
experimenting with recycling asphalt shingles for the past two years and has steadily used
shingles in recycled asphalt pavement for the last year without any problems.
Texas, which formerly held stringent requirements for the percentage of virgin materials used in
construction projects, now promotes the use of asphalt shingles as aggregate in pavement by
providing specifications for "asphalt content of 15-25 percent by mass of shingle."99 There is,
however, a potential barrier in this specification, because it contains many requirements as to
how shingles may be used in construction projects. For instance, manufacturer and post-
consumer shingle waste may not be mixed for beneficial reuse.100
Environmental Effects
Created from petroleum, asphalt shingles can be beneficially reused as fuel. As petroleum prices
rise, more firms may look towards this beneficial reuse which could reduce the environmental
impacts of petroleum extraction and processing. However, air emissions must be considered
when shingles are used for fuel.
Despite this small and declining percentage of asbestos in shingles, as discussed above, asbestos
is still present and encountered during demolition projects. As a result, beneficial reuse projects
should account for the presence and potential environmental and health hazards associated with
reuse of shingles that contain asbestos.
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3.3.3.3 Concrete
Economic/Market Drivers and Barriers
Scrap concrete can be beneficially reused in creative ways, as listed in Table 3-2. However, if
virgin materials are abundant and cheap in a locality and more convenient to transport and use,
beneficial reuse would not be a lower cost alternative. The rate of beneficial reuse of scrap
concrete in these situations is affected by the local availability of materials. In addition, the
weight and mass of concrete could lead to high transportation costs, which could hinder
beneficial reuse, especially if reuse locations are not near the construction or demolition sites
generating the byproducts.
Regulatory Drivers/Barriers
In some cases, concrete can contain harmful chemicals, depending on the site in which it was
originally used. Because of this potential, some state agencies, such as New Jersey Department
of Environmental Protection, are restricting its reuse.101 However, many states agencies, such as
the Texas and Florida DOTs, support reuse of concrete as aggregate, base, or fill.102 In addition,
Louisiana is promoting the use of concrete to create artificial reefs/wetlands. In this type of
beneficial reuse, sediments become trapped around the debris, creating conditions in which reef
and wetland plants and organisms can thrive. Louisiana has a project to restore the Acadian Bay
reef using concrete rubble and has been consulted in using concrete rubble more widely in its
coastal restoration projects.103 The state of Mississippi is using concrete from demolition sites as
rip rap to counteract erosion along channels near the town of Gautier.104
Environmental Effects
As mentioned above, depending on the location where the concrete was originally used, it could
possibly be contaminated with toxic or hazardous materials. In these cases, beneficial reuse
could have environmental or human health impacts, and the concrete should not be reused near
residential areas unless properly capped.105 Ecosystems can be positively impacted, however,
when scrap concrete is chosen and reused appropriately to construct artificial reefs/wetlands.
3.3.3.4 Wood
Economic/Market Drivers and Barriers
The beneficial reuse of wood from construction or demolition of structures for non-fuel purposes
can be hindered by requirements for careful separation and clean storage. Additionally, after
disasters, wood debris can be ruined or considered hazardous due to water damage and
contaminants. However, it can be easily cleaned with germicidal bleach to remove mold if that
step is deemed necessary prior to beneficial reuse.106 The market for old wooden beams, siding,
shingles, and other materials with historical value can drive beneficial reuse, especially in the
Gulf Coast states Cypress wood is prevalent. Cypress has historically been used in the
Southeastern U.S. due to its long life and termite-proof qualities. Consequently, the wood is in
high demand even while Cypress forests are in decline throughout much of the Gulf Coast area.
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Despite this demand for specialty wood and architectural items, locality characteristics may
inhibit cross-sector reuse. For example, wood from New Orleans could not be transported to
other regions for beneficial reuse because the Formosan termite, which is prevalent in the local
area, might be spread to currently unaffected regions.
Regulatory/Programmatic Drivers and Barriers
State environmental agencies are driving beneficial reuse by promoting the use of wood,
particularly Christmas trees in Louisiana, to create artificial reefs and wetlands. In this
application, sediments are trapped, plants take root around the debris, and organisms are
attracted, all of which aids in re-building damaged ecosystems in the form of reefs and wetlands.
This type of creative beneficial reuse could also apply to wood from C&D operations.
Environmental Effects
Beneficial reuse of wood from construction and demolition can positively affect the environment
by reduce the use of virgin materials and the environmental impacts of logging. Reusing native
woods like Cypress can allow woodland ecosystems to remain untouched or be allowed to
regenerate after extensive logging ventures. In addition, the ecosystem restoration efforts
described above illustrate how beneficial reuse can positively impact the environment.
3.3.3.5 Gypsum Wallboard
Economic/Market Drivers and Barriers
Similar to wood, wallboard requires careful separation and clean storage to be beneficially
reused. In addition, after disasters, C&D materials can be ruined due to water damage or
considered hazardous due to contaminants. However, recovered gypsum wallboard may be more
easily reused than other materials from C&D sites when it is removed separately by a dry wall
contractor and, therefore, is separated from other byproducts and potential contaminants.107 In
some cases though, each general contractor disposes of wastes, which may lead to wallboard
being mixed in with other C&D materials.
Beneficial reuse opportunities are limited when gypsum wallboard has been painted, especially
with lead-based paint. Current technologies in the United States are not effective at removing
paint from wallboard (Canada, however, has a method of separating the paint from the paper on
the wallboard).108 Although there are technological barriers to recycling wallboard, European-
developed technologies are providing more opportunities to beneficially reuse gypsum wallboard
in the U.S.109 Some companies have found success using recycled gypsum waste and selling it as a
reprocessed raw material, such as Gypsum Recycling International (GRI).110
Regulatory Drivers/Barriers
Facilities that process gypsum wallboard for beneficial reuse may require an air emissions permit
from the state.
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Environmental Effects
The environmental and human health effects of landfilling gypsum wallboard are a strong driver
for beneficial reuse. Under conditions that are often found at landfills, decomposing drywall can
generate hydrogen sulfide, a gas that causes odors at low levels and health affects at high
levels."111 In fact, the City of Vancouver, BC, Canada, has banned landfill disposal of wallboard
for this reason.
3.4 Electric Power Generation at Fossil Fuel Plants (NAICS 221112)
Burning coal in steam boiler furnaces at electric power plants produces coal combustion
products. Coal is either injected or conveyed into the furnaces where it ignites and burns. When
the coal is completely combusted, the coal combustion products (CCPs) (i.e., the non-
combustible portions of the coal) either fall to the bottom of the boiler or exit the furnace in a
flue gas stream that is captured by dust collection devises. Fly ash is the ash in the flue gas that is
removed before the gas exits the chimney. Flue gas desulfurization (FGD) material is produced
when sulfur dioxide is removed from the exit gas, in order to prevent acid rain.112
3.4.1 Beneficial Reuse Traits and Trends Electric Power Generation at Fossil
Fuel Plants
In 2004, almost 400 fossil-fuel-burning electric power generation facilities operated in Gulf
Coast states, as shown in Table 3-8. The large number of facilities in the Gulf Coast states could
present significant opportunities for beneficial reuse of CCP byproducts from the facilities in this
sector that are coal burning.
Table 3-8: Number of Fossil Fuel Burning Electric Power Generation Facilities in Gulf Coast States as
Characterized by U.S. Census 2004 County Business Patterns113
State
Electric Power Generation, Transmission, & Distribution (NAICS 221112)
Alabama
11
Florida
122
Louisiana
75
Mississippi
13
Texas
175
Total
396
The American Coal Ash Association's (ACAA) CCP Production and Use Survey indicates a
trend of increased beneficial reuse of fly ash and flue gas desulfurization (FGD) material from
1966 to 2004. The 2004 ACAA CCP Production and Use Survey reported CCP utilization at
49.1 million tons, a 6 percent increase from 2003. The survey also reported a 40.1 percent CCP
beneficial reuse rate in 2004, up from 38.1 percent in 2003.
Figures 3-5 and 3-6 display the quantities of CCP produced and the relative amount of beneficial
reuse in the Gulf States in 2004.114 According to the American Coal Council (ACC), beneficial
reuse of CCPs has seen slow but consistent growth from 2001 to 2003, in the following areas:
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o FGD gypsum material for the production of wallboard, which increased 25 percent during the
time period, was the most significant area of growth for the beneficial reuse of CCPs.115 FGD
gypsum is a synthetic material that results from the burning of coal for electricity. It is
identical in chemical structure to mined gypsum.
o Total tonnage of FGD gypsum sold increase by approximately 11 percent, from 6.6 million
tons in 2001 to 7.4 million tons in 2003.116
o Beneficial reuse of fly ash increased by 23 percent.117
o Total tonnage of fly ash sold increased 10 percent, from 17.8 million tons in 2001 to 19.5
million tons in 2003.118
Figure 3-5: Coal Combustion Products Produced by Coal-Fired
Power Plants Located in the Gulf States in 2004 (metric tons)119
Fluidized
Boiler Slag
FGD Gypsum
2,273,607
^24%
Fly Ash
4,655,317
51%
Bottom Ash
1,631,944
18%
\ Fluidized Bed
Boiler Slag / \ \ Combustion
38,102 -/ ^ ^ Ash
0 4o/o Web Scrubber 379,843
310,059	4%
3%
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Figure 3-6: Coal Combustion Products Production and Beneficial Reuse
in the Gulf Coast States in 2004120
Fly Ash
Flue Gas Desulphurization - Syn. Gypsum
Bottom Ash
Fluidized Bed Combustion Ash
Boiler Slag
FGD Wet Scrubber
ฆ Produced
~ Beneficial Reuse
500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000
(thousand metric tons)
National efforts such as EPA's Coal Combustion Products Partnership (C2P2) Program and
regional/state efforts from groups such as the Texas Coal Ash Utilization Group (TCAUG) have
surely contributed to this growth, with their focus on increasing the education and awareness of
potential beneficial reuses for CCPs. However, the degree of understanding and acceptance of
CCP beneficial reuse varies from state to state, resulting in very different practices in the
regulation of CCP beneficial reuse, specifically for non-traditional reuses, such as land
applications.
Table 3-9 displays the various reuses for CCPs and the quantities of each byproduct reused in the
Gulf States in 2004. As discussed in Section 3.1 and shown in this table, the largest quantities of
CCPs, almost 2 million metric tons, are reused in cement and concrete applications.
Table 3-9: Coal Combustion Products Beneficial Reuses in the Gulf States in 2004121
Beneficial Reuse
Coal Combustion Byproducts (metric tons)
Fly Ash
FGD
Gypsum
Bottom
Ash
FBC
Ash
Boiler
Slag
FGD Wet
Scrubber
Total
Aggregate


16,121



16,121
Agricultural Uses
167
59,716
1,498


5,877
67,258
Blasting and Sanding




38,102

38,102
Concrete
1,678,206
130,805
59,979



1,868,990
Concrete Aggregate
231,176
46,592
62,032


21,128
360,929
Deicing and Traction
3,156

9,280



12,437
Flowable Fill
3,109





3,109
Mineral Filler
20,921





20,921
Road Base
232,497

185,952



418,449
Soil Stabilization
70,252

8,459
172,752


251,463
Structural Fill
1,568

12,825



14,392
Waste Stabilization
260





260
Miscellaneous
95,996

23,128
14,161


133,284
Wallboard

1,165,959




1,165,959
Total
2,337,308
1,403,073
379,273
186,913
38,102
27,005
4,371,673
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Data on energy production indicate a continuing steady supply of CCPs. In 2005, coal-fired
plants produced 50 percent of power. US Department of Energy's (DOE's) Energy Information
Administration (EIA) projects that, in 2015, coal-fired plants will account for 49 percent of
power generation. As natural-gas fired power plants add capacity over the next 10 years,
electricity generated from coal is expected to decrease. However, as natural gas becomes more
expensive, more coal-fired plants are expected to be built. Therefore, EIA projects that in 2030,
57 percent of electricity will be generated from coal and 16 percent will be generated from
natural gas.122 In addition, the United States has over 275 billion tons of coal reserves, which
would last over 200 years at current usage rates.123 Thus, in meeting future U.S. electricity needs,
greater amounts of CCPs are likely to be produced, unless new coal-based technologies such as
coal gasification take hold, new nuclear plants are built, and differing qualities of coal are used.
In addition, ACC asserts that CCP management is increasingly becoming an important strategy
to lower costs and generate revenue for power plants.124
Pollution prevention and air compliance measures have also had, and will continue to have,
effects on the supply and composition of CCPs available for beneficial reuse:
o ACAA anticipates an increase in generation of FGD materials because of the application of
the Clean Air Interstate Rule (CAIR), EPA's 2005 Clean Air Mercury Rule (CAMR), and the
application of technologies to capture mercury and sulfur dioxide (S02). However, whether
the additional byproducts are FGD gypsum or other FGD material will depend upon whether
the coal-fired power plants select a forced-oxidation wet scrubbing technology (which
generates gypsum) or a dry scrubber technology (which generates a lower value byproduct).
Coal-fired power plants in the eastern U.S. more commonly use wet scrubbers, while coal-
fired power plants in the more arid western U.S. more commonly use dry scrubbers.125
o Recent research suggests that some facilities will use activated carbon injection to control
mercury emissions regulated through CAMR. The injection systems reduce the air
entrainment potential of the fly ash, which reduces the structural rigidity when cured,
producing unmarketable fly ash. A regulatory impact analysis developed for CAMR found
that by 2020, utilities will likely use activated carbon injection in no more than 12 percent of
their coal-fired generating capacity, potentially affecting only a small percentage of fly
ash.126
o As explained in the opening paragraph of this section, power plants install FGD units to
mitigate SO2 emissions. In 2004, electric power companies announced 30,000 megawatts
(MW) of FGD equipment to be added in coming years to meet SO2 standards. As a result,
ACC estimates that the largest area of increase in CCP production will likely be in the area of
FGD materials, motivated by the next phase of the Clean Air Act (CAA) requiring further
reductions in SO2 emissions.127
o Some utilities may switch from high-sulfur to low-sulfur coal to control SO2 regulated
through CAIR. Research suggests that the quantity and quality of fly ash produced from low-
sulfur coal combustion is not significantly different than the fly ash produced from high-
sulfur coal.128
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Literature reviews and discussions with contacts reveal that, currently, demand for CCPs appears
to be growing as a result of increased efforts by utilities and marketing firms to promote
beneficial reuse. Increased awareness of the potential for and benefits of beneficial reuse, along
with clear state specifications (e.g., those required by DOTs) and regulations have led to
increased utilization. A shortage of affordable raw and manufactured materials that are replaced
by CCPs is also contributing to demand. ACC estimates that current and continued cement
shortages will increase the use of fly ash in concrete applications with an expected annual growth
around 2 percent.129 Embodying this point, the state of Florida currently imports fly ash from
other states for beneficial reuse in concrete manufacture.
One of the most significant areas for potential growth in the utilization of CCPs is in the
production of synthetic gypsum for the wallboard industry. Recent trend data indicate a growing
market for wallboard and synthetic gypsum used in the production of wallboard.130
3.4.2 Beneficial Reuse Drivers and Barriers in Electric Power Generation at
Fossil Fuel Plants
Table 3-10 lists the electric power generation industry byproducts selected for analysis in this
white paper, along with the rationale for their selection. As discussed in Section 3.5.1, cross-
sector beneficial reuse of these coal plant byproducts is thriving and growing. Other industries,
especially the cement industry, have found a number of uses for the byproducts as substitutes for
raw materials. The following sections detail the drivers that have made these reuses successful,
or at least lowered barriers to reuse, and the barriers that the electric power generation industry
and other industries may have to face as they move forward in increasing beneficial reuse across
sectors. Electric utilities are also engaged in cross-sector beneficial reuse by utilizing woods
from the construction and demolition (C&D) and forest products industries as alternative fuel.
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Table 3-10: Byproducts from Electric Power Generation at Fossil Fuel Plants (NAICS: 221112)
Selected for Analysis131
Byproducts
Reuse
Rationale for Inclusion
Fly Ash
•	Mineral filler
•	Deicing and traction
•	Flowable fill
•	Structural fill
•	Waste stabilization
•	Agricultural uses
•	In concrete and road base aggregate
Cement Sector
•	Raw material for Portland cement production132
•	Portland cement additive133
•	Building and transportation construction134
•	Substitute for Portland cement
•	Soil stabilization
Does not meet definition of beneficial reuse for this
paper because reuse occurs as same facility:
•	Mining uses (e.g., roads, ramps, construction,
reclamation); the majority of coal mines in
Texas have electricity generating units (EGUs)
adjacent to the mine
•	Produced in quantities significant
enough for beneficial reuse: 5.1 M
short tons in Gulf States in 2004135
•	Potential for more reuse to occur:
about 2.5 M short tons (53.5
percent) currently being reused in
Gulf States136; in EPA Region 6
(Louisiana, Arkansas, Oklahoma,
New Mexico, and Texas),
approximately 2 percent of the
boiler ash generated and 2 percent
of the fly ash in the Region was
used for cement production137
•	Can be reused in sectors of interest
and in other sectors for nonfuel
purposes
FGD Gypsum
1 ou
•	Wallboard manufacturing
•	Cement clinker additive139
•	Agricultural uses, such as soil amendment and
nutrient source
•	Produced in quantities significant
enough for beneficial reuse: 2.5 M
short tons in Gulf States in 2004140
•	Potential for more reuse to occur:
about 1.5 M short tons (32.1
percent) currently being reused in
Gulf States141; in EPA Region 6
(Louisiana, Arkansas, Oklahoma,
New Mexico, and Texas),
approximately 1 percent of FGD
material produced in the Region
was used for cement production142
•	Can be reused in sectors of interest
and in other sectors for nonfuel
purposes
Byproducts from Other Sectors used in Electric Power Genera tiona t Fossil Fuel Plants
Wood (from
Demolition and
Construction and
from Forest
Products)
• Electricity generation
• See C&D and Forest Products for
rationale
3.4.2.1 Fly Ash
Economic/Market Drivers and Barriers
The production of coal ash is greatest in the winter and summer months when consumers use
electricity to heat and cool their homes. In other parts of the US, winter is a slow time for
construction projects; therefore, electric power plants incur a storage cost to hold the fly ash until
it can be reused in construction.143 However, in the Gulf Coast states, construction typically takes
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place year-round, providing a consistent end use for coal ash. Selling fly ash as an additive to
Portland cement or for use as flowable fill is profitable for electric power plants, and beneficial
reuse of coal ash reduces purchasing costs of virgin raw materials for construction projects.144'145
Beneficial reuse of fly ash often requires that the byproduct meet certain specifications, which
inhibit beneficial reuse. Consistency in composition of the fly ash is important for beneficial
reuse, and Some electric power plants produce an inconsistent quality of fly ash due to
combustion of non-homogeneous coal.146'147 In addition, fly ash contains some volatile
impurities that can cause violations of EPA's proposed mercury regulation.148 This can increase
the perception of liability risk associated with beneficial reuse of fly ash.
In terms of beneficial reuse of fly ash in concrete production, high carbon content in fly ash can
prevent proper protection of concrete from damage caused by freeze-thaw cycles, thus reducing
the value of fly ash as a raw material input.149 The need for fast setting concrete also limits the
amount of high carbon fly ash that can be used in some projects.150 Finally, the use of high-
carbon fly ash (that requires beneficiation) as an additive in concrete or cement requires
processing to meet specifications, which creates a processing cost.151 However, most fly ash
requires no processing for reuse.152
Although these specifications can inhibit beneficial reuse of fly ash in concrete or cement, in
Florida, architects, contractors, and ready-mix suppliers are generally accepting of the use of fly
ash as a substitute for Portland cement in concrete153 because certain physical properties of
finished products can be enhanced by the introduction of fly ash as a component material. The
use of fly ash as Portland cement additive can improve workability in the mixed cement and
higher strength and increased longevity in the finished concrete product, increasing resistance to
chemical attack, strength, and workability.154 Fly ash can also be used in plastics production to
increase the stiffness of plastic and reduce production costs by replacing plastic resin.155
Finally, several organizations are providing research and education to promote beneficial reuse
of fly ash:
o The Texas Recycling Market Development Board (RMDB) primarily focuses on beneficial
reuse of coal ash in concrete.
o The U.S. Department of Agriculture (USD A) is researching the use of fly ash as a soil
amendment.156
o The Office of Surface Mining (OSM) is examining the possibility of utilizing fly ash in mine
reclamation.157
o The University of North Dakota established the Energy and Environmental Research Center
(EERC) and the Coal Ash Resources Research Consortium.158
o The state of Ohio supports Energy Industries of Ohio in their research to reduce the weight of
automotive industry components using off-specification fly ash.159
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o The American Coal Ash Association (ACAA) has put forth extensive research and education
efforts to promote the reuse of coal ash and fly ash.
o The Recycled Materials Resource Center is a national center that promotes the appropriate
use of secondary materials, including coal ash, in the highway environment. The Center is an
active and viable partnership between FHWA, the University of New Hampshire (UNH), and
the University of Wisconsin-Madison.
Regulatory/Programmatic Drivers and Barriers
Efforts to reduce and control air emissions from electric generating units (EGUs) may affect the
quality and consistency of the coal ash produced.160 The most significant example of such an
effect results from the federal legislation on mercury emissions. Current mercury control
techniques can contaminate fly ash with activated carbon and mercury and create a byproduct
that may not meet beneficial reuse specifications.
Several states have regulations and programs that specifically address fly ash, in addition to their
general beneficial reuse regulations discussed in previous sections of this paper. These
regulations and specifications may be drivers for beneficial reuse of fly ash by creating a clear
understanding of acceptable uses. However, regulations and specifications can be barriers if they
limit the beneficial reuse of fly ash.
Alabama considers fly ash a "special waste" in certain circumstances, thereby requiring specific
processing, handling, or disposal techniques.161 These specific requirements can raise barriers to
beneficial reuse. However, Alabama Department of Transportation (DOT) is lowering barriers to
beneficial reuse by allowing fly ash to be used in concrete if it meets the requirements of the
American Association of State Highway and Transportation Officials (AASHTO) M295,
allowing fly ash to be used in roadbed and base stabilization, and providing specifications for fly
ash use as mineral filler for hot mix asphalt (Special Provision No. 02-0130).
In Florida, a fly ash supplier must submit samples to a Florida DOT (FDOT) laboratory every
three months to check for quality. High unburned carbon content can prevent the reuse of the
ash, and FDOT does not allow fly ash to be used in flowable fill if it is designed to be excavated.
162 Despite these restrictions, FDOT defers to American Society for Testing and Materials
(ASTM) C618 specifications for fly ash in concrete, and to AASHTO M85 specifications for
cement. Incorporation of these commonly known standards can lower barriers to beneficial
reuse. Finally, FDOT has an approved source list of concrete sources used in state projects
including cement, boiler slag, and fly ash, further lowering barriers to beneficial reuse, and
FDOT specifies 18 to 22 percent Class F fly ash replacement for Portland cement in regular
concrete projects. Mass concrete and drill shafts can use up to 50 and 35 percent fly ash,
respectively, because FDOT, ash marketers, and ready-mix suppliers find these percentages
allow for the best durability in marine environments and create a superior product.163
Mississippi DOT has specifications for the use of fly ash, which can reduce the uncertainties
associated with reusing the byproduct in engineering projects.
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Texas has a number of specifications in place that
appear to be lowering barriers to beneficial reuse of
fly ash, based on success stories like the Xcel and
LaFarge example described in the text box. These
specifications include:
o Fly ash is considered nonhazardous recyclable
material and has specifications for reuse under
DM S-11000.
o Fly Ash Quality Monitoring Program (FAQMP)
specifications (DMS - 4610 - Fly Ash) establish
requirements for Class C, Class F, and ultra fine
fly ash used in concrete products.
o FAQMP has specifications for fly ash used in
sub-grade or base treatment (i.e., soil treatment)
(DMS-4615).
o Texas DOT adopted coal ash specifications in
2004 on a district and statewide basis. The
TxDOT specifications require a minimum of 20
percent fly ash and a maximum of 35 percent in
concrete.
o Amendment to 30 Texas Administrative Code
(TAC) Chapter 335 - Industrial Solid Waste and
Municipal Wastes permits coal ash reuse in Texas if it meets eight criteria. Lf>4"lw
At the federal level, the Federal Highway Administration (FHWA) requires state highway
departments to have specifications preferring cement and concrete containing coal fly ash for
federally funded projects, and Federal Aviation Administration (FAA) standards allow for fly
ash in certain concrete products 166
Environmental Effects
Some studies have shown that the use of fly ash in place of cement reduces carbon dioxide (CO2)
emissions by one ton for every ton of fly ash used.16 In addition, a recent study by an EPA
contractor cited limited energy and water use, reduced atmospheric emissions and waterborne
and end-of-life waste, and improvements in overall human health from partial fly ash substitution
in concrete parking lot pavements.
On August 29, 2007, EPA Office of Solid Waste and Emergency Response (OSWER) published
a "Noti ce of Data Availability on the Di sposal of Coal Combustion Wastes in Landfills and
Surface Impoundments" (72 FR 49714). The NOD A conveys new information received since the
Agency issued its May 2000 Regulatory Determination on coal combustion waste, which
recommended that coal combustion product remain excluded from federal hazardous waste
Fly Ash Reuse in Texas
in the spring of 2002, Xcel Energy and
Lafarge North America performed a trial
highway project in Randall County, TX.
using, among other materials, 200 tons of
CCP material to stabilize a road base. The
performance of the fly ash material was
strong compared to the other tested
materials. Lafarge subsequently witnessed
geotechnical applications increase from 20
percent of stabilization work in the Arnarillo
market in 2002 to 90 percent in 2006.
Xcel Energy and Lafarge continue to
beneficially reuse CCPs. Xcel's Harrington
and Tolk power stations beneficially reuse
all 500,000 tons of the CCPs that they
produce annually. According to Xcel
Energy's estimates, in 2003, Texas
stabilization projects utilized an estimated
15,865 tons of these CCPs. "Assuming that
75 percent of fly ash used for soil
stabilization replaces the use of lime, the
corresponding ratio of CCP to lime use is
about 2:1, and an emission factor for lime is
0.17 metric tones of carbon equivalent
(MTCE) perton, then greenhouse gas
emissions attributable to this CCP use in
stabilization projects can be reduced by
1,350 MTCE per year."
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management, but indicated the Agency's commitment to review CCW for potential management
under the federal Criteria for Solid Waste Landfills, RCRA Subtitle D. The August 2007 NODA
was part of that continuing review,
In interviews with the American Coal Ash Association (ACAA), they acknowledge that there
have been some situations historically where fly ash has been disposed inappropriately.
However, for beneficial uses ACAA believes that current state oversight is sufficient to prevent
future problems. It is important for states, material providers, and users to evaluate a beneficial
reuse project from two perspectives: 1) evaluate the characteristics (geography, water sources,
climatic conditions, etc.) of the site or project; and 2) evaluate the characteristics of the CCPs to
make sure they are compatible with the intended use." This conscious effort to thoroughly
evaluate the project and materials before placement will help prevent any environmental
degradation in the future.169
3.4.2.2 FGD Gypsum
Economic/Market Drivers and Barriers
As reported in a National Council for Air and Stream Improvement (NCASI) white paper
presented an industrial byproducts beneficial use meeting, FGD material from coal-fired power
plants that contains significant amounts of calcium chloride is not usable as an additive in
Portland cement.170 However, for FGD material that does meet the appropriate specifications, the
byproduct, depending on transportation costs, can be a less expensive raw material for Portland
cement production than natural rock gypsum.
Regarding FGD gypsum reused in construction and demolition, synthetic gypsum is often
preferred over natural rock gypsum by wallboard manufacturers because of its purity.171 Also
driving beneficial reuse, certain synthetic wallboard plants are located adjacent to power plants,
and thus use all the wallboard-quality FGD gypsum from that particular plant.172
Regulatory/Programmatic Drivers and Barriers
As air emissions regulations increase, the amount of FGD material available for beneficial reuse
could increase because more will be captured in systems designed to limit emissions.
Environmental Effects
Beneficial reuse of FGD gypsum can replace virgin gypsum in wallboard or Portland cement
production, limiting the consumption of natural resources.
3.5 Forest Products: Pulp, Paper, ami P.-tperboard (NAICS 3221)
The forest products industry includes the raising and harvesting of timber, as well as the paper
and paperboard production process. Pulping, the first step in producing paper and paperboard,
breaks down wood chips or recycled paper into individual fibers through chemical,
semichemical, or mechanical methods. Chemical processes are most commonly used for wood
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chips. Chemicals are recovered in the chemical pulping process, and are commonly called
causticizing materials. Most pulp and paper mills recycle water to conserve energy and raw
materials. Excess process water is either treated on-site or off-site at a municipal wastewater
treatment plant. If treated on-site, the excess water is usually treated through a clarification
(primary) process and biological (secondary) treatment process which removes suspended solids
and soluble organic materials. The solid materials, composed of wood fibers, minerals, and
microbial biomass, are collected and usually dewatered into a cake-like consistency.173 Biomass
is typically used for energy recovery or feedstock for pulp and paper production within the
facility that produced the byproduct, making it outside the scope of this paper.
Energy is essential for pulp and paper manufacturing. Energy is often generated on-site by power
boilers, which burn coal, natural gas, wood, oil, and mixed fuels (e.g., coal, wood residues,
process residues, tires, etc.). Boiler ash is the non-combustible material remaining after the fuels
are burned.174
3.5.1 Beneficial Reuse Traits and Trends in the Forest Products Sector
As shown in Table 3-11, fewer than 100 pulp, paper, and paperboard mills were operating in the
Gulf Coast states in 2004.
Table 3-11: Number of Pulp, Paper, and Paperboard Mills in Gulf Coast States
as Characterized by U.S. Census 2004 County Business Patterns 175
State
Pulp, Paper, and Paperboard Mills (NAICS 3221)
Alabama
25
Florida
14
Louisiana
15
Mississippi
11
Texas
20
Total
85
Available data indicate that the U.S. forest products industry is in decline. Although it remains
the world's leader in the pulp and paper business, producing 28 percent of the world's pulp and
25 percent of the total world output of paper and paperboard176, the industry is facing increasing
competition from foreign competitors such as Canada, Scandinavian countries, Brazil, and Japan,
which in some cases enjoy economic advantages in wood, labor, and environmental costs. Other
competitive pressures include the growing use of electronic communications and advertising,
product substitution, an aging process infrastructure, few technology breakthroughs, and scarcity
of capital for new investments.177
Beneficial reuse of byproducts from pulp, paper, and paperboard mills is occurring, with most
byproducts predominately used for energy and land applications. Many mills have focused on
reusing their byproducts (e.g., biomass) for energy production to the extent possible, resulting in
increased quantities of boiler ash.178 Mills have found that, although boiler ash quantities are
increased, using biomass is more economical than fossil fuels and is more likely to decrease a
facility's carbon footprint. Programs like the Agenda 2020 Technology Alliance, an industry-led
partnership with government and academia, focuses on improving processes, materials, and
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region	51
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markets within the industry. Agenda 2020 listed creation of beneficial reuses for solid wastes as
one of their focus areas in 2006.179
Generation rates in Canada (and likely elsewhere) for ashes from boiler combustion have
increased substantially since the mid-1990s.180 However, changes in energy supply and pollution
prevention measures have had an effect on, and will continue to affect, the supply of byproducts
from pulp, paper, and paperboard mills. Over time, byproduct quantities may decrease due to
technology development focused on waste reduction through increased manufacturing efficiency.
For example, Agenda 2020 projects focus on reducing waste from pulp and paper production
through the development of more efficient manufacturing processes that reduce waste.181
However, the exact effect and extent of this research on byproduct supply is unknown. EPA's
Sector Strategies Program notes the following trends that may affect the supply of byproducts
from the industry:
o Recovery furnaces, which burn spent liquor to recover chemicals used during the pulping
process, are reaching the end of their useful life within the pulp and paper industry. However,
no new technology currently exists to replace these
furnaces. Should a new, cost-effective technology
emerge, the supply of byproducts resulting from
energy production may be affected.
o Within the pulp and paper industry, there is a
constant push to decrease water consumption. A
decrease in water consumption may, over time,
impact the consistency and supply of wastewater
treatment plant (WWTP) residuals. However, the
exact effect on WWTP residual supply is
unknown.182
On the demand side, there appears to be constant
demand for fly ash and bottom ash/boiler slag for
beneficial reuse by cement manufacturers. However, it
is unclear how much of this demand is for ash from the
pulp and paper industry, as United State Geological
Survey (USGS) data on the use of ash by cement
manufacturers do not differentiate between fly ash from
electric power generation and boiler ash from pulp and paper mills.
3.5.2 Beneficial Reuse Drivers and Barriers in the Forest Products Sector
Table 3-12 lists the forest products industry byproducts selected for analysis in this paper, along
with the rationale for their selection. As shown in the table, much of the beneficial reuse of pulp,
paper, and paperboard mill byproducts involves energy production or land application. Although
many other innovative reuses are listed in the table, as described in Section 3.6.1, not much is
known about the effects of efforts to increase beneficial reuse of byproducts from the forest
products industry in other industries. The following sections explain the drivers that may
Boiler Ash Reuse in Georgia
Georgia-Pacific's Savannah River mill
(SRM) uses its petroleum coke fired boiler
ash as aggregate for mill site roads and to
support the wastewater sludge disposal cell
structures at the landfill. The mill also sells
its boiler ash to a local county, which uses it
in road aggregate.
The Georgia Environmental Protection
Division (GAEPD) granted approval for
these beneficial reuses and the Georgia
DOT implemented a specification for graded
aggregate road bas material and listed SRM
as a source. This specification was helpful
to establish the value of the aggregate
product and to gain the acceptance of the
construction community.
SRM beneficially reused 477,160 cubic
meters (624,102 cubic yards) of aggregate
from September 2001 to January 1, 2003,
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encourage more beneficial reuse of pulp, paper, and paperboard manufacturing byproducts in
other sectors and barriers that may discourage such cross-sector reuse. The forest products
industry does not appear to be engaging in beneficial reuse of any byproducts that meet the
selection criteria for this paper.
Table 3-12: Byproducts from Pulp, Paper, and Paperboard Mills (NAICS: 3221)
Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
WWTP Residuals
(wood fibers,
minerals and
microbial biomass)
•	Energy (21.9 percent)183184
•	Land application as an organic soil
amendment185, hydraulic barriers, strip mine
caps (14.6 percent)
•	Other (11.7 percent)
o Recovered papermaking fiber and filler
(about 6 percent in 1995)
o Industrial absorbent
o Animal bedding
o Lightweight/glass aggregate
o Admixture in Portland cement concrete186
o Raw material in Portland cement
o Building board 187
o Agricultural chemical carriers
o Roofing tar or felt
o Fuel pellet ingredient
o Manufactured soil
o Compost feedstock
o Low-permeability landfill and strip mine
caps
o Gasification fuel products
o Chemical feedstock
o Mulch ingredient
o Plastic additive
o Animal feed product
•	Believed to be produced in
quantities significant enough for
beneficial reuse: in 1995, industry
produced 5.5 M dry tons of WWTP
residuals188
•	Believed to have potential for more
reuse to occur: in 2002, 52 percent
of byproduct landfilled and 48
percent beneficially reused189
•	Can be reused in sectors of interest
and other sectors for fuel and
nonfuel purposes
Boiler Ash
(noncombustible
materials left after
burning of coal,
wood, other fuel)
Coal-fired boiler ash (15 percent)
•	Mineral admixture in Portland cement
•	Grout
•	Mineral filler in asphalt paving
•	Flowable fill
•	Structural fill
•	Waste solidification/soil stabilizer
•	Soil amendment
•	Fine aggregate in asphalt paving
•	Granular base
•	Soil stabilization/waste solidification
•	Snow and ice control
•	Surface mine reclamation
•	Blasting grit
•	Stabilized base
•	Supplemental fuel
Wood-fired boiler ash (22 percent)
•	Soil amendment
•	Compost
•	Soil waste stabilization
•	Compost
•	Supplemental fuel
•	Many of the same beneficial use options as
•	Believed to be produced in
quantities significant enough for
beneficial reuse: in 1995, 4 M tons
of ash* produced by energy
generation in pulp and paper
industry
•	Believed to have potential for more
reuse to occur: in 2002, 65.4
percent boiler ash disposed in
landfill or lagoon and 34.6 percent
beneficially reused; land application
utilized 9.3 percent of the material,
and other beneficial reuses
accounted for the other 25.3
percent; of this 25.3 percent, a 1995
survey indicated that 12 percent of
the ash had application in earthen
construction for roadbeds, berms,
and other structures
•	Can be reused in sectors of interest
and other sectors for nonfuel
purposes
*Coal-fired ash comprises 15 percent of
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Table 3-12: Byproducts from Pulp, Paper, and Paperboard Mills (NAICS: 3221)
Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion

listed under coal-fired ash; however,
modifications to wood ash may be required
before it can be used in many of these
applications
Mixed fuel source ash (63 percent)
•	See reuse options for coal-fired ash and wood-
fired ash
•	Specific use option for each mixed fuel ash will
highly depend upon relative proportions of the
fuel
generated ash, whereas wood-fired ash
comprises 22 percent of generated ash,
of which:
o 28 percent (0.8 M tons)
beneficially reused
o 2.0 M tons disposed in landfill
or lagoon
Mixed fuel source ash comprises 63
percent of generated ash
Causticizing
Residues (i.e.,
lime mud, lime
slaker grits, and
green liquor dregs)
Lime Mud
•	Landfill/lagoon: 70 percent
•	Land application: 9 percent
•	Reuse in-mill: 1 percent
•	Other beneficial use: 20 percent
Green Liauor Dreas
•	Landfill/lagoon: 95 percent
•	Land application: 3 percent
•	Reuse in-mill: 0 percent
•	Other beneficial use: 2 percent
Lime Slaker Grits
•	Landfill/lagoon: 91 percent
•	Land application: 5 percent
•	Reuse in-mill: 3 percent
•	Other beneficial use: 1 percent
Other Beneficial Reuse
•	Soil amendment
•	Alternative daily cover for landfills
•	Waste stabilization
•	Raw material for Portland cement production
•	Clay brick ingredient
•	Road dust control
•	Removal of sulfur gases
•	AMD control amendment
•	Soil Stabilization
•	Fine aggregate in asphalt paving
•	Surface mine reclamation
•	Feedstock compost
•	Admixture to hydraulic barrier material
•	Settling aid in wastewater treatment
•	pH adjustment of process water ingredient in
manufactured soil190
• Management of acidic water in fish ponds191
•	Believed to be produced in
quantities significant enough for
beneficial reuse: According to
NCASI, 1.7 M dry tons/year
produced in 2001192
o Lime slaker grits (15 percent
of waste)
o Green liquor dregs (30
percent of waste)
o Lime mud (55 percent of
waste)
•	Believed to have potential for more
reuse to occur: According to NCASI,
1.4 M tons (81 percent) landfilled in
2001 and 300,000 tons (19 percent)
beneficially reused in 2001
•	Can be reused in sectors of interest
and other sectors for nonfuel
purposes
Byproducts from Other Sectors used in Pulp, Paper, and Paperboard Mills
Byproducts reused in pulp, paper, and paperboard mills do not meet selection criteria.
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3.5.2.1	General Forest Products Beneficial Reuse
Economic/Market Drivers and Barriers
The prevalence of forest products manufacturers in the Gulf Coast states could help drive cross
sector beneficial reuse. The forest products industry ranks as Alabama's number one
manufacturing industry and ranks as one of the top manufacturing industries in Florida,
Louisiana, Mississippi and Texas. It is a vital component in the economies of all five states.193
The robust concrete market associated with economic development and rebuilding in the Gulf
Coast states can drive the demand for pulp and paper byproducts that can be reused in cement
manufacturing.194
Many pulp and paper companies have adopted goals to develop beneficial reuses for solid waste
as part of corporate sustainability programs, potentially making information and case studies
available to other companies interested in beneficially using similar byproducts.195 In addition,
some industry association programs are focusing on beneficial reuse of forest product
manufacturing byproducts:
o The Agenda 2020 Technology Alliance is focusing on developing customer-focused
beneficial use opportunities that make the use of mill residuals at lower cost than landfilling
the byproducts.196
o NCASI, an environmental resource for the forest products industry, is promoting the
beneficial use of byproducts of the pulp and paper industry.
o The Technical Association of the Pulp and Paper Industry (TAPPI) provides resources to the
pulp and paper industry relating to beneficial use of pulp and paper byproducts.197
Regulatory/Programmatic Drivers and Barriers
As discussed in Chapter 2, Louisiana has an agreement in place with the Louisiana Pulp and
Paper Association (LPPA) to encourage beneficial reuse of pulp and paper byproducts.
Pulp and paper industry byproducts normally do not meet the definition of RCRA hazardous
waste, which makes disposal a less costly option and could discourage beneficial reuse.198
Alternatively, not meeting the definition of RCRA hazardous waste could make reuse of
byproducts easier, as generators and end users would not have to navigate rules on the definitions
of solid waste and hazardous waste recycling.199
3.5.2.2	Wastewater Treatment Plant Residuals
Economic/Market Drivers and Barriers
As with some other byproducts discussed in this paper, the inability to easily separate reusable
components from the overall waste stream can be a challenge for beneficial reuse of WWTP
residuals.200 In addition, some beneficial reuses require dewatered or dried residuals with 90
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percent solids content, which can be cost prohibitive, thus presenting barriers to beneficial
Studies have been undertaken to assess the performance characteristics of WWTP in the
following beneficial reuses: cementitious products, light weight aggregate, and kitty or poultry
litter.202 Full-scale operations have successfully demonstrated pelletization of sludge and non-
recyclable paper for beneficial reuse as fuel and beneficial reuse of sludge in cement kiln
feedstock.203 However, initial capital costs, distribution and marketing issues, and
incompatibilities with company business strategies have inhibited some companies from
pursuing the use of sludge to produce kitty or poultry litter.204
In terms of specific projects that are working to drive beneficial reuse of WWTP residuals, an
Agenda 2020 project plans to incorporate the fibrous residuals from mills into ready-mixed
concrete to improve the strength, durability, and life span of concrete structures.205
Regulatory/Programmatic Drivers and Barriers
No standards exist at the national level for reuse of forest byproducts, which could be viewed as
a barrier, because there is a lack of guidance for potential end users to consult, which may lead
them to perceive beneficial reuse as risky in terms of liability. However, a lack of regulations
could also drive beneficial reuse, as it might open up more options to potential end users.
Environmental Effects
Potential environmental hazards are associated with trace constituents in WWTP residuals
(dioxins and metals); however, recent trends away from chlorine bleaching have reduced the
presence of dioxins in these byproducts. Potential end users must assess the mobility and
leachability of these trace constituents before pursuing beneficial reuse.206
WWTP residuals can also be converted into fuel pellets. Most state regulatory agencies require
end users to evaluate the combustion byproducts of alternative fuels before proposing them for
widespread use; however, companies involved in both production and use of sludge and fuel
pellets have indicated that regulatory reaction to trial burn data has generally been positive.207
3.5.2.3 Boiler Ash
Economic/Market Drivers and Barriers
Some sources found that, due to the variety of fuels used by forest product mills, maintaining a
consistent quality of boiler ash is a challenge. As with coal combustion products, inconsistency
of boiler ash can create barriers to beneficial reuse because it can limit the available reuse
ฆ • 208
options.
Real-world experience has shown success with beneficial reuse of boiler ash. Concrete of
acceptable quality has been produced with wood ash from a mid-west U.S. pulp and paper mill.
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Similarly, at another mill, boiler ash from the combustion of wood and wastewater treatment
residuals was found to be suitable for cement and brick manufacturing.
Regulatory/Programmatic Drivers and Barriers
Wood ash has no national regulations restricting reuse, but Mississippi has state-specific
standards for beneficial reuse of nonhazardous solid wastes. Chapter 2 provides a description of
drivers and barriers arising from these regulations.
Environmental Effects
Although boiler ash can contain few potential environmental contaminants, in some cases
unacceptably high levels of unburned carbon in ash have limited the beneficial reuse of this
byproduct.209
3.5.2.4 Causticizing Residues
Economic/Market Drivers and Barriers
The beneficial reuse of causticizing residues shares the drivers and barriers discussed above for
other forest industry byproducts. In addition, causticizing residues contain sodium and sulfur,
which if in excess, can impair some manufacturing processes or product quality. In addition to
this chemical composition, cement companies will consider quantity available, ease of material
handling, and regulatory implications. 210
At least two kraft mills in the U.S. use dewatered slaker grits for road construction. These mills
can serve as examples for other mills wishing to undertake the same beneficial reuse. The
projects did find a disadvantage of using dewatered slaker grits for road construction because the
grit and sand road is finer and can migrate farther than that produced from native soil roads.211
Regulatory/Programmatic Drivers and Barriers
Research yielded little information on regulations concerning causticizing residues; however,
one general U.S. standard for beneficial reuse of causticizing residues as alternative daily cover
was identified.212>213
Environmental Effects
Pulp, paper, and paperboard mills generally try to lower the RCRA corrosivity characteristics of
their causticizing residues. As a result, these byproducts generally do not exhibit significant
environmental hazards, with their low concentrations of heavy metals and lack of RCRA
corrosivity characteristics. 214
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3.6 Iron and Steel Mills (NAICS 3311)
Iron and steel mills use one of two processes in producing steel. Integrated steel mills use basic
oxide furnaces (BOF) to produce steel from up to 30 percent steel scrap and at least 70 percent
molten iron produced from blast furnaces (which use iron ore from mines, limestone from
quarries, and coke from batteries of ovens). "Mini-mills" use electric arc furnaces (EAF) to
recycle steel scrap into new steel products, and account for more than 50 percent of US steel
production.215 The largest byproduct from steel production is slag, a mixture of limestone and
iron ore impurities, which is collected on top of the molten iron. Other byproducts include EAF
dust, a combination of gaseous emissions and metal dust that is a byproduct from mini-mills, and
pickle liquor that is used in steel finishing operations.216
3.6.1 Beneficial Reuse Traits and Trends in Iron and Steel Mills
Only 17 iron and steel mills that generate new steel currently operate in the Gulf Coast states in
2004, as shown in Table 3-13. These data are a subset of the 91 facilities reported by the U.S.
Census 2004 County Business Patterns because NAICS 3311 includes facilities other than
integrated mills and mini-mills that use electric arc furnaces, which are the focus of this paper.
Table 3-13: Number of Iron and Steel Mills in Gulf Coast States as Characterized by EPA and U.S.
Census
State
Integrated
Mills217
Mini-mills (Electric Arc
Furnace)
Iron and Steel Mills and
Ferroalloy Manufacturing
(NAICS 3311)218
Alabama
1
5
17
Florida
0
1
13
Louisiana
0
1
4
Mississippi
0
2
5
Texas
0
7
52
Total
1
16
91
With the advancement of free trade and globalization, iron and steel manufacturers in the United
States have met international competition.219 Although U.S. iron and steel production has been
on an upswing in recent years, as shown in Figure 3-7, the U.S. world share of this market
decreased to less than 10 percent in 2004. The U.S. steel industry generates about 30 million tons
of byproducts each year, including 6 million tons of basic oxygen furnace (BOF)/basic oxygen
process (BOP) slag.220 In 2002, the U.S. industry produced steel in 373 locations, nine of which
were fully integrated mills, 48 were partially integrated mills, and 316 were non-integrated
mills.221 To stay competitive, the remaining U.S. iron and steel factories have had to reduce
expenses, one of which is generation and disposal of such byproducts. To achieve this goal, the
sector has an incentive to creatively reuse its own byproducts or find available markets within
other industries for reuse.
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222
Figure 3-7: U.S. Domestic Production of Steel and Pig Iron
160,000
140,000
137,000
120,000
100,000

c
o
91,900
o
| 80,000
T3
C
re
t/>
3
67,700
o
60,000
40,000
39,300
20,000
1950
1956
1962
1968
1974
1980
1986
1992
1998
2004
Steel 	Pig Iron
Beneficial reuse of iron and steel byproducts within the industry, primarily for combustion in
facilities' own furnaces, has taken place for decades.223 The cement industry is also a significant
end user of slag, as discussed in Section 3.1. In 2005, approximately 525,000 metric tons of steel
slag were used in cement clinker production, and approximately 920,000 metric tons of blast
furnace slag (granulated and other) were used in cement clinker production and cement
production.224 The Slag Cement Association (SCA) attributes this growth to increased
availability of slag to more geographic areas, more widespread acceptance of the use of slag
cement in concrete, efforts by the cement industry to educate construction professionals on slag
cement's benefits, and a growing interest in green building construction.225
Government agencies also seem to be affecting demand for iron and steel byproducts.
Alabama's and Texas' Departments of Transportation (DOTs) have shown particular interest in
beneficially reusing iron and steel byproducts in highway and cement construction and
production.
Despite these factors affecting demand for byproducts, regulations and pollution prevention
measures may affect the quantities of iron and steel mill byproducts available for reuse. EAF
dust and spent pickle liquor are listed as hazardous wastes under the Resource Conservation and
Recovery Act (RCRA) and, as such, are subject to handling, treatment, and disposal
requirements that can be costly for manufacturers. As a result, the industry has an incentive to
reduce these byproducts or develop reuse options that can diminish the costs spent on disposal.
In addition, the iron and steel industry has requested that EPA delist spent pickle liquor, which
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would decrease the regulatory barrier of RCRA regulation, thereby increasing the quantities
available for beneficial reuse.
Demand for valuable components of byproducts can affect the supply available for reuse. For
example, metals that can be recovered from EAF dust are in demand; as a result, EAF dust is
being exported to Mexico for metals recovery. However, this removes the EAF dust from the
pipeline for potential domestic beneficial reuse and removes its beneficial reuse from EPA's
authority. 226"227
The global iron and steel trade could potentially have effects on the supply of byproducts in the
Gulf Coast region. If users of iron and steel are able to easily access cheaper supplies through the
numerous large ports in the area (such as those in New Orleans), the Gulf Coast iron and steel
mill industry might see a downturn.
3.6.2 Beneficial Reuse Drivers and Barriers in Iron and Steel Mills
Table 3-14 lists iron and steel mill byproducts selected for analysis in this paper, along with the
rationale for their selection. As discussed in Section 3.7.1, iron and steel mills have been reusing
their own byproducts for decades and the cement industry reuses a significant quantity of slag
and EAF dust as substitutes for raw materials. The following sections discuss the drivers that are
encouraging cross-sector beneficial reuse in the cement and other industry sectors, as well as
barriers that may be inhibiting more beneficial reuse of slag, EAF dust, and spent pickle liquor in
other industries' manufacturing processes. However, our research did not reveal that iron and
steel mills are reusing any byproducts in their manufacturing processes that meet this paper's
selection criteria.
Table 3-14: Byproducts from Iron and Steel (NAICS: 3311) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
Slag (slag from
BOF and EAF
mills (steel slag);
blast furnace slag;
GGBFS; other)
22ซ
•	Road building aggregate
•	Soil remineralization 29
•	Raw material for Portland cement production
•	GGBFS in cement sector230
•	BOF slag recycling231
•	List of providers of fly ash and ground
granulated blast furnace slag (GGBFS) (no
date)232
Does not meet definition of beneficial reuse for this
paper:
•	In furnaces in-house
•	Produced in quantities significant
enough for beneficial reuse: 19.7 M
tons of steel slag produced each
year233
•	The U.S. steel industry generates
about 30 M tons of byproducts
each year, including 6 M tons of
BOF/BOP slag234
•	Potential for more reuse: 7.7 to 8.3
M tons reused each year
(approximately 39 - 42 percent)235
•	Can be reused across sectors of
interest and other sectors for
nonfuel purposes
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Table 3-14: Byproducts from Iron and Steel (NAICS: 3311) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
EAF Dust/Sludge
(from EAF gas
cleaning and
collection)
•	Raw material for Portland cement
production236
•	Raw material for bricks, sandblasting, or
fertilizers (if metal content low enough)237
•	Trace metals [particularly zinc] are reclaimed;
Horsehead Corp, for example, provides EAF
recycling and metal recovery services238
•	Drinkard Metalox, Inc. (DMI) has developed a
unique technology to completely process EAF
dust into saleable products using a hydro
metallurgical process239
Does not meet definition of beneficial reuse for this
paper:
•	In furnaces in-house (if metal content is
sufficient)240
•	Produced in quantities significant
enough for beneficial reuse, with
potential for more reuse:
approximately 0.65 M tons of EAF
dust disposed of annually in the
U.S. and Canada with the
remainder shipped to Mexico for
metals recovery 241 242
•	Can be reused across sectors of
interest and other sectors for
nonfuel purposes
Spent Pickle
Liquor
•	Ferrous sulfate product
•	Sewage treatment to break down detergents,
washing powders, and fertilizers
•	Ferric oxide powder - manufacture of
.... . . . , • , 243 244 245
audio/visual tapes, electric motor cores
Does not meet definition of beneficial reuse for this
paper:
•	Hydrogen chloride gas - returned to pickle line
•	Produced in quantities significant
enough for beneficial reuse: about
1.5 billion gallons produced
annually24
•	Approximately 80 percent of spent
pickle liquor is recycled industry-
wide (in-house) or in wastewater
treatment, but only 2 percent is
reused in other industries247
•	Can be reused across sectors for
nonfuel purposes
Byproducts from Other Sectors used in Iron and Steel Mills
Byproducts reused by iron and steel mills do not meet criteria for selection.
3.6.2.1 Slag
Economic Market Drivers and Barriers
With only 17 integrated and mini-mills in the Gulf Coast, smaller quantities of slag may be
available for beneficial reuse. However, organizations
like the Steel Recycling Institute (SRI), and Slag
Cement Association (SCA) are working to educate
generators and end users of slag about markets and
potential opportunities for beneficial reuse. In fact, in
2005, 3.5 MMT of slag cement, which incorporates
ground granulated blast furnace slag (GGBFS), were
produced in the United States, which is triple the
amount produced in 1996.248 SCA attributes this
growth to increased availability of slag to more geographic areas, more widespread acceptance of
the use of slag cement in concrete, efforts by the cement industry to educate construction
professionals on slag cement's benefits, and a growing interest in green building construction.
Currently, there are 12 Portland cement plants in the Gulf Coast that are using slag in the
production of cement: 7 in Texas, 1 in Louisiana, 1 in Alabama, and 3 in Florida.249 In Texas,
EAF Steel Slag Reuse in Texas
EAF steel slag is being successfully reused
in Texas cement plants using the patented
CemStar™ process. In 2002, approximately
90,000 tons were reused at TXI Midlothian
and 45,000 tons were reused at North Star
Cement.
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slag is commonly used in concrete and hot mix asphalt, resulting in a lower barrier to beneficial
reuse for this byproduct. Also in Texas, one cement kiln is using slag as a raw material for
Portland cement, using a patented production process.250 Once plants begin using slag in
production of cement, others may learn lessons and best practices from the end users, which
could lead to more reuse by other facilities. New end users can take advantage of other plants
climbing the learning curve, which may drive the market for beneficial reuse.
Although slag is being reused in concrete, slag components are not uniform as a result of
different raw materials used and final steel chemistry251; therefore, only slag with particular
properties can be used in certain applications. For instance, slag with significant amounts of free
lime or magnesia can cause cracking of pavements and therefore is not recommended for use in
hot mix asphalt although these types of slag can be used for other applications such as soil
252 253
stabilization. ' To characterize and ensure that inferior slags are not used, special quality-
control procedures are conducted such as petrographic examination, autoclave disruption testing,
and allowing the slag to age.254
Regulatory/Programmatic Drivers and Barriers
If not beneficially reused, slag would have to be disposed of as solid waste, causing generators to
incur tipping fees and transportation costs.
In Alabama, Section 429 of the Alabama DOT (ADOT) code allows the use of crushed slag in
construction aggregate.255 This opens up opportunities for generators of crushed slag to seek end
users of it. Without specific regulatory permission, generators might be hesitant to seek out this
particular reuse.
Although Alabama and Louisiana allow beneficial reuse, as noted above slag components are not
uniform. Some application problems have resulted, such as deterioration and raveling, leading to
some states restricting its use.256
Environmental Effects
Portland cement is produced from virgin materials in an energy-intensive process that generates
greenhouse gases (GHG), which can be avoided by beneficially reusing slag instead of virgin
materials. A quantity of 3.5 MMT of slag cement would avoid 3.0 MMT of CO2 emissions, 15
trillion BTUs, and 5.2 MMT of virgin materials.257 Although these effects are not likely drivers
for individual utilities, the effects could drive regulatory or other programs aimed at
environmental improvement.
3.6.2.2 Electric Arc Furnace (EAF) Dust
Economic/Market Drivers and Barriers
Heavy metals can be reclaimed from EAF dust and sold as commodities, which makes the dust
valuable. In fact, metals are being recovered from EAF dust, 258 with EAF dust being exported to
Mexico for metals recovery.259 This decreases the quantity available for beneficial reuse in the
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U.S. and, more specifically, in the Gulf Coast states. It also takes the management and beneficial
reuse of the dust outside of EPA jurisdiction. However, it does ensure that the dust is not
disposed of directly in a landfill.
Also driving its reuse, EAF dust provides a cheap and plentiful source of raw material for
beneficial reuse, otherwise the byproduct would be treated and disposed of generally as
hazardous waste. The Timken company in Ohio recycled over 6 million pounds of EAF dust,
which saved the company $1 million in 1996.260 Timken was successful in its recycling efforts
by focusing on reducing releases of metals commonly found in EAF dust by recovering the
metals under high temperatures at on- and off-site facilities.
Regulatory/Programmatic Drivers and Barriers
EAF dust is classified as hazardous waste under RCRA, which has hindered its potential
beneficial reuse in the past. Because RCRA requires treatment of the waste to remove hazardous
constituents before disposal, generators typically treat the waste with a high temperature metals
recovery process or chemical stabilization before it is landfilled.261 Such treatment would need to
be considered in any beneficial reuse scenario. For example, generators and end users would be
required to determine (1) where the waste falls under the RCRA regulatory definition of solid
waste, and (2) whether this treatment, coupled with reuse, would be considered reclamation and
would, therefore, not be permissible under the regulation. With EPA's re-proposal of the
definition of solid waste in March 2007, generators and end users may see more opportunities for
beneficial reuse provided they meet the conditions set forth in the rule.
In Alabama, Section 429 of the ADOT code allows EAF dust to be used as mineral filler in
highway construction. Mineral filler is used to enhance certain engineering properties, such as
stiffness of asphalt.262 This approach creates clear opportunities for EAF dust generators to seek
out potential reuses. Without this specific regulatory "permission," generators might be hesitant
to seek out this particular reuse.
Environmental Effects
Untreated EAF dust typically contains hazardous levels of lead and cadmium and therefore
treatment may be necessary, depending on the intended beneficial reuse, to remove heavy
metals.263
3.6.2.3 Spent Pickle Liquor
Economic/Market Drivers and Barriers
With only 17 iron and steel mills in the Gulf Coast, smaller quantities of spent pickle liquor may
be available for beneficial reuse.
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Regulatory/Programmatic Drivers and Barriers
State agencies in Louisiana and Florida support using spent pickle liquor in wastewater treatment
facilities, where it improves the quality of effluent by degrading detergents, washing chemicals,
and fertilizers.264'265 This endorsement may change perceptions of liability and therefore lower
barriers to beneficial reuse. Louisiana requires National Pollutant Discharge Elimination System
(NPDES) permits for any facility that discharges pollutants, including spent pickle liquor to be
used in wastewater treatment facilities.266'267
On the federal level, most spent pickle liquor is listed as a hazardous waste under RCRA
regulations and must be treated and disposed of under the definition of solid waste regulations.
This listing limits its ability to be beneficially reused. Generators and end users would need to
ensure that any treatment before reuse is not categorized as "reclamation" under the regulation,
making reuse non-permissible. The iron and steel industry is petitioning EPA to delist the
byproduct, which would open more avenues for beneficial reuse.
Louisiana does not list spent pickle liquor from the iron and steel industry as hazardous waste;
rather, the state considers the material hazardous only if it exhibits one or more hazardous
characteristics. Therefore, spent pickle liquor is not automatically considered a hazardous waste
under state regulations and might be beneficially reused in some circumstances.268
Environmental Effects
Beneficial reuse of spent pickle liquor can have positive environmental effects. Adding spent
pickle liquor improves the quality of wastewater effluent exiting treatment plants, which can
reduce detrimental impacts to the aquatic system by removing substances that lead to
eutrophi cation.269
3.7 Metal Casting - Foundries (NAP
Industrial processes in the metal casting industry require pouring (or injecting) molten metal into
a cast in the shape of the desired end-product. Casting methods include permanent mold, die
casting, sand casting, shell casting, and investment casting. Sand casting is the most prevalent
process, producing more than half of U.S. castings, followed by permanent mold, die casting,
and investment casting.270 In sand casting, a cast and/or core is made of sand bound together by
any of several substances. "Green sands" are held together by bentonite clay, which makes up 4
to 10 percent of the blend that also includes 85 to 95 percent high-quality silica sand, 2 to 10
percent of a carbonaceous additive to improve the casting surface finish, and 2 to 5 percent
water. Green sands are used to produce about 90 percent of sand-casted products in the U.S., and
are generally the sands available in quantities and chemical constituents suitable for beneficial
reuse. Resin sands are often used for cores and are bound together by organic compounds, which
may make them suitable for fewer beneficial reuses.271
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3.7.1 Beneficial Reuse Traits and Trends in Foundries
In 2004, more than 225 foundries operated in the Gulf Coast, with the majority located in Texas,
as shown in Table 3-15. Such concentrated clusters of facilities could make consolidation of
foundry sands more feasible for the industry, which could lead to more beneficial reuse by
facilities in other sectors.
Table 3-15: Number of Foundries in Gulf Coast States
as Characterized by U.S. Census 2004 County Business Patterns 272
State
Foundries (NAICS 3315)
Alabama
57
Florida
41
Louisiana
12
Mississippi
9
Texas
117
Total
236
In recent years, foundry sands have gained increased recognition as suitable material for
beneficial reuse applications such as flowable fill, asphalt, concrete, road construction, and soil
amendments. The increased emphasis on reuse is partially due to state Departments of
Transportation (DOTs) endorsing foundry sand reuse. In addition, the Federal Highway
Administration (FHWA) has a policy to increase the use of recycled materials in construction,
reconstruction, and maintenance of the nation's transportation infrastructure. Foundry sand is
one of six target materials for FHWA's recycling efforts. EPA's Sector Strategies Program, the
Resource Conservation Challenge (RCC) and other initiatives have made strides in educating
potential users about the possibilities for beneficial reuse of foundry sands. Industry trade
organizations, including Foundry Industry Recycling Starts Today (FIRST) and the American
Foundry Society (AFS), have programs to promote proper management, marketing, and use of
foundry sand.
The American Foundry Society reports that the metal-casting process generates approximately
9.4 million tons of foundry sand annually.273 The extrapolated results from a survey by the
American Foundry Society (AFS) indicate that approximately 2.6 million tons of foundry sand is
beneficially used each year. Table 3-16 summarizes results of the 2007 AFS survey, which
indicate that the most common beneficial use applications for foundry sand are use as
construction fill (which includes both structural and flowable fill), use in asphalt pavement, and
use in the manufacture of concrete. Daily landfill cover, although excluded from the 2.6 million
ton estimate, may also be considered a beneficial use for foundry sands under certain
circumstances.
American Foundry Society's August 2007 survey publication indicates an increase in foundry
sand beneficial reuse: survey respondents indicated a total of 2.6 million short tons is reused
annually, which is 28.2 percent of the sand available for reuse.
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Table 3-16: Beneficial Reuses of Foundry Sands According to
American Foundry Society Survey274
Beneficial Use Application
Quantity Beneficially Used (Tons)
Construction fillb
1,140,914
Concrete
303,531
Not specified/Other
292,928
Road construction
144,288
Top soil mix/horticulture
220,949
Reuse at another foundry0
48,426
Asphalt
494,390
Total:
2,645,427d
a.	Based on 244 total respondents, or a 24 percent completion rate. Survey respondents had the option of selecting more than
one beneficial use application. Beneficial use quantities have been extrapolated to reflect beneficial use in the entire metal
casting industry.
b.	Construction fill includes both structural fill and flowable fill.
c.	Spent foundry sand is transferred from one foundry to another for use in on-site construction projects or other application.
d.	AFS excludes landfill cover as a beneficial use application from the total beneficial use quantity (2,645,427 tons).
According to FIRST, because the cost of high-quality sand for use in metal casting is so high
(about $45-60 per yard), foundries have an incentive to reuse sands as much as possible, which
could decrease the quantity available for beneficial reuse by other industries. Also according to
FIRST, over the past 10 years, many foundries have invested in thermal or mechanical
reclamation systems, reusing much sand in-house and producing lower quantities of byproduct
per unit of manufactured product.
The foundry industry, like iron and steel, has been subject to intense global competition from
China and other countries, which has led to the closing of many facilities over the past 10 years.
This, however, could lead to consolidation in the industry, with each plant generating larger
quantities of sands.
According to FIRST, there has not been a sharp rise in demand for foundry sands, mainly
because of issues associated with the prevalence of small foundries in the industry. Some
generators and end users have attempted to address this issue by consolidating small batches of
foundry sand from many generators into a single large batch for shipment to a cement kiln or
other large-quantity user. However, brokers are limited by shipping fees, so they need to be
careful about locating centrally to foundries, but also strategically to reuse opportunities.
3.7.2 Beneficial Reuse Drivers and Barriers in Foundries
Table 3-17 lists foundry byproducts selected for analysis in this paper, along with the rationale
for their selection. As discussed in Section 3.8.1, demand for foundry sands has grown, but the
current rate (approximately 28 percent) leaves much room for improvement. The sections below
discuss this and other barriers to reuse of foundry sands in other manufacturing industries, in
addition to addressing the drivers that have led to the cross-sector beneficial reuse of foundry
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sands and that may encourage further cross-sector beneficial reuse. Foundries do not appear to
use any byproducts from other industries that meet the selection criteria for this paper.
Table 3-17
Byproducts from Metal Casting - Foundries (NAICS: 3315) Selected for Analysis
Byproducts
Reuse
Rationale for Inclusion
Foundry Sands
•	Geotechnical applications such as road bases,
structural fills, embankments, general fills and
landfills
•	Manufactured products such as flowable fill and
concrete products
•	Manufactured soils and other agricultural
applications275
•	Fine aggregate for asphalt paving276
•	Road base/subbase
•	Soil blending/manufactured topsoil/potting
soil/compost
•	Alternative daily cover for landfill
•	Hydraulic barrier in landfill final cover
•	Rock wool277
•	Raw material for Portland cement production278
•	Fill on construction sites
•	Produced in quantities significant
enough for beneficial reuse:
approximately 9.4 MMT of waste
foundry sand are generated
annually in the U.S.
•	Potential for more reuse to occur:
only about 28 percent currently
reused outside of foundries
•	Can be reused in sectors of interest
and in other sectors for nonfuel
purposes
Byproducts from Other Sectors used in Foundries
Byproducts reused by foundries do not meet criteria for selection.
3.7.2.1 Foundry Sands
Economic/Market Drivers and Barriers
In addition to the overarching economic/market drivers and barriers discussed in Section 3.1,
several drivers and barriers specifically affect beneficial reuse of foundry sands.
Geographic distribution of foundries creates some challenges for beneficial reuse in the Gulf
Coast states. Of the 2,513 foundries in the U.S., most are concentrated in the Eastern and
Midwestern U.S. However, only 10 percent are in the Gulf Coast states, which could result in
lower quantities to be reused in Gulf Coast industries.279 However, almost half of the Gulf Coast
state foundries (117 of 236) are located in Texas, possibly providing opportunities for
consolidating and reusing foundry sands. In fact, approximately 70,000 tons of foundry sand are
produced in Texas annually.280 Also, there are fewer foundries in Alabama (57), but they tend to
be some of the largest foundries in the industry, which is why Alabama is a top 10 foundry state
by production.
Disposal and transportation costs also play into the cross-sector beneficial reuse picture for
foundry sands. As discussed in Section 3.1, low tipping fees can encourage disposal and higher
tipping fees could lead to less disposal and potentially more beneficial reuse. Hauling costs and
tipping fees for disposal of foundry sand tend to be low, with a national average of about $32.61
per ton.281 Without the incentive to save money on tipping fees, generators may be more likely to
opt for disposal, rather than incur time and cost trying to connect with end users of the sand.
Transportation costs can be a significant barrier to cross-sector beneficial reuse, considering the
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weight of foundry sands. An EPA review of case studies found that 25 to 50 miles is the
maximum distance generators or end users are willing
to transport foundry sands for beneficial reuse.
Foundry sands must be screened prior to beneficial
reuse to remove metal scraps, or may need to be
crushed to an appropriate size for reuse. A recent
EPA study found that foundry sand processing costs
range, on average, from $5 to $10 per ton.283
Research into beneficial reuse of byproducts can open
avenues for reuses and reduce uncertainty for
potential end users. Universities and DOTs have
performed numerous studies on the physical,
chemical, and engineering properties of foundry sand
and its suitability for reuse in highways, flowable fill,
embankments, and other reuses. A collaborative
research effort between EPA and USDA will soon
yield a study on foundry sand use in soil
amendments. The study is expected to be published
in Summer 2008.
Finally, collaborations between industry
organizations such as FIRST and AFS and
government organizations, such as EPA's Resource
Conservation Challenge (RCC) and Sector Strategies
have resulted in initiatives to educate generators and
users of foundry sands about markets and possibilities
for reuse. In addition, AFS offers a web-based mapping program to help metal casters find their
closest end users in cement, asphalt, or ready-mix concrete production.284
A more detailed white paper on economic incentives for foundry sand will be published by EPA,
Office of Solid Waste in spring 2008. In the paper, EPA uses economic models to attempt to
quantify the benefits of foundry sand beneficial reuse accounting for life-cycle costs of
manufacturing.
Regulatorv/Progj-ammatic Drivers and Barriers
As described in Section 2, Alabama has a detailed regulatory program for foundry sands. This
type of program can help encourage beneficial reuse, because it reduces the uncertainty
associated with potential liability from beneficial reuse. Each foundry is required to maintain
proper documentation and recordkeeping.
In Texas, TCEQ also has a specific beneficial reuse program addressing foundry sands. In the
state, non-regulated hazardous wastes require notification to the state upon beneficial reuse,
while recycling of regulated hazardous wastes require both permits and notification. TCEQ
Foundry Sand in Home Construction
Eureka Foundry, a family-owned iron
foundry in Tennessee, began making its
foundry sand available to local contractors
and haulers for beneficial reuse projects in
1996. Eureka samples and tests the sand
every two to three years to comply with
Tennessee regulations governing the use of
foundry sand as structural fill
Eureka removes the sand from the casting
process and screens it to separate sand for
beneficial reuse from the sand that can
continue to be used in the foundry's casting
process. Eureka does not charge
contractors for the sand, but transportation
arrangements are generally made on a
project-by-project basis in order to ensure
that the beneficial use of the sand is not
cost-prohibitive to any potential end users.
Contractors generally use Eureka's foundry
sand as foundation fill for individual home
construction projects within an hour's drive
of the foundry. The sand is typically placed
within cinder block walls and capped with
concrete. Contractors complete
approximately four to five projects, of
varying sizes, per year with Eureka's sand.
These uses amount to a total of about 200
to 300 tons, about one-third of Eureka's
byproduct foundry sand.
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maintains a database of beneficial use notifications, which includes the quantity of byproducts
beneficially reused, the identity of the offsite receiver, and information on the beneficial reuse.285
On the federal level, EPA's Sector Strategies Program is working to drive beneficial reuse of
foundry sand and has produced the State Toolkit for Developing Beneficial Reuse Programs for
Foundry Sands, which gives states a step-wise process to develop programs that encourage
beneficial reuse of foundry sands while protecting human health and environment. As described
in the Toolkit, some states approve reuse of foundry sands on a case-by-case basis, which can
involve a time intensive and costly process for generators or end users to prove their sands meet
requirements for beneficial reuse.
Environmental Effects
According to FIRST, most sands come from ferrous foundries and are "green sands," which are
considered nonhazardous in most cases. Therefore, the sands can be reused for a variety of
reuses without impacts to human health and environment. A recent OSW draft report suggests
beneficial reuse of foundry sands can have significant energy savings and, therefore, emissions
reductions, over extraction of virgin sand:
o Substitution of all spent foundry sand for virgin sand would result in an extrapolated 1.2
billion mega joules of avoided energy consumption, which would equal approximately $34
M per year in saved energy costs based on 2006 energy prices.
o The report also suggests that substitution of virgin sand with 10 million tons of foundry sand
in road base would result in 170.8 million gallons of water savings.286
Despite these findings, some still hold perceptions that foundry sands are environmentally
hazardous. To address this perception, EPA's Office of Solid Waste (OSW) is collaborating
with USD A to undertake a multi-year evaluation of the environmental and ecological effects of
foundry sands in soil. The five-year project, entitled "Benefits and Risks of Using Waste
Foundry Sand for Agricultural and Horticultural Applications" (expected to be published in
Summer 2008) will:
o Focus on identifying and quantifying potentially hazardous organics and trace metals in
waste sands from ferrous and non-ferrous foundries.
o Conduct studies to determine the movement potential of any organics and/or trace metals of
environmental concern identified.
o Investigate blending waste sands with organic amendments as a method of mitigating
hazardous constituents.
o Investigate whether waste foundry sands present a risk to commonly used biological
indicators, including soil micro-organisms, earthworms, and plants.
o Assess the suitability of using waste foundry sands in horticultural and agricultural
settings.287
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3.8 Oil and Gas Extraction (NAICS 211111, 211112, 212111, 213112;
As part of oil and gas drilling process, operators must handle the large volumes of rock
fragments that are carried to the surface in the drilling fluid as well as the drilling muds that flow
through the drilling pipe.288 These muds, which are water or oil-based fluids with additives, close
the reservoir to prevent contaminant flows and eliminate cuttings. They also stabilize the well
bore, offer lubrication and counteract formation pressure.289 Though oil-based fluids—coated in
both oil and mud—cannot be discharged to surface waters, they are often reused in the drilling of
other wells because associated base material is relatively expensive.290
During the oil and gas production phase, gas is first separated, and then the sand, silt, water, and
other additives used to facilitate extraction are removed. In addition, oil-water emulsions are
broken down during the production phase. The process that separates the leftover fluids and
solids creates layers of sand, mostly oil-free water, emulsion, and a relatively small amount of
pure oil. The loose sediment and water are removed by using vibrating shaker screens, while the
emulsions are broken apart by exposure to high heat or chemicals.291 The resulting oil is
approximately 98 percent pure, a level appropriate for storing or sending to a refinery for further
processing.292 As the oil is stored, however, the heavy hydrocarbons, clay, sand, and mineral
scale previously suspended in the liquids begin to settle, creating a layer of sludge, known as
"tank bottoms" or "basic sediment and water," along the bottom of the tank.
3.8.1 Beneficial Reuse Traits and Trends in Oil and Gas Extraction
The American Petroleum Institute (API) reports an upswing in extraction activities: an estimated
37,261 oil wells, natural gas wells, and dry holes were completed in the first three quarters of
2006, which is the highest number in 21 years.293 Although the 2004 U.S. Census reports
numerous oil and gas extraction facilities in the Gulf Coast region, these raw data reflect neither
the supply of nor the demand for beneficial reuse of byproducts within the industry.294 The
amount of extraction activity taking place provides a
better predictor of the quantity of drill cuttings and
nonhazardous tank bottoms potentially available for
beneficial reuse.
On-site beneficial reuse occurs frequently during oil
and gas extraction activities; however, such reuse
activities are not within the scope of this paper. EPA
estimates that roughly 10 percent of total drilling
waste volumes, including both liquids and solids, are
reused or recycled into construction and infrastructure
projects as levee fill and road-base material.295
Nonetheless, demand for drill cuttings and
nonhazardous tank bottoms for use in other
manufacturing sectors is not as strong. This weak
demand could be due to the small amounts of tank
bottoms that tend to be generated and/or extensive
transportation costs and liability concerns.
Drilling Waste Reuse in Texas
U.S. Liquids of Louisiana (USLL) recently
has begun converting exploration and
production waste into road-base material
and levee fill in South Texas. As part of
USLL's recycling process, waste is purified
and mixed with other feedstock to create the
road-base materials. With legislative
support from the Texas Department of
Transportation and the Texas Railroad
Commission, USLL produces the recycled
materials without assuming operator liability
for exploration and production waste. USLL
anticipates serving a growing market in the
Gulf Coast region interested in purchasing
road materials that not only are
environmentally advanced, but also possess
a higher compressive strength for less price
than similar road construction substances.1
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3.8.2 Beneficial Reuse Drivers and Barriers in Oil and Gas Extraction
Table 3-18 lists oil and gas extraction byproducts selected for analysis in this paper, along with
the rationale for each byproduct's selection. As discussed in Section 3.9.1, beneficial reuse of
drill cuttings and nonhazardous tank bottoms in other manufacturing sectors has not been
widespread. The following sections discuss barriers that are contributing to lack of cross-sector
beneficial reuse, including liability concerns and limited quantities of byproducts. The discussion
also focuses on efforts to lower these barriers to reuse. In general, the oil and gas sector does not
appear to rely upon byproducts from other industries in their extraction processes.
Table 3-18: Byproducts from Oil and Gas Extraction (NAICS: 211111, 211112, 213111, 213112)
Selected for Analysis
Byproducts
Reuse
Rationale for inclusion
Drill Cuttings
•	Roadbed construction
•	Dike stabilization296
•	Substrate for restoring coastal wetlands297
•	Fill material
•	Daily cover material at landfills
•	Aggregate or filler in concrete, brick, or block
manufacturing
•	Road pavements
•	Bitumen
•	Asphalt
•	Cement manufacture
•	Use as fuel at UK power plants298
Does not meet definition of beneficial reuse for this
paper:
•	Landfarming/landspreading, which seems to be
a land disposal method rather than reuse
•	Drilling muds are reconditioned and used in
drilling of other wells
•	Plugging and abandonment of other wells
•	Reuse within drilling operations for roads,
construction of drilling pads, and other drilling
infrastructure299 300
•	Produced in quantities significant
enough for beneficial reuse: for
offshore drilling, EPA estimated in a
Technical Amendment that on the
order of 500 to 2,000 barrels of drill
cuttings are generated per well
drilled in the Gulf of Mexico (density
of drill cuttings is on the order of
700-1,000 lbs per barrel)301'302
•	Potential for more reuse: in 2000,
only about 10 percent of total drilling
waste quantity was being reused30
•	Can be reused in a sector of
interest and across other sectors for
C 1 304 305
nonfuel purposes
Nonhazardous
Tank Bottoms
(sediments and
water)
•	Used in refineries as feedstock for coking306
•	Dust palliative on low-volume public roads
•	Fuel in cement kilns or aggregate kilns307
•	Although quantities may not be
large (tank cleanings occur a few
times a year or several years apart),
co-location of many refineries and
exploration operations may facilitate
reuse.
•	Can be reused in two sectors of
interest.
Byproducts from Other Sectors used in Oil and Gas Extraction
Oil and Gas Extraction industry does not appear to reuse byproducts from other sectors.
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3.8.2.1 Drill Cuttings
Economic/Market Drivers and Barriers
The physical condition of drill cuttings can dictate beneficial reuse options. Before drill cuttings
can be beneficially reused, it is necessary to ensure that the salinity as well as the hydrocarbon
moisture and clay content of the cuttings are suitable for the intended reuse of the material. Even
after separation from other byproducts, cuttings are still coated with mud and therefore difficult
to use for construction. Treatment options can mitigate these barriers, along with the possibility
of combining the cuttings with fly ash, cement, or other materials to facilitate handling.308
Industry sources cite location, quantity, and cost as the most important criteria for potential end
users in deciding whether to purchase drill cuttings. For example, due to high transportation
costs, prospective clients for roadbase material want the reused product to be located in close
proximity to the feedstock repository. Likewise, the end user needs to have a sustainable amount
of the reused product on hand, and the cost for such material must be attractive compared to
other similar options already available.309
If connections can be made between generators and end users, the market for beneficial reuse of
drill cuttings can expand. Historically, road base products used by the South Texas Department
of Transportation (DOT) have been imported from as far away as Central Texas and Southern
Mexico, indicating viable demand for such products and a potential market for beneficial reuse
of drill cuttings.
Other potential barriers arise when: the end user of the reuse product needs larger volumes than
the recycler currently can provide; the end user needs more exact engineering product design
details than the recycler can offer; and recyclers lack the necessary experience or equipment to
produce a correctly engineered recycled item.310
Regulatory/Programmatic Drivers and Barriers
At the federal level, drill cuttings are typically exempt from Resource Conservation and
Recovery Act (RCRA) hazardous waste regulations and can therefore be beneficially reused.311
Despite the RCRA exemption, and even though DOE has funded several projects to test the
feasibility of reusing cuttings to restore Louisiana's damaged wetlands, neither EPA nor the U.S.
Army Corps of Engineers (USACE) would issue a permit to field demonstrate the use of cuttings
for wetland restoration.312
Some states are addressing the liability concerns that can inhibit beneficial reuse of drill cuttings.
In December 2006, the Railroad Commission of Texas (RRC) revised Texas Administrative
Code Title 16, Part 1, Chapter 4, Subchapter B to specify that "a recyclable product is not a
waste..The rule was proposed and written to address concerns held by potential end users on
liability associated with reuse.313 When "recyclable product" is no longer classified as a waste,
but instead becomes a commercial product after complying with the environmental and
engineering expectations set by the local governing board, then operators benefit from greatly
reduced liability because responsibility for the product shifts to the recycler. The "recyclable
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product," however, would convert into waste if it were disposed of or abandoned instead of
following the prescribed recycling process.314
Environmental Effects
Drill cuttings have been used for road spreading in the past, which can have deleterious
environmental impacts due to their hydrocarbon content. Such impacts have raised significant
concerns and, as a result, road spreading applications involving drill cuttings are prohibited by
many regulatory agencies.
3.8.2.2 Nonhazardous Tank Bottoms
Economic/Market Drivers and Barriers
Offsite beneficial reuse of nonhazardous tank bottoms requires a suitable quantity and quality of
the byproduct. Research indicates that tank cleaning takes place occasionally and does not create
large amounts of byproduct, though co-location with extraction and refining operations can
facilitate beneficial reuse by shortening transportation distances and time requirements.
Petroleum refining operations use the byproduct as alternative fuel for their coking operations.
Sludges can only be recovered for use as feedstock if the sludges have a high percentage of
recoverable hydrocarbons and no hazardous components in hazardous amounts.315
Regulatory/Programmatic Drivers and Barriers
Nonhazardous tank bottoms are typically exempt from RCRA hazardous waste regulations and,
thus, can be beneficially reused.316
Environmental Effects
Obtaining beneficially reusable materials from tank bottoms can ensure that tanks and drums are
thoroughly cleaned before being reused or stored, lessening the chance of environmental
contamination due to drum deterioration and leakage.
3.9 Petrole rfining (NAIC5 32411)
The purpose of the petroleum refining process is to separate distinct organic compounds from the
crude oil, creating more valuable compounds out of less valuable ones.317 Petroleum refining
typically begins by removing salt content from the crude feedstock and then continues with
distillation and further refining process such as cracking and treating.
In the first phase of the process, salt, clay, and various other components are removed by mixing
water into the crude. In the distillation stage, the crude is heated to allow various fractions in the
oil to be recovered. The refining phase targets particular fractions by subjecting them to thermal
treatment and other catalysts.
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Each stage of the refining process creates waste: removing salt produces significant wastewaters
and sludges affected with petroleum, while distillation and refining generate spent heavy-metal
catalysts, spent caustics, and spent desiccant clays. Afterwards, tank cleaning and wastewater
treatment create more sludges from primary or second treatments.318
Oily wastes generated during the refining process can be recycled by returning them to the crude
or processing them in a coker. Spent caustics, acids, and catalysts may be reused by a
regeneration process or by retrieving their valuable metal components. For example, 'cat
cracking' catalyst has been recycled into alumina in cement manufacturing, and sulfidic caustics
may be recycled off-site in the paper industry or as feedstock for producing sulfuric acid.319
3.9.1 Beneficial Reuse Traits and Trends in Petroleum Refining
In 2004, more than 100 petroleum refineries were operating in the Gulf Coast states
(approximately 2/3 of the total U.S. population), with the majority located in Texas and
Louisiana, as shown in Table 3-19.
Table 3-19: Number of Petroleum Refineries in Gulf Coast States
as Characterized by U.S. Census 2004 County Business Patterns320
State
Petroleum Refineries (NAICS 32411)
Alabama
6
Florida
6
Louisiana
30
Mississippi
8
Texas
61
Total
111
Reuse of byproducts from petroleum refineries in other sectors carries liability concerns.
However, there does exist a low, but slowly growing, level of interest in reusing sulfidic caustics.
In fact, some individual firms have shown interest and have developed processes for beneficial
reuse. Because sulfidic caustics are likely to be reused within a refinery, ample supply should be
available for beneficial reuse. By 2010, the petroleum industry intends to cut total amount of
finally disposed waste by 67 percent in comparison to 1990 levels.321
3.9.2 Beneficial Drivers and Barriers in Petroleum Refining
Table 3-20 lists petroleum refining byproducts selected for analysis in this paper, along with the
rationale for their selection. As mentioned in Section 3.10.1, manufacturing industries are
exhibiting a slight, but growing level of interest in reusing sulfidic caustics. The following
discussions present drivers that are leading to this beneficial reuse and barriers that present
challenges to increasing the level of cross-sector beneficial reuse. The petroleum refining
industry also uses nonhazardous tank bottoms as an alternative fuel for coking operations, as
discussed in Section 3.9.
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Table 3-20: Byproducts from Petroleum Refining (NAICS: 32411) Selected for Analysis322
Byproducts
Reuse
Rationale for Inclusion
Sulfidic Caustics
•	A bleach for pulp in paper manufacturing facilities
•	Feedstock for manufacturing sulfuric acid323
•	Merichem's proprietary manufacturing process in Houston,
Texas, uses sulfidic caustic as a substitute for other
commercially available chemical products324 (Substitution
for other commercially available products is considered a
non-waste by EPA)
•	Some specialty chemical companies will buy spent caustic
streams from refiners to recover the phenol value325
•	At least one firm is
reusing sulfidic caustics
in manufacturing
process; therefore, it is
likely these byproducts
are produced in
quantities significant
enough for beneficial
reuse
•	Potential for more reuse
to occur outside the
refinery; sulfidic caustic
has the least potential
for reuse within a
refinery326, but there is
legitimate potential for
more reuse across
sectors
•	Reuse potential across
two sectors of interest
for nonfuel uses
Byproducts from Other Sectors Used in Petroleum Refining
Nonhazardous
Tank Bottoms
(from oil and gas
exploration; see
Section 3.9.2)
• As feedstock for coking operations32'
See Oil and Gas for
rationale
3.9.2.1 Sulfidic Caustics
Economic/Market Drivers and Barriers
Phenolic compounds can be recovered from caustics and used as inputs into manufacturing
processes. However, the cost effectiveness of recovering phenolic compounds for beneficial
reuse depends on proximity of the recovery facilities to the refinery.328 Such beneficial reuse
may be less expensive than treatment and discharge to a wastewater treatment plant.
Regulatory/Programmatic Drivers and Barriers
EPA excludes from the Resource Conservation and Recovery Act (RCRA) hazardous waste
regulations spent caustics generated by petroleum refineries when they are reused as a feedstock
in the manufacture of certain commercial chemical products.329 This exclusion can lower barriers
to beneficial reuse by reducing compliance costs.
Environmental Effects
By taking materials out of the wastewater discharge stream, beneficial reuse of spent caustics
reduces strain on wastewater treatment facilities.
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4.0	Discussion and Findings
Our research and analysis reveals themes in the
drivers and barriers affecting cross-sector beneficial
reuse of byproduct materials. As illustrated in the
sector specific discussions in Section 3, we found that
the themes ran across all three categories:
economic/market drivers and barriers; regulatory/programmatic drivers and barriers; and
environmental effects. These findings may be useful in informing future EPA research efforts,
policy and/or voluntary initiatives, as well as outreach efforts to potential stakeholders interested
in beneficial reuse of byproduct materials (e.g., industry, federal and state governments,
regulatory agencies, industry groups).
4.1	Economic/Market Drivers and Barriers
Several economic/market drivers and barriers affect most of the industrial sectors examined in
this paper. Each of these drivers and barriers can shape the supply and demand for beneficial
reuse of byproducts.
1. Geographic Distribution. The distance between byproduct generators and potential end
users, access to transportation corridors (highway, rail), and associated transportation costs affect
beneficial reuse across all of the sectors analyzed for this paper. Plotting the locations of
industrial sectors in a region of interest is an initial step to identifying potential flows between
byproduct generators and end users and addressing the challenge of geographic distribution.
Figure 4-1 illustrates such as exercise, presenting the locations of seven industrial sectors in a
region within Texas. Plotting facility locations on a map that includes road and railroad corridors
may readily illustrate potential beneficial reuse pathways. For example, the numerous
establishments from several sectors and ease of access to transportation at the convergence of I-
35 and 1-45 indicate potential opportunities for byproduct pathways. Organizations interested in
material exchanges might also look at the area along the southern part of 1-45, in which there is a
cluster of two to three forest products establishments, two to five foundries, more than 20 electric
power generation facilities, and two cement manufacturing facilities, all within 25 miles of one
another.
Chapter 4.0 Findings
4.1	Economic/Market Drivers and Barriers
4.2	Regulatory/Programmatic Drivers and
Barriers
4.3	Environmental Effects
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Figure 4-1: Geographic Distribution and Density of Establishments in Seven Industry Sectors as
Characterized by US Census 2004 County Business Patterns
Area of Interest
Cement Manufacturing (2004)
ft 1 Establishment
ฎ 2 Establishments
More than 2 Establishments
Electrical Power Generation
at Fossil Fuel Plants (2005)
•	1 to 10 Establishments
•	11 to 20 Establishments
0 More than 20 Establishments
Chemicals (2004)
*	1 Establishment
2 to 4 Establishments
3|ฃ More than 4 Establishments
Forest Products (2004)
*	1 Establishment
ฆ	2 to 3 Establishments
ฆ	More than 3 Establishments
Petroleum Refining (2004)
~	1 Establishment
+ 2 to 4 Establishments
+ More than 4 Establishments
Foundries (2004)
~	1 Establishment
~	2 to 5 Establishments
^ More than 5 Establishments
Iron and Steel Mills (2004)
*	1 Establishment
A 2 to 3 Establishments
^ More than 3 Establishments
G u If
of
Mexico
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2.	Relative Convenience and Lower Cost of Landfilling. The easiest and cheapest means of a
facility ridding itself of most byproducts is a landfill. Unless a material has a market value such
that an end user is willing to pay top dollar for it (e.g., scrap metal or petroleum coke), incentives
must be in place for beneficial reuse. Otherwise, a generator is more likely to dispose of
byproducts in the closest landfill, which is most likely more convenient than arranging and
transporting for beneficial reuse.
In addition, tipping fees charged for waste disposal tend to be relatively low, especially in the
southeastern states, which may make landfilling a less expensive option when compared to the
effort of locating an end user and transporting or arranging for transport of byproducts for reuse.
Tipping fees vary significantly from one location to another. Tipping fees for both municipal
solid waste (MSW) and construction and demolition (C&D) waste in the southeastern U.S. were
among the lowest in the country in 2005, at an average of $33.43 per ton, as compared to the
average of $67 per ton in the northeast.330 Nationally, these average tipping fees have risen
steadily each year and are expected to continue to rise. As tipping fees increase and become
expensive enough for generators to consider alternatives to disposal, beneficial reuse may
become a more desirable option.
Land for landfills is relatively cheap and plentiful in the Gulf Coast. Without scarcity of land
leading to restrictions on landfill disposal (and therefore encouraging beneficial reuse), economic
incentives may be more important, and possibly more effective, in encouraging reuse. For
example, a tax break for companies engaging in documented beneficial reuse may steer more
facilities to that option.
Some localities have taken specific actions to create disincentives to landfill disposal.
Vancouver, British Columbia, Canada, banned gypsum wallboard in landfills, because the
material's breakdown creates hydrogen sulfide gas, a human health hazard. This type of active
governmental decision creates a strong barrier to landfill disposal and a strong driver to get
byproducts into the hands of potential end users.
3.	Inconsistent Quantities and Composition of Byproducts. Beneficial reuse projects often
require a minimum quantity of byproduct and a specific composition and consistency to make
reuse in a manufacturing process feasible. Numerous small- to medium-sized facilities comprise
most of the sectors, making accumulation of significant amounts of byproduct challenging. This
characterization is also illustrated by the size of the clusters displayed in Figure 4-1. Thus, even
though industries are generating reusable byproducts, volumes from one or even a few facilities
may be insufficient for beneficial reuse in certain manufacturing processes. In addition, if the end
user is paying for byproduct transport, transportation of one large shipment can be much more
cost effective than transportation of multiple small shipments.
The prevalence of small generators may also contribute to inconsistent physical and chemical
compositions of byproducts. Although consolidation and blending of byproducts could address
these barriers, establishing a network to accomplish this can be a daunting task. In addition, some
states prohibit mixing of byproducts from different facilities, thereby inhibiting the collection of
threshold quantities of byproduct needed for input into manufacturing processes.
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This "inconsistent quantities and composition" barrier could be addressed through federal and/or
state regulatory frameworks relating to storage, transportation, and/or mixing of waste products.
Depending on byproduct materials and regulations in place, storage of a material may be a viable
option for a generator until a sufficient quantity is produced to make transportation of the
material economically feasible. In addition, consolidator firms may address this barrier by
picking up byproducts from small volume generators, accumulating shipments until a "critical
mass" is gathered, and then transporting the material to an end user. To make transportation and
consolidation effective, other organizations, facilities, and/or governments addressing the
"inconsistent quantities" barrier might also think in terms of facility clusters (see the
"Geographic Distribution" barrier discussion).
4.	Awareness and Marketing. Lack of awareness of the connections between generators and
potential end users creates another barrier to beneficial reuse, even where the markets for reuse
exist. Whether generators are unaware that potential end users exist nearby or end users are
unaware that byproducts can be used in their manufacturing process, matching up these entities
can be a challenging process. The lack of connections can also lead to generators incurring costs
to find end users or third parties who will broker their byproducts to potential end users. Several
industry trade associations and beneficial reuse organizations have led awareness and marketing
efforts to address this barrier, and state programs, such as Texas' RENEW, are making
connections between generators and end users to increase beneficial reuse. Some local
government entities in Europe are addressing this issue by coordinating the exchange of
materials, ensuring quality of materials, and examining the economic costs and benefits of
beneficial reuse.
5.	Standards and Specifications. Some states and industries have developed standards to
address the beneficial reuse of byproducts in manufacturing, engineering, and construction. For
example, several state departments of transportation (DOTs) have instituted specific engineering
standards for reuse of foundry sands and coal combustion products (CCP) in road base, asphalt,
and embankments. For other industries, however, states or organizations have only distributed
very generalized information on beneficial reuse of industrial byproducts. In addition,
specifications that are in place are not always effective. For instance, the beneficial reuse of
asphalt shingles in pavement has the potential to keep the shingles out of landfills. However,
some specifications, such as those in Texas that require separation of manufacturer and post-
consumer asphalt waste, may contain provisions that are difficult, costly, or time-consuming to
meet. Specifications that are carefully crafted may enable beneficial reuse by taking away
uncertainty associated with engineering properties, while still providing some flexibility in
consolidation and reuse options.
A 2003 meeting held by EPA's National Center for Environmental Innovation (NCEI) found the
potential for liability creates increased costs with beneficial reuse.331 Published manufacturing
specifications for input of byproducts may diminish the uncertainty of liability and production
issues associated with bringing a byproduct into the manufacturing process, thereby lowering
barriers to beneficial reuse. However, specifications must be relevant and attainable to help
drive beneficial reuse.
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6. Core Competency. Core competency is a business concept describing "an area of specialized
expertise that is the result of harmonizing complex streams of technology and work activity."332
Beneficial reuse is not a core competency for many manufacturing sectors, which creates
challenges in overcoming perceived notions of the time and cost involved to beneficially reuse
materials. A key barrier to beneficial reuse is overcoming the hesitancy of firms to investigate
reuse opportunities based on a lack of information about the reuse process and its potential
benefits to the firm. Due to this lack of information, some industries may not understand the
value to production (or the upfront costs in terms of staff expertise and research necessary) that
can make beneficial reuse a viable alternative to standard treatment and disposal practices. The
cement sector is an example of one industry that has made beneficial reuse part of its core
competency, meeting and even exceeding industry goals for beneficial reuse.
If industries and stakeholders approach the concept of beneficial reuse by "thinking with the end
in mind," they may shift away from the a waste management chain that consists of waste
generation, followed by waste treatment, followed by waste disposal. Although some
manufacturing processes cannot be modified to incorporate collection of byproducts, many firms
can facilitate more beneficial reuse by analyzing their processes and their waste streams,
assessing potential end users, and modifying "end-of-pipe" processes to collect and convey the
byproducts to end users. As shown by the Dow Byproduct Synergy project, this can be a
collaborative effort between industries and governments. Finally, where industries and firms can
be shown quantifiable evidence of the benefits of beneficial reuse, they may be more willing to
consider modifying their core competencies to include beneficial reuse.
4.2 Regulatory/Programmatic Drivers and Barriers
We found that state government regulations and non-regulatory programs (described in Section
2) typically have a significant effect on the beneficial reuse of industrial byproducts. State
regulations in Gulf States vary in their complexity, levels of allowable beneficial reuses, and
even required processes for state approval of beneficial reuse. Inconsistent state regulations and
approval processes on beneficial reuse can inhibit cross-sector reuse across state lines when
generators and end-users must be compliant with two or more sets of regulatory requirements.
We found that materials are more likely to be safely reused when state regulations and non-
regulatory programs encourage industry to initiate reuse activities while also ensuring adequate
protection of human health and the environment.
1. State Regulations Specific to Beneficial Reuse. Although regulations may be seen by some
as a barrier to beneficial reuse because they outline restrictions on beneficial reuse activities,
regulations also provide generators and end users with a predictable process. The steps outlined
in regulations, such as those in Louisiana, may provide generators and end users with assurance
that, by following the requirements, they will be able to lawfully reuse industrial byproducts.
Therefore, regulations may reduce the regulatory uncertainty generators and end users face when
deciding whether or not to reuse certain byproducts. A lack of regulatory limitations on reuse
activities, such as in Alabama and Florida, may lower barriers to beneficial reuse because
generators and end users will not incur costs associated with obtaining approval from the state.
However, as discussed in Section 2.0, some review and approval processes, such as Florida's
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case-by-case reviews, might result in some limitations on reuse requirements, despite the lack of
regulations.
2.	State Regulations Specific to Beneficial Reuse of Certain Materials. Some states have
beneficial reuse regulations that pertain to specific byproducts, either in lieu of or in addition to
the state's general beneficial reuse regulations. These regulations governing reuse of specific
materials may provide generators and end users with a predictable process and reassure them
that, by following the requirements, they will be allowed to lawfully reuse specific industrial
byproducts. For example, Alabama's beneficial reuse regulations for foundry sand regulations
give generators and end users of that material certainty about their regulatory requirements when
initiating reuse.
3.	Exemptions for Beneficial Reuse Activities Proven to be Safe. Providing exemptions for
specific beneficial reuse activities may lower barriers to beneficial reuse. For example,
Louisiana has specific regulations for the pulp and paper industry, which include pre-approved
reuse activities, including use as ingredients, raw materials, or feedstocks in industrial processes
to make products; use as effective substitutes for commercial products; and land application
reuses. By lifting the application requirement for pulp and paper byproducts in specific reuses,
Louisiana is removing a barrier to reuse. Mississippi's regulations allow generators or end users
to pursue beneficial reuse activities that are "Standing Uses" without applying to the state for
approval and exempts generators or end users who pursue a Standing Use from the annual
reporting requirement.
4.	Exemptions for Byproducts that are Effective Substitutes for Raw Materials. By
exempting from regulation those byproducts that are effective substitutes for raw materials, some
states reduce a generator's or end user's costs for compliance with solid waste transport and
disposal requirements. With lower costs, a generator or end user may be more inclined to
participate in beneficial reuse activities. For example, in Louisiana, pulp and paper byproducts
that are used as raw materials in an industrial process or as effective substitutes for commercial
products are exempted from generator, transporter, or permitting requirements under Louisiana's
solid waste regulations.
5.	State Agency Specifications and Standards. As with specifications published by standards
organizations and supported by trade associations, those published by state agencies can also
lower barriers to reuse. In Texas, the state DOT established specifications that specifically call
or allow for the use of recycled materials in road and transportation construction.333 By providing
the public with this information, the state DOT is helping generators and end users identify
suitable materials for construction reuse activities.
6.	Investment in Outreach, Education, and Marketing Programs. Outreach efforts educate
generators and end users about beneficial reuse opportunities and may serve as a catalyst to
encourage beneficial reuse activities. To encourage reuse, TCEQ provides various guidance
documents regarding beneficial reuse of byproducts on their website. In addition to the outreach
materials, TCEQ sponsors the RENEW program, which is a marketing channel for generators
and end users. RENEW helps generators of various byproducts connect with potential end users,
which is a driver for reuse.
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7.	Government Resources. Encompassing both economic/market and regulatory/programmatic
issues are the resources available for governments to run beneficial reuse programs. Median
income levels in the Gulf Coast states are lower than in many other areas of the country, which
limits the tax revenue available for state and local agencies to run environmental programs. In
fact, Alabama ranks last out of all 50 states for the amount of money available and spent on
environmental issues.334 Although government agencies may not be able to dedicate resources to
providing information and insight into beneficial reuse, some industry organizations have
stepped in to fill this need, devoting time and resources to research and education on beneficial
reuse opportunities.
8.	Sampling and Testing Requirements. Material sampling and testing requirements are often
necessary to protect human health and the environment. However, requirements that are not
clearly defined may create barriers to beneficial reuse. For instance, Louisiana's regulations do
not specify the constituents to test for, the constituent concentration thresholds, or the testing
method to be used. Such a lack of specificity can cause uncertainty on the part of generators or
end users, who may perceive beneficial reuse activities as too risky in terms of liability and
enforcement. If a generator characterizes its waste in one way, identifying certain constituents,
and the LA DEQ disagrees with the generator's approach to the analysis, the generator may need
to re-run the analysis. These uncertainties discourage reuse because of the time and cost to gain
approval.
9.	Approval Process. When states incorporate an approval process into their regulations and
beneficial reuse programs, the states gain greater oversight of beneficial reuse. However,
generators and end users may view multiple layers of approvals as a barrier to reuse, because the
additional approvals may increase the costs of and time needed to initiate beneficial reuse
activities. For example, in Louisiana, for nearly all beneficial reuse activities, a generator or end
user must submit an application to the LA DEQ and receive the agency's approval. For
byproducts from the pulp and paper industry, in certain cases industry also needs approval for the
reuse activities from the LA Department of Agriculture and Forestry. In Mississippi, for
byproducts that fall within Categories II-IV, a generator or end user must submit an application
to the MS DEQ and receive the agency's approval. In addition to the MS DEQ's approval, for
byproducts that will be used in engineered construction or other civil engineering uses (Category
II), a PE licensed in Mississippi must certify that the byproduct is suitable for the proposed
construction or civil engineering use. Generators and end users may view these multiple layers of
certification and approvals as a barrier to reuse because of the added costs and time.
10.	Permit Requirements. In some cases, generators or end users of byproducts face additional
costs associated with obtaining permit modifications. These costs may serve as a disincentive to
initiating beneficial reuse of the byproducts. For example, in Louisiana, before removing the
materials from the landfill or surface impoundment, a generator or end user must obtain a Solid
Waste Permit Minor Modification. However, once the byproducts are removed from the facility,
they are no longer subject to generator, transporter, or permitting requirements under Louisiana's
solid waste regulations.
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4.3 Environmental Effects
As shown in the sector discussions, there are significant positive environmental outcomes and
the potential for some negative outcomes as well. The positive outcomes are compelling. First,
and probably foremost, the use of secondary materials obviates the need to harvest virgin
materials for the same use. In cases where the extracting the virgin material is very damaging,
such as most mining activities, the benefits are significant. However, not all harvesting or
extraction has the same level of environmental damage, so this benefit varies from material to
material.
In some cases, the by-product is also prepared in a less environmentally damaging manner than
the virgin material. For example, using fly ash in concrete reduces the need for Portland Cement
production, which generates relatively high greenhouse gas emissions.335 Also, in many
situations, the generators and end users are located closer to each other than they are to the virgin
materials. The shorter transportation requirements lead to reduced air emissions, energy
consumption, and other environmental impacts from transportation. There are also specific
benefits for many materials, such as decreased water use, filtering capability, or ability to use the
material in cooler weather. In almost every case, the beneficial reuse diverts byproducts from
landfill disposal, conserving land for other purposes.
All of these factors together usually results in massive environmental gains. For example,
energy savings associated with the use of fly ash and FGD gypsum totals approximately 167
billion megajoules of energy (or approximately $4.7 billion in 2007 energy prices). Based on the
average monthly consumption of residential electricity customers, this is enough energy to power
over 4 million homes for an entire year. Avoided water use totals approximately 121 billion liters
or approximately $76.9 million in 2007 water prices). This is roughly equivalent to the annual
water consumption of 61,000 Americans.336
Another example is also from a recent EPA economic report on foundry sand. Beneficial reuse
of foundry sand has significant impacts that include energy savings and water use reductions
associated with avoided extraction of virgin sands. Total energy savings are approximately 224
million megajoules of energy (or approximately $6.2 million in 2006 energy prices), and 36
million gallons of water (or approximately $88,000 in 2006 energy prices). Other key impacts
include greenhouse gas (C02) emissions reductions of approximately 18,000 megagrams,
particulate matter emissions of approximately 267,000 kilograms and reductions in RCRA
hazardous waste generation of nearly 289,000 kilograms.337
Negative environmental effects can run the gamut from benign to significant environmental
effects if mismanaged. However, in every case a carefully designed state program that is
protective, but also simple for the regulated community to navigate, can mitigate potential
environmental damages. The risks (which are usually far less than the benefits) tend to vary not
only with the nature of the material, but also with the use. Bound applications, such as use of a
material in cement or asphalt, generally require far less scrutiny than unbound applications, such
as road bases, embankments, and soil amendments. However, we also found that a relatively
benign material that is reused in an unbound application can be as safe (or more safe depending
on the nature of the virgin materials) as use in bound applications. It is important to evaluate not
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only the material and its use, but the background levels in the soils where it will be used. In
some cases, state programs have established requirements that are equal to or higher than the
background levels that already exist. In those cases, it may be appropriate to allow the permit-
seeker to make an alternative demonstration to the state authority.
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End Notes
1	U.S. EPA's website reports that the U.S. annually generates 7.6 billion tons of industrial solid waste
(http://www.epa.gov/industrialwaste/) and that in 2003, the country generated more than 236 million tons of
municipal solid waste (http://www.epa.gov/garbage/facts.htm).
2
Lynn Roper, Alabama Department of Environmental Management. Program Support Unit (Waste Approvals).
Personal Communication with Liz Gormsen, ICF International, April 2007.
3	Lynn Roper, Alabama Department of Environmental Management. Program Support Unit (Waste Approvals).
Personal Communication with Liz Gormsen, ICF International, January 2008.
4	www.dep.state.fl.us/waste/categories/solid waste/pages/beneficialuse.htm
5	Richard Tedder, Florida Department of Environmental Protection. Solid Waste Section. Personal Communication
with Liz Gormsen, ICF International. 16 October 2007.
6	Bijan Sharafkhani, Louisiana Dept. of Environmental Quality, Administrator, Waste Permits Division. Personal
Communication with Liz Gormsen, ICF International on 19 October 2007.
7
Mike Lindner. Texas Council on Environmental Quality. Personal Communication with Liz Gormsen, ICF
International on 17 October 2007.
g
Cement Americas, 2005 North American Cement Directory, published by Primedia Business Magazines and
Media, Chicago, IL, 2004.
9	United States Geological Survey. Minerals Yearbook, Cement: 1999
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/170499.pdf (accessed on October 19, 2007)
10	United States Geological Survey. Minerals Yearbook, Cement: 2004
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/cemenmvb04.pdf (accessed on October 19, 2007)
11	Cement Americas, 2005 North American Cement Directory.
12	Van Oss, 2006. Background Facts and Issues Concerning Cement and Cement Data, Hendrik G. van Oss, Open-
File Report 2005-1152, U.S. Geological Survey, 2006, http://pubs.usgs.gOv/of/2005/l 152/2005-1152.pdf. Page 33
(accessed on October 19, 2007)
13Portland Cement Association, 2007 Report on Sustainable Manufacturing,
http://www.cement.org/smreport07/sec page3 2.htm (accessed on October 19, 2007)
14	Portland Cement Association, 2007 Table on Historic Cement Kiln Dust Production, September 18, 2007.
15	Portland Cement Association, 2007 Report on Sustainable Manufacturing,
http://www.cement.org/smreport07/sec page3 2.htm (obtained on October 19, 2007)
16	Portland Cement Association, 2007 Report on Sustainable Manufacturing,
http://www.cement.org/smreport07/sec pagel 3 C.htm (accessed on October 19, 2007)
17	United States Geological Survey. Minerals Yearbook, Cement: 1999, 2000, 2001, 2002, 2003, 2004, 2005
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/ (accessed on October 19, 2007)
18	Portland Cement Association. www.cement.org/smreport07/images/graphs_maps/GR_CKDUSES_S.jpg
'Portland Cement Association, 2007 Report on Sustainable Manufacturing,
http://www.cement.org/smreport07/slag raw materials.htm (accessed on October 19, 2007)
20	Portland Cement Association, 2007 Report on Sustainable Manufacturing,
http://www.cement.org/smreport07/flv ash raw materials.htm (accessed on October 19, 2007)
21	American Coal Ash Association (ACAA), CCP Production & Use Surveys (2001 through 2005)
http://www. acaa-usa.org/CCPSurvevShort.htm (accessed on October 19, 2007)
22	Portland Cement Association, 2006 U.S. and Canadian Portland Cement Industry: Plant Information Summary,
http://www.cement.org/smreport07/sec page2 l.htm (accessed on October 19, 2007)
23	United States Geological Survey. Minerals Yearbook, Cement: 1999
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/170499.pdf (accessed on October 19, 2007)
24	United States Geological Survey. Minerals Yearbook, Cement: 2004
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/cemenmvb04.pdf (accessed on October 19, 2007)
25	United States Geological Survey. Minerals Yearbook, Cement: 2005
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/cemenmvb05.pdf (accessed on October 19, 2007)
26United States Geological Survey. Minerals Yearbook, Cement: 2000
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/17040Q.pdf (accessed on October 19, 2007)
27 United States Geological Survey. Minerals Yearbook, Cement: 2001
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/cememvbO 1 .pdf (accessed on October 19, 2007)
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
Endnotes-1

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28	U.S. Geological Survey. Minerals Yearbook, Cement: 1999, 2000, 2001, 2002, 2003, 2004, 2005.
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/
29	U.S. Geological Survey. Minerals Yearbook, Cement: 1999, 2000, 2001, 2002, 2003, 2004, 2005.
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/
30	http://minerals.usgs.gov/minerals/pubs/commoditv/iron & steel slag/79040l.pdf
31	Scrap tires are outside the scope of this study because scrap tires are a "post-consumer" waste and not an
industrial process byproduct. Approximately 400,000 metric tons of scrap tires were used as alternative fuel in
cement kilns in 2003, 2004, and 2005.
32	U.S. and Canadian Labor-Energy Input Survey 2006, Portland Cement Association and Economic Research,
December 31, 2006.
33	Portland Cement Association, 2007 Report on Sustainable Manufacturing,
http://www.cement.org/smreport07/images/graphs maps/MA TDF S.jpg (accessed on October 19, 2007)
34	Lehigh Cement Company website (http://www.lehighcement.com').
35	United States Geological Survey. Minerals Yearbook, Cement: 1994
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/170494.pdf (accessed on October 19, 2007)
36	United States Geological Survey. Minerals Yearbook, Cement: 2004
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/cemenmvb04.pdf (accessed on October 19, 2007)
37	www.bvproductsummit.com/midwest/summit/rmt rpt.pdf
38	USGS data
39	http ://www .cement. org/smreport06/sec_page3_2. htm
40	http ://www .cement. org/smreport06/sec_page3_2. htm
41	http ://www .cement. org/smreport07/sec_page3_2. htm#
42	http://www.cement.org/concretethinking/pdf files/SP401.PDF
43	http://www.cement.org/smreport06/sec_page3_2.htm
44	http://www.hatch.ca/Sustainable Development/Proiects/cemstar process.htm
45	http://findarticles.eom/p/articles/mi mONSX/is 1 49/ai 112905707 Patented grinding technology offers new
ready-mix options: Portland cement substitute yields economic, environmental, and durability benefits - Innovations
Concrete Construction. January 2004 by Tom Klemens
46	Van Oss, 2006. Background Facts and Issues Concerning Cement and Cement Data, Hendrik G. van Oss, Open-
File Report 2005-1152, U.S. Geological Survey, 2006, http://pubs.usgs.gOv/of/2005/l 152/2005-1152.pdf Page 40.
47	http://www.hatch.ca/Sustainable Development/Articles/Cemstar Production Profit.pdf
48	http://minerals.usgs.gov/minerals/pubs/commoditv/cement/17040Q.pdf
49	Industrial Resources Council Briefing, January 23, 2007, EPA Office of Solid Waste.
50	http://www.titanamerica.com/about/environment.html
51	Industrial Resources Council Briefing, January 23, 2007, EPA Office of Solid Waste.
52	http://www.epa.gov/ttn/atw/pcem/fr20de06.pdf 71 FR 76525
53	http://www.epa.gov/ttn/atw/pcem/fr20de06.pdf 71 FR 76525
54	American Chemistry Council, Snapshot of the Chemical Industry. Accessed on October 8, 2007.
http://www.americanchemistrv.eom/s acc/sec statistics.asp?CID=293&DID=748
55	U.S. Census Bureau. 2004 County Business Patterns: Geography Area Series: County Business Patterns for the
U.S. http://factfinder.census.gov/servlet/IBOTable? bm=v&-ds name=CB0400Al&-ib tvpe=NAICS2002&-
NAICS2002=2211132211324111325113252132531325413273101331113315&- industrv=3254&-
NAICS2002sector=*4&- lang=en&-fds name=EC0200Al. Queried on 27 January 2007.
56	An LQG is a facility that generates greater than 1,000 kilograms (2,200 pounds) of hazardous waste in a calendar
month.
57	It should be noted that some states use a lower state-defined threshold for LQGs, count wastes regulated only by
their states, or count wastes exempt from federal regulation. Reporting facilities and their generated and/or managed
waste quantities presented here are for the reporting year 2005. Data reported can include hazardous waste streams
such as wastewater and sediment that have the potential to skew data when viewed by annual tons reported, making
year-to-year comparisons problematic.
58	Commission for Environmental Cooperation. Taking Stock: 2003 North American Pollutant Releases and
Transfers. July 2006. http://www.cec.org/files/PDF/POLLUTANTS/TSQ3 en.pdf. p. 54
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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59	US Department of Energy, Energy Efficiency and Renewable Energy. Chemicals: Best Practices Plant-Wide
Case Assessment Study. September 2005. 29 October 2007. http://www.usbcsd.org/pdf%5CDow Case Studv.pdf
60	EPA has requested data from Dow and USBCSD. When those data become available, they will be included in
subsequent versions of this report.
61	USEPA, "Building Savings: Strategies for Waste Reduction of Construction and Demolition Debris from
Buildings," June 2000, 20 Sept. 2006 .
62	U.S. Census Bureau. "2004 County Business Patterns: Geography Area Series: County Business Patterns for the
U.S.", 12 Dec. 2006, 27 Jan. 2007 .
63	Bradley Guy and Scott Shell. Design for Deconstruction and Materials Reuse. 19 Dec. 2006
.
65	North Central Texas Council of Governments. "Construction and Demolition Waste Minimization Strategies for
North Central Texas Region." August 2005. 25 October 2007.
http://www.nctcog.org/envir/SEELT/documents/NCTCOG C D Final Report.pdf
66	USEPA. "Green Buildings," 2005, 19 Dec. 2006 .
67	"Demolition Man," Scrap Magazine, March/April 2007, pp.133 - 144.
68	Gaye Farris, "USGS Reports Preliminary Wetland Loss Estimates for Southeast Louisiana From Hurricanes
Katrina and Rita," USGS. 1 Nov. 2005, 18 Dec. 2006 .
69	Shingle Recycling.org, 19 Dec. 2006 .
70	Ken Sandler, "Analyzing What's Recyclable in C&D Debris," BioCvcle. Nov. 2003: Vol. 44, Iss. 11; p. 51.
71	TxDOT. "April Roofing Shingles," Year of the Recycled Roadway Materials. 19 Oct. 2006
.
73	Ken Sandler, "Analyzing What's Recyclable in C&D Debris," BioCvcle. Nov. 2003: Vol. 44, Iss. 11; p. 52.
74	Associated General Contractor's of America, "Recycle This!" 19 Dec. 2006
.
75	Robert H. Falk and David B. McKeever, "Recovering wood for reuse and recycling A United States Perspective,"
Management of Recovered Wood Recycling. Bioenergy. and other Options, ed. Christos Gallis (Thessaloniki:
University Studio Press, 2004) 29-40.
76	DrywallRecycling.org, 19 Dec. 2006 .
77	Citrus County Government, The New River Solid Waste Association, and Okaloosa County Government, "Citrus
County, Putnam County, Okaloosa County and the New River Solid Waste Association, 1998-1999 Innovative
Grant Project: Recycling Of Discarded Gypsum Drywall in Florida," 31 Jan. 2001, 19 Oct. 2006
.
78	"Wallboard (Drywall) Recycling," California Integrated Waste Management Board. 26 July 2007, 22 Oct. 2007
.
79	"Gypsum Wallboard Recycling," Gypsum Recycling International. 22 Oct. 2007
.
80	Gypsum Recycling International. 19 Oct. 2006 .
81	"GRI Chosen as Recycling Partner," Gypsum Recycling International. 19 Oct. 2006
.
82	"Board of Directors Meeting," NERC. 25 Oct. 2006
.
Also note that the easiest to reuse, new construction and manufacturing scrap, consist of the largest component of
waste. This means that there is plenty of opportunity to effectively reuse this scrap using current technological
methods.
83	"Gypsum Wallboard Recycling," Gypsum Recycling International. 22 Oct. 2007
.
84	"Gypsum Powder Uses." Gypsum Recycling International. 22 Dec. 2006
.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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85	Mike Taylor, "Demolition Man," Scrap Magazine, March/April 2007, pp.136.
86	North Central Texas Council of Governments. "Construction and Demolition Waste Minimization Strategies for
North Central Texas Region." August 2005. 25 October 2007.
http://www.nctcog.org/envir/SEELT/documents/NCTCOG C D Final Report.pdf
87	U.S. Census. "Annual Estimates of Population Change for the United States and States and for Puerto Rico and
State Rankings: April 1, 2000 to July 1, 2006." 1 July 2006. 25 October 2007.
http://www.census.gov/popest/datasets.html.
88	Kimberly Cochran, USEPA. Email communication to Jeff Kohn, EPA. 2January 2008.
89	"Recycling," Florida Department of Environmental Protection. 2006, 25 Oct. 2006
.
90	Susan Boroff, Personal Interview, 5 January 2007.
91	TNRCC - Strategic Investment Division, "Solid Waste Management in Texas Strategic Plan 2001-2005," Texas
Natural Resource Conservation Commission. Dec. 2000, 25 Oct. 2006
http://www.tcea.state.tx.us/assets/public/comm exec/pubs/sfr/042 Ol.pdf and
"Biennial Report to the 79th Legislature FY2003-FY2004," Texas Commission on Environmental Quality. Dec.
2004, 25 Oct. 2006 .
92	Mike Taylor, "Demolition Man," Scrap Magazine, March/April 2007, pp.134, 137.
93	State Task Force on Recycling, "Report to the Mississippi Legislature," 31 Dec. 2004, 25 Oct. 2006
.
94	Mike Taylor, "Demolition Man," Scrap Magazine, March/April 2007, pp.134.
95	Patrick Dolan, Richard Lampo, and Jacqueline Dearborn. 1999. "Concepts for Reuse and Recycling of
Construction and Demolition Waste," US Army Corp of Engineers. June 1999, 20 Sept. 2006
.
96	International Residential Code briefing for U.S. EPA Office of Solid Waste, 23 January 2007 in Arlington,
Virginia.
97	"Improved Bituminous Concrete Base, Binder, and Wearing Surface Layers," Alabama Department of
Transportation. 1998, 22 Oct. 2007
.
98	Randy Mountcastle, Alabama DOT, Personal Interview, 29 Dec. 2006.
99	TxDOT. "April Roofing Shingles," Year of the Recycled Roadway Materials. 19 Oct. 2006
.
100	TxDOT, "Special Specification Item 3028 Hot Mix Asphaltic Concrete Pavement Containing Reclaimed Roofing
Shingles," 1995, 22 Dec. 2006 .
101	Construction and Demolition Recycling. "Proposed Regulations Trouble New Jersey Concrete Recyclers," 12
Oct. 2006, 16 Oct. 2006 .
102	TxDOT, "Specifications Using Recycled Materials," 2006, 22 Dec. 2006
.
Shiou-San Kuo, Hesham S. Mahgoub, and Jose E. Ortega, 2001. "Use of Recycled Concrete made with Florida
Limestone Aggregate for a Base Course in Flexible Pavement," Florida DOT. Oct. 2001, 22 Dec. 2006
.
103	State Wetlands Conservation and Restoration Authority. "State of Louisiana Wetlands Conservation and
Restoration Plan", Feb. 2004, 22 Dec. 2006 .
Providence Engineering, "Disposition of Storm Generated Debris: An Analysis of the Composition, Handling,
Disposal, and Potential Reuse of Storm-Generated Debris in Louisiana Coastal Restoration Projects," 22 Dec. 2006
.
104
Mississippi Department of Marine Resources. "Jackson County Mississippi Coastal Impact Assistance Plan Tier
2 Project Description." no date. 18 January 2008. http://www.dmr.state.ms.us/ciap/project-proposals/pdfs/30.729-
jackson-county-restoration-creation-maintenance.pdf no date.
105	Construction and Demolition Recycling. "Proposed Regulations Trouble New Jersey Concrete Recyclers," 12
Oct. 2006, 16 Oct. 2006 .
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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106	Brad Guy, BMRA, Personal Interview, 12 Oct. 2006.
107	EnviroSense. "1993/1994 Gypsum Market Profile August 1994," USEPA. 1995, 22 Dec. 2006
.
108	Brad Guy, Personal Interview, 12 Oct. 2006.
109	"Gypsum Wallboard Recycling," Gypsum Recycling International. 22 Oct. 2007
.
110	"Company profile," Gypsum Recycling International. 2006, 19 Dec. 2006
.
111	SWAN A, "Hurricane Katrina Disaster Debris Management: Lessons Learned from State and Local
Governments," 21 Sept. 2005, 23 Aug. 2006 .
112	Power Products Engineering for the American Coal Council, The Value of Coal Combustion Products: An
Economic Assessment of CCP Utilization for the US Economy (Phoenix, AZ: American Coal Council, 2005) 13-18.
113	U.S. Census Bureau, "2004 County Business Patterns," 28 Oct. 2008, 27 Jan. 2007
.
114	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
115	Power Products Engineering for the American Coal Council, The Value of Coal Combustion Products: An
Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005) 1-
128.
116	Power Products Engineering for the American Coal Council, The Value of Coal Combustion Products: An
Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005) 57.
117	Power Products Engineering for the American Coal Council, The Value of Coal Combustion Products: An
Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005) 1-
128.
118	Power Products Engineering for the American Coal Council, The Value of Coal Combustion Products: An
Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005) 57.
119
2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept 2006).
120
2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
121	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
122	Energy Information Administration, "Annual Energy Outlook 2007 with Projections to 2030," Feb. 2007, 15 Oct.
2007 .
123	Power Products Engineering for the American Coal Council, The Value of Coal Combustion Products: An
Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005) 1-
128.
124	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
125	Industrial Resources Council Briefing (EPA Office of Solid Waste, 23 Jan. 2007).
126	Industrial Economics, Incorporated prepared for U.S. EPA, Waste Materials-Flow Benchmark Sector Report:
Beneficial Use of Secondary Materials - Coal Combustion Products. (15 Dec. 2006) 1-29.
127	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
128	Industrial Economics, Incorporated prepared for U.S. EPA, Waste Materials-Flow Benchmark Sector Report:
Beneficial Use of Secondary Materials - Coal Combustion Products. (15 Dec. 2006).
129	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
130	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
131	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006) (unless otherwise
indicated).
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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132 Hendrik G. van Oss, "Cement," U.S. Geological Survey Minerals Yearbook. 2004, 15 Oct. 2006
.
1 H
Hendrik G. van Oss, "Cement," U.S. Geological Survey Minerals Yearbook. 2004, 15 Oct. 2006
.
134	These beneficial uses of CCP are for the making of concrete for use in construction projects, not for the
manufacture of Portland cement.
135	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
136	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
137	American Coal Ash Association, "CCP Survey," 15 Oct. 2007 .
138	Georgia-Pacific, "Products/Gypsum Boards andDrywall," 17 October 2007
.
139	Michael Lenahan, "Mineral By-Products: 'What, Where, and How'" Resource Recovery Corporatioa 30 Jun.
2005, 15 Oct. 2007 .
140	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
141	2004 Survey results for Gulf States (American Coal Ash Association CCP, 8 Sept. 2006).
142	American Coal Ash Association, "CCP Survey," 15 Oct. 2007 .
143	Industrial Economics, Incorporated prepared for U.S. EPA, Waste Materials-Flow Benchmark Sector Report:
Beneficial Use of Secondary Materials - Coal Combustion Products. (15 Dec. 2006) 1-29.
144	U.S. EPA, "Waste Reduction Activities of Selected WasteWi$e Partners: Electric Power Industry: EPA530-R-
97-017," August 1997, 15 Oct. 2007 .
145	U.S. EPA, "Waste Reduction Activities of Selected WasteWi$e Partners: Electric Power Industry: EPA530-R-
97-017," August 1997, 15 Oct. 2007 .
146	U.S. EPA, "Waste Reduction Activities of Selected WasteWi$e Partners: Electric Power Industry: EPA530-R-
97-017," Aug. 1997, 15 Oct. 2007 : Energy & Environmental Research
Center, University of North Dakota, "Review of Florida Regulations, Standards, and Practices Related to the Use of
Coal Combustion Products," Apr. 2006; Energy & Environmental Research Center, University of North Dakota,
"Review of State Regulations, Standards, and Practices, Related to the Use of Coal Combustion Products: Texas
Review Case Study." Jan. 2005.
147	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006; and Energy &
Environmental Research Center, University of North Dakota, "Review of State Regulations, Standards, and
Practices, Related to the Use of Coal Combustion Products: Texas Review Case Study," Jan. 2005.
148	The Clean Coal Technology Demonstration Program (CCTDP), "Coal Utilization By-Products: Topical Report
Number 24," National Energy Technology Laboratory and Department of Energy, Jul. 2006.
149	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
150	U.S. EPA, "Coal Combustion Products Partnership - Fact Sheet," Jan. 2003.
151	Industrial Economics, Incorporated prepared for U.S. EPA, Waste Materials-Flow Benchmark Sector Report:
Beneficial Use of Secondary Materials - Coal Combustion Products. (15 Dec. 2006) 1-29.
152	Email communication from Dave Goss, American Coal Ash Association (ACAA) to Jeff Kohn, EPA, 28
November 2007.
153Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006.
154	U.S. EPA, "Coal Combustion Products Partnership - Fact Sheet," Jan. 2003.
155	The Clean Coal Technology Demonstration Program (CCTDP), "Coal Utilization By-Products: Topical Report
Number 24," National Energy Technology Laboratory and Department of Energy, Jul. 2006.
156	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
157	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
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158	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
159	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
160	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006; and Energy &
Environmental Research Center, University of North Dakota, "Review of State Regulations, Standards, and
Practices, Related to the Use of Coal Combustion Products: Texas Review Case Study," Jan. 2005.
161	Bruce A. Dockter and Diana M. Jagiella, "Engineering and Environmental Specifications of State Agencies for
Utilization and Disposal of CCPs: Volume 2 - Environmental Regulations." Energy & Environmental Research
Center. University of North Dakota. Jul. 2005.
162	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006.
163	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006.
164	Case Study: The Clean Coal Technology Demonstration Program (CCTDP), "Coal Utilization By-Products:
Topical Report Number 24," National Energy Technology Laboratory and Department of Energy, Jul. 2006.
165	Energy & Environmental Research Center, University of North Dakota, "Review of State Regulations, Standards,
and Practices, Related to the Use of Coal Combustion Products: Texas Review Case Study," Jan. 2005.
166	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
167	Power Products Engineering prepared for the American Coal Council, The Value of Coal Combustion Products:
An Economic Assessment of CCP Utilization for the U.S. Economy (Phoenix, AZ: American Coal Council, 2005)
1-128.
168	Industrial Economics, Incorporated prepared for U.S. EPA, Waste Materials-Flow Benchmark Sector Report:
Beneficial Use of Secondary Materials - Coal Combustion Products. (15 Dec. 2006) 1-29.
169	Goss, Dave, American Coal Ash Association. Personal Communication with Jeff Kohn, EPA. 23 January 2008.
170	NCASI, "Beneficial Use of Industrial By-Products: Identification and Review of Material Specifications,
Performance Standards, and Technical Guidance," Dec. 2003, 15 Oct. 2007
.
171	The Clean Coal Technology Demonstration Program (CCTDP), "Coal Utilization By-Products: Topical Report
Number 24," National Energy Technology Laboratory and Department of Energy, Jul. 2006.
172	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006.
173	RMT, Inc. for NCASI, "Beneficial Use of Industrial By-Products," Dec. 2003, 15 Oct. 2007
.
174	RMT, Inc. for NCASI, "Beneficial Use of Industrial By-Products," Dec. 2003, 15 Oct. 2007
.
1 75
U.S. Census Bureau, "2004 County Business Patterns," 15 Oct., 2007, 27 Jan. 2007
.
176	U.S. Department of Energy, Industrial Technologies Program, "Forest Products Industry of the Future: Fiscal
Year 2004 Annual Report," 15 Oct. 2007 .
177	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul. 2006, 15 Oct. 2007
.
178	Paula VanLare, EPA Sector Strategies Program sector lead for forest products, Personal interviews, 18 December
2006 and 16 October 2007.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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179	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul 2006, 15 Oct. 2007
.
180	Allan Elliott and Taltat Mahmood, "Beneficial uses of pulp and paper power boiler ash residues," TAPPI Journal
Oct. 2006: Vol. 5: No. 10.
181	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul. 2006, Oct. 2007
.
182	Paula VanLare, EPA Sector Strategies Program sector lead for forest products, Personal interview, 18 December
2006.
183	All data on byproduct volume reuse from RMT, Inc. for NCASI unless otherwise indicated, "Beneficial Use of
Industrial By-Products," December 2003, 15 Oct. 2007
.
184	National Council for Air and Stream Improvement, Inc. (NCASI), "Alternative Fuels Used in the Forest Products
Industry: Their Composition and Impact on Emissions: Technical Bulletin No. 0906," (Research Triangle Park, NC:
National Council for Air and Stream Improvement, Inc., 2005) 15 Oct. 2007
.
185	National Council for Air and Stream Improvement, Inc. (NCASI) Publication Detail, "Technical Bulletin No.
0900: Compilation of Alternative Landfill Cover Experience Using Wastewater Treatment Plant Residuals," 15 Oct.
2007 .
186	Tarun R. Naik, et al., "Use of Pulp and Paper Mill Residual Solids in Production of Cellucrete," Center for By-
products Utilization. The University of Wisconsin - Milwaukee. Jan. 2003, 15 Oct. 2007
.
187	John Simonsen, et al., "Beneficial Use of Pulp and Paper Industry Residuals: Extrusion for the Manufacture of
Building Panels: Technical Bulletin No. 814," National Council for Air and Stream Improvement. Inc. (NCASI)
Oct. 2000, 15 Oct. 2007 .
188	All data on byproduct quantities from RMT, Inc. for NCASI unless otherwise indicated, "Beneficial Use of
Industrial By-Products," Dec. 2003, 15 Oct. 2007
.
189	All data on byproduct volume reuse from RMT, Inc. for NCASI unless otherwise indicated, "Beneficial Use of
Industrial By-Products," Dec. 2003, 15 Oct. 2007
.
190	National Center for Environmental Innovation, "NCEI Issue Forum Addressing Barriers to Reduction and Reuse
of Industrial Wastes: Final Meeting Summary," Nov. 2003, 15 Oct. 2007
.
191	S. Deka and S. Yasmin, "Utilization of lime sludge waste from paper mills for fish culture," Current Science
April 2006: Vol. 90, No. 8, 15 Oct. 2007
.
192	National Council for Air and Stream Improvement, Inc. (NCASI), "Technical Bulletin No. 0894: Composting of
By-Product Solids from the Pulp and Paper Industry," Feb. 2005, 15 Oct. 2005
.
193	American Forest & Paper Association, "State Economic Brochures for Alabama, Florida, Louisiana, Mississippi
and Texas ," 15 Oct. 2007
.
194	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006, 15 Oct. 2007
.
195	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul. 2006,
.
196	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul. 2006,
.
15 Oct. 2007
15 Oct. 2007
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
Endnotes-8

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197	RMT, Inc. prepared for NCASI, "Beneficial Use of Industrial Byproducts," Dec. 2003, 15 Oct. 2007
.
198	RMT, Inc. prepared for NCASI, "Beneficial Use of Industrial Byproducts," Dec. 2003, 15 Oct. 2007
.
199	RMT, Inc. prepared for NCASI, "Beneficial Use of Industrial Byproducts," Dec. 2003, 15 Oct. 2007
.
200	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul. 2006, 15 Oct. 2007
.
201	Agenda 2020 Technology Alliance, "Forest Products Industry Technology Road map," Jul. 2006, 15 Oct. 2007
.
202	Paul S. Wiegand and Jay P. Unwin, "Alternative management of pulp and paper industry
Journal Apr. 1994: Vol 77, No. 4.
203	Paul S. Wiegand and Jay P. Unwin, "Alternative management of pulp and paper industry
Journal Apr. 1994: Vol 77, No. 4.
204	Paul S. Wiegand and Jay P. Unwin, "Alternative management of pulp and paper industry
Journal Apr. 1994: Vol 77, No. 4.
205	IT "Forest Products Project Fact Sheet: Use of Residual Solids from Pulp and Paper Mills for Enhancing Strength
and Durability of Ready-Mixed Concrete," Feb. 2001, 15 Oct. 2007
.
206	RMT, Inc. prepared for NCASI, "Beneficial Use of Industrial Byproducts," Dec. 2003, 15 Oct. 2007
.
207	Paul S. Wiegand and Jay P. Unwin, "Alternative management of pulp and paper industry solid wastes," TAPPI
Journal April 1994: Vol 77, No. 4.
208	Energy & Environmental Research Center, University of North Dakota, "Review of Florida Regulations,
Standards, and Practices Related to the Use of Coal Combustion Products," Apr. 2006, 15 Oct. 2007
.
209	Paul S. Wiegand and Jay P. Unwin, "Alternative management of pulp and paper industry solid wastes," TAPPI
Journal Apr. 1994: Vol 77, No. 4.
210	William E. Thacker, "Management of By-Product Solids Generated in the Pulp and Paper Industry," NCASI.
211	Paul S. Wiegand and Jay P. Unwin, "Alternative management of pulp and paper industry solid wastes," TAPPI
Journal Apr. 1994: Vol 77, No. 4.
212	RMT, Inc. prepared for NCASI, "Beneficial Use of Industrial Byproducts," Dec. 2003, 15 Oct. 2007
.
213	National Council for Air and Stream Improvement, Inc.(NCASI), "Composting of By-Product Solids from the
Pulp and Paper Industry: Technical Bulletin No. 089," 2005, 15 Oct. 2007
.
214	RMT, Inc. prepared for NCASI, "Beneficial Use of Industrial Byproducts," Dec. 2003, 15 Oct. 2007
.
215	Considine, T. The Transformation of the North American Steel Industry: Drivers, Prospects, and Vulnerabilities.
Penn State Department of Energy and Geo-Environmental Engineering. 21 April 2005. p. 21
216"Primary Metals: Chapter 2. The Steel Making Industry," 5 Sept. 2006
.
217	Tom Tyler, U.S. EPA Sector Strategies Program sector lead for iron and steel. Personal correspondence, 16
October 2007.
218
U.S. Census Bureau. 2004 County Business Patterns: Geography Area Series: County Business Patterns for the
U.S. http://factfinder.census.gov/servlet/IBOTable? bm=v&-ds name=CB0400Al&-ib tvpe=NAICS2002&-
NAICS2002=2211132211324111325113252132531325413273101331113315&- industrv=3254&-
NAICS2002sector=*4&- lang=en&-fds name=EC0200Al. Queried on 27 January 2007.
solid wastes," TAPPI
solid wastes," TAPPI
solid wastes," TAPPI
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
Endnotes-9

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219	U.S. EPA. 2006 Sectors Performance Report. "Iron and Steel." 2006. 19 October 2007.
http://www.epa. gov/sectors/pdf/ironandsteel.pdf#search=%22iron%20and%20steel%20reuse%20%22.
220	U.S. Department of Energy, Office of Industrial Technologies. "Steel Project Fact Sheet: Recycling And Reuse
Of Basic Oxygen Furnace (Bof)/Basic Oxygen Process (Bop) Steelmaking Slags." January 2002. 19 October 2007.
www.eere.energy.gov/industrv/steel/pdfs/recvcling bof.pdf.
221	U.S. Census Bureau, "Iron and Steel Mills: 2002." December 2004. 15 October 2007.
ww.census.gov/prod/ec02/ec023 li33111 l.pdf
222	U.S. Geological Survey, Data Series 140: Historical Statistics for Mineral and Material Commodities in the
United States, Version 1.2 (Online Only). 26 April 2007. 19 October 2007. http://minerals.usgs.gov/ds/2005/140/.
223	Steel Recycling Institute. 2005 The Inherent Recycled Content of Today's Steel. Updated August 2007. 19
October 2007. http://www.recvcle-steel.org/PDFs/Inherent2006.pdf.
224
Van Oss, Hendrick. U.S. Geological Survey. "Cement." Minerals Yearbook 2003. 19 October 2007.
http://minerals.usgs.gov/minerals/pubs/commoditv/cement/cemenmvb03.pdf.
225	Slag Cement Association. "U.S. Slag Cement Shipments." 2007. 19 October 2007.
http://www.slagcement.org/shared/custompage/custompage.isp? event=view& id=445505 c sU128801 s H48636
226	Horsehead Corporation. "EAF Dust Recycling Services." 2005. 19 October 2007.
http://www.horseheadcorp.com/EAF.html.
227
Texas Center for Policy Studies. "The Generation and Management of Hazardous Wastes and Transboundary
Hazardous Waste
Shipments between Mexico, Canada and the United States Since NAFTA: A 2004 Update." Table 9. July 2004. 19
October 2007. http://www.texascenter.org/publications/hazwaste04.pdf.
228
W. Hansen, E.A. Jensen, and P. Mohr. U.S. Department of Transportation, Federal Highways Administration.
"The Effects of Higher Strength and Associated Concrete Properties on Pavement Performance." June 2001. 19
October 2007. www.tfhrc.gov/pavement/pubs/00161a.pdf.
229	Steel Recycling Institute. 2005 The Inherent Recycled Content of Today's Steel. Updated August 2007. 19
October 2007. http://www.recvcle-steel.org/PDFs/Inherent2006.pdf.
230
Frank Hogan, Jerry Meusel and Lou Spellman. "Breathing Easier with Blast Furnace Slag." Cement Americas.
1 July 2001. 19 October 2007. http://cementamericas.com/mag/cement_breathing_easier_blast/
231	U.S. Department of Energy, Office of Industrial Technologies. "Steel Project Fact Sheet: Recycling And Reuse
Of Basic Oxygen Furnace (Bof)/Basic Oxygen Process (Bop) Steelmaking Slags." January 2002. 19 October 2007.
www.eere.energy.gov/industrv/steel/pdfs/recvcling bof.pdf.
232	U.S. Department of Energy. http://www.eh.doe.gov/p2/epp/library/FlyAsh502.pdf
233	Van Oss, Hendrick. U.S. Geological Survey. "Slag-Iron and Steel." Minerals Yearbook 2003. 19 October 2007.
http://minerals.usgs.gov/minerals/pubs/commoditv/iron & steel slag/islagmvb03.pdf. Table 1
234
U.S. Department of Energy, Office of Industrial Technologies. "Steel Project Fact Sheet: Recycling And Reuse
Of Basic Oxygen Furnace (Bof)/Basic Oxygen Process (Bop) Steelmaking Slags." January 2002. 19 October 2007.
www.eere.energy.gov/industrv/steel/pdfs/recvcling bof.pdf.
235	Recycled Materials Resource Center. "Steel Slag Materials Description." No date. 19 October 2007.
http://www.rmrc.unh.edu/Partners/UserGuide/ssal.htm
236	North Carolina Department of Environment and Natural Resources, Division of Pollution Prevention and
Environmental Assistance. "Chapter 2: The Steelmaking Industry." No date. 19 October 2007.
http://www.p2pays.org/ref/01/text/00778/chapter2.htm
237	North Carolina Department of Environment and Natural Resources, Division of Pollution Prevention and
Environmental Assistance. "Chapter 2: The Steelmaking Industry." No date. 19 October 2007.
http://www.p2pays.org/ref/01/text/00778/chapter2.htm.
238	Horsehead Corporation. "EAF Dust Recycling Services." 2005. 19 October 2007.
http://www.horseheadcorp.com/EAF.html.
239
U.S. Department of Energy, Office of Industrial Technologies. "Steel Project Fact Sheet: Processing Electric
Arc Furnace Dust Into Saleable Chemical Products." April 1998. 19 October 2007.
www.nrel. gov/docs/fv99osti/24621 .pdf.
240	North Carolina Department of Environment and Natural Resources, Division of Pollution Prevention and
Environmental Assistance. "Chapter 2: The Steelmaking Industry." No date. 19 October 2007.
http://www.p2pays.org/ref/01/text/00778/chapter2.htm
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
Endnotes-10

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241	U.S. Department of Energy, Office of Industrial Technologies. "Steel Project Fact Sheet: Processing Electric Arc
Furnace Dust Into Saleable Chemical Products." April 1998. 19 October 2007.
www.nrel. gov/docs/Iv 99osti/24621 .pdf.
242	Marc Liebman, AIM Market Research. "The Current Status of Electric Arc Furnace Dust Recycling In North
America." No date. 19 October 2007. www.aimmarketresearch.com/pdfs/dustPaper/251PaperTMSFormat.pdf
243	Bluescope Steel. "Reusing the By-products of the Steel Industry." No date. 19 October 2007.
www.bluescopesteel.com/navajo/display.cfm/objectID.E5D6A460-C49F-4353-94392E7DC53E71AB
244	U.S. Department of Energy, Energy Efficiency and Renewable Energy, Industrial Technologies Program.
"Enrichment of By-Product Materials from Steel Pickling Acid Regeneration Plants Recovering Iron-containing
Waste Materials to Produce Saleable Product for the Magnetics Industry." November 2006. 19 October 2007.
www. eere. energy. gov/industry/steel/pdfs/pickling_acid_regen.pdf
245
American Iron and Steel Institute. "Enrichment of By-Product Materials from Steel Pickling Acid Regeneration
Plants." No date. 19 October 2007. www.steel-trp.org/TRPGreenBook2006/9942factsheet.pdf
246
U.S. Department of Energy, Office of Industrial Technologies. "Steel Project Fact Sheet: Energy-Saving
Regeneration of Hydrochloric Acid Pickling Liquor." June 2000. 19 October 2007.
www.nrel.gov/docs/IV00osti/28232.pdf.
247	U.S. Department of Energy. "Energy and Environmental Profile of the U.S. Iron and Steel Industry." August
2000. 19 October 2007. http://www.eere.energy.gov/industrv/steel/pdfs/steel profile.pdf
248	Slag Cement Association. "U.S. Slag Cement Shipments." 2007. 19 October 2007.
http://www.slagcement.org/shared/custompage/custompage.isp? event=view& id=445505 c sU128801 s H48636
249	Portland Cement Association Sustainable Manufacturing Fact Sheet: Iron and Steel Byproducts. July 2005. 19
October 2007. http://www.cement.org/pdf files/is326.pdf. Accessed 6 September 2006.
250	Texas Department of Transportation. " Specifications Using Recycled Materials- By Application." 2007. 19
October 2007. http://www.dot.state.tx.us/services/general_services/recycling/speclist.htm.
Rock Products Cement Edition Staff. 1998. TXI Uses Steel Slag to Reduce C02 Emissions.
http://cementamericas.com/mag/cement txi uses steel/ Accessed 18 December 2006.
TxDOT. September Slags. Year of the Recycled Roadway Materials, ftp://ftp.dot.state.tx.us/pub/txdot-
info/gsd/pdf/vrr sept.pdf Accessed 19 October 2006.
251	Edw. C. Levy Co., "Steel Furnace Slag Characteristics," 25 May 2006, 15 Oct. 2007
.
252	USDOT. 2004. Steel Slag. Turner-Fairbank Highway Research Center.
http://www.tfhrc.gov/hnr20/recvcle/waste/ssa2.htm Accessed 18 December 2006.
253	David H.Y. Poh, "Soil Stabilization using Basic Oxygen (BOS) Steel Slag," University of Birmingham. 16 Oct.
2007 .
254	USDOT. 2004. Steel Slag. Turner-Fairbank Highway Research Center.
http://www.tfhrc.gov/hnr20/recvcle/waste/ssa2.htm Accessed 18 December 2006.
255	Alabama Department of Transportation. 1998. Improved Bituminous Concrete Base, Binder, and Wearing
Surface Layers. http:/Avww. dot, state. al.us/Burcau/Constmct ion/Spec 1992/2200(8). pdf Accessed 25 October 2006.
256	Blemker, D., Heckett MultiServ. (Note: MultiServ is an international firm involved in handling steel slag ~
mainly for metals recovery.) Personal Communications with M. MacKay, John Emery Geotechnical Engineering
Limited, August and September 1996. As cited in USDOT. 2004. Steel Slag. Turner-Fairbank Highway Research
Center, http://www.tfhrc.gov/hnr20/recvcle/waste/ssa2.htm Accessed 18 December 2006.
257	Slag Cement Association. "U.S. Slag Cement Shipments." 2007. 19 October 2007.
www.slagcement.org/shared/custompage/custompage.isp? event=view& id=445505 c sU128801 s H48636.
258	Horsehead Corporation. "EAF Dust Recycling Services." 2005. 19 October 2007.
http://www.horseheadcorp.com/EAF.html.
259	http://www.texascenter.org/publications/hazwaste04.pdf Table 9
260	Ohio EPA. 1998. Governor's Pollution Prevention Award, 1997 Recipient The Timken Company. Office of
Pollution Prevention, http://www.p2pavs.org/ref/16/15808.pdf Accessed 22 December 2006.
261	Liebman, Marc. 2000. The Treatment and Disposal of Electric Arc Furnace Dust in North America.
http://librarv.aist.org/ISSStore/PDF.nsf/OnePage by Name/PR-324-093/$FILE/PR-324-093,pdf?OpenElement
Accessed 18 December 2006.
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262	Alabama Department of Transportation. Standard Specifications for Highway Construction. 2002 edition. 19
October 2007. http://www.dot.alabama.gov/NR/rdonlvres/7D61FEC8-C42B-4E6F-AA93-
78B957B29 IB 1/0/2002 ALDOT Spec Book.pdf.
263	EPA. 1995. Profile of the Iron and Steel Industry.
http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/ironstlptl.pdf Accessed 18
December 2006.
264	LDEQ. 1998. Title 33 Environmental Quality Hazardous Waste and Hazardous Materials.
http://www.dea.louisiana.gOv/portal/Portals/0/planning/regs/addition/1998/hw063fin.pdf Accessed 25 October 2006.
EPA. 2005. 2005 Hazardous Waste Report, http://www.dep.state.fl.us/waste/auick topics/forms/documents/62-
730/730 8formsandinstructions.pdf Accessed 25 October 2006.
265	BlueScope Steel. Reusing the By-products of the Steel Industry.
http://www.bluescopesteel.com/index.cfm?obiectid=E5D6A460-C49F-4353-94392E7DC53E71AB Accessed 14
October 2006.
266	LDEQ, "LPDES Permits," 16 Oct. 2007 .
267	LDEQ. 1998. Title 33 Environmental Quality Hazardous Waste and Hazardous Materials.
http://www.dea.louisiana.gOv/portal/Portals/0/planning/regs/addition/1998/hw063fin.pdf Accessed 25 October 2006.
268	LDEQ. 1998. Title 33 Environmental Quality Hazardous Waste and Hazardous Materials.
http://www.dea.louisiana.gOv/portal/Portals/0/planning/regs/addition/1998/hw063fin.pdf Accessed 25 October 2006.
269	BlueScope Steel. Reusing the By-products of the Steel Industry.
http://www.bluescopesteel.com/index.cfm?obiectid=E5D6A460-C49F-4353-94392E7DC53E71AB Accessed 14
October 2006.
270	U.S. Department of Energy. "Metalcasting Industry Analysis Brief." 31 August 2000. 11 October 2007.
http://www.eia.doe.gov/emeu/mecs/iab/metalcasting/index.html.
271	Foundry Industry Recycling Starts Today. "What is Recycled Foundry Sand?" 2007. 11 October 2007.
http://foundrvrecvcling.org/Home/WhatisRecvcledFoundrvSand/tabid/294/Default.aspx.
272
U.S. Census Bureau. "2004 County Business Patterns: Geography Area Series: County Business Patterns for the
U.S." http://factfinder.census.gov/servlet/IBOTable? bm=v&-ds name=CB0400Al&-ib tvpe=NAICS2002&-
NAICS2002=2211132211324111325113252132531325413273101331113315&- industrv=3254&-
NAICS2002sector=*4&- lang=en&-fds name=EC0200Al. Queried on 27 January 2007.
273	American Foundry Society (AFS). August 2007. "Foundry Industry Benchmarking Survey: Industry Practices
Regarding the Disposal and Beneficial Reuse of Foundry Sand - Results and Analysis." Accessed at:
http://www.strategicgoals.org/benchmarking/foundrv.html.
274	Alicia Oman, American Foundry Society (AFS), personal communication, 12/21/07, and, Foundry Industry
Benchmarking Survey, August 2007, accessed at: http://www.strategicgoals.org/benchmarking/foundrvresults8-
7.pdf.
275	"What is Recycled Foundry Sand?" Foundry Industry Recycling Starts Today (FIRST). 10 October 2007.
http://www.foundrvrecvcling.org/Home/WhatisRecvcledFoundrvSand/tabid/294/Default.aspx.
276	U.S. EPA Office of Compliance. Profile of the Metal Casting Industry. (Washington, DC: USEPA October
1998) 83. 10 October 2007.
http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/metcstsna.pdf.
277
RMT, Inc. for National Council for Air and Stream Improvement, Inc. (NCASI). Beneficial Use of Industrial
By-Products Identification and Review of Material Specifications, Performance Standards, and Technical Guidance.
(Madison, WI: RMT Inc./NCASI December 2003) 16. 10 October 2007.
http://www.bvproductsummit.com/midwest/summit/rmt rpt.pdf
278	RMT, Inc. for National Council for Air and Stream Improvement, Inc. (NCASI). Beneficial Use of Industrial
By-Products Identification and Review of Material Specifications, Performance Standards, and Technical Guidance.
(Madison, WI: RMT Inc./NCASI December 2003) 14. 10 October 2007.
http://www.bvproductsummit.com/midwest/summit/rmt rpt.pdf
279
U.S. Census Bureau. "2004 County Business Patterns: Geography Area Series: County Business Patterns for the
U.S." http://factfinder.census.gov/servlet/IBOTable? bm=v&-ds name=CB0400Al&-ib tvpe=NAICS2002&-
NAICS2002=2211132211324111325113252132531325413273101331113315&- industrv=3254&-
NAICS2002sector=*4&- lang=en&-fds name=EC0200Al. Queried on 27 January 2007.
280	Wang, Shyh-Yau and C. Vipulanandan. "Foundry Sand for Highway Applications." (Houston, TX: University
of Houston 1998). 10 October 2007. http://geml.cive.uh.edu/content/conf exhib/00 poster/11.htm.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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281	U.S. Department of Energy, Energy Efficiency and Renewable Energy, Office of Industrial Technologies. Metal
Casting Project Fact Sheet. (Washington, DC: U.S. Department of Energy August 1998). 10 October 2007.
http://www.p2pays.org/ref/08/07591.pdf. $25 per ton costs reported in 1998 dollars converted to $32.61 per ton in
2006 dollars using the Engineering News-Record Construction Cost Index (CCI), Engineering News-Record,
December 2006.
282	U.S. EPA, Sector Strategies Division. Beneficial Reuse of Foundry Sand: A Review of State Practices and
Regulations. (Washington, DC: EPA December 2002). 33.10 October 2007.
http://epa.gov/sectors/metalcasting/reuse.pdf.
283	Mike Lenahan, Resource Recovery Corporation. Personal communications with Industrial Economics
Incorporated. 22 July 2005.
284	American Foundry Society (AFS). "Beneficial Reuse Directory." 2007. 11 October 2007.
http://www.afsinc.org/component/option.com mtree/Itemid. 193/.
285	Scott Green, Texas Commission on Environmental Quality. TCEQ Technical Analysis. Telephone conversation
between Mariana Arcaya, ICF Consulting. Mr. Green provided a copy of the database by email from John Carillo
JCARRILL@tcea. state.tx.us to Mariana Arcaya. 11 April 2005.
286	Industrial Economics, Incorporated for EPA Office of Solid Waste. DRAFT "Waste and Materials-Flow
Benchmark Sector Report: Beneficial Use of Secondary Materials - Foundry Sand." 28 December 2006.
287	U.S. Department of Agriculture Agricultural Research Service. "Benefits and Risks of Using Waste Foundry
Sand for Agricultural and Horticultural Applications." 8 October 2007. 11 October 2007.
http://www.ars.usda.gov/research/proiects/proiects.htm7ACCN NQ=409580.
288	EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry," U.S.
Environmental Protection Agency, October 2000, Accessed 8 October 2007, p. 46-50
.
289	"Fact Sheet—The First Step: Separation of Mud from Cuttings, " Drilling Waste Management Information
System, Accessed October 8 2007 .
290	EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry," U.S.
Environmental Protection Agency, October 2000, Accessed 8 October 2007, p. 46-50
.
291
Karen McCosh "Invert Fluid Flocculation—A Novel Technique for Drilling Fluid Recycling," 13th International
Petroleum Environmental Conference San Antonio, Texas, 17-20 October 2006, Accessed 15 October 2007
.
292	EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry," U.S.
Environmental Protection Agency, October 2000, Accessed 8 October 2007, p. 46-50
.
293	"Estimated U.S. drilling activity hits 21-year high," API 20 October 2007, Accessed 8 October 2007
.
294	"2004 County Business Patterns: Geography Area Series: County Business Patterns for the U.S," U.S. Census
Bureau, 2004, 27 January 2007 . Accessed 27 January 2007
295	EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry," U.S.
Environmental Protection Agency, October 2000, Accessed 8 October 2007, p. 46-50
.
296"EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry," U.S.
Environmental Protection Agency, October 2000, Accessed 8 October 2007, p. 46-50
.
297 Argonne has worked with Southeastern Louisiana University and industry to develop a process to use treated drill
cuttings to restore wetlands in coastal Louisiana: —DEAD LINK
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298	"Fact Sheet—Beneficial Reuse of Drilling Wastes, "Argonne National Laboratory, Accessed October 8 2007
.
299	Mark L. Susich and Max W. Schwenne, "Onshore Drilling Waste Management: Beneficial Reuse, 2003,
Accessed 10 October 2007 .
300	http://www.encana.com/responsibilitv/environment innovation fund/sagd.html-DEAD LINK
301	http://www.epa.gov/fedrgstr/EPA-WATER/2001/Januarv/Dav-22/w361 .htm Effluent Limitations Guidelines and
New Source Performance Standards for the Oil and Gas Extraction Point Source Category; OMB Approval Under
the Paperwork Reduction Act: Technical Amendment. 66 FR 6862
302	The volume of cuttings generated while drilling the SBF or OBF intervals of a well depends on the type of well
(development or production) and the water depth (shallow or deep). EPA developed OBF and SBF model well
characteristics from information provided by the American Petroleum Institute (API). API provided well size date
for four types of wells currently drilling the GOM: development and exploratory wells in both deep water (i.e.,
greater than or equal to 1,000 feet of water) and shallow water (i.e., less than 1,000 feet of water). These model
wells are referred to as: (1) Shallow-water development (SWD); (2) shallow-water exploratory (SWE); (3) deep-
water development (DWD); and (4) deep-water exploratory (DWE). For the four model wells, EPA determined that
the volumes of cuttings generated by these SBF or OBF well intervals are (in barrels): 565 for SWD; 1,184 for
SWE; 855 for DWD; and 1,901 for DWE. These volumes represent only the rock, sand, and other formation solids
drilled from the hole, and do not include drilling fluid that adheres to these formation cuttings. These values also
include the additional formation cuttings volume of 7.5% washout. Washout is caving in or sloughing off of the well
bore. Washout, therefore, increases hole volume and increases the amount of cuttings generated when drilling a
well. The washout percentage EPA used in its analyses (i.e., 7.5%) is based on the rule of thumb
reported by industry representatives of 5 to 10% washout when drilling with SBF or OBF.
303"EPA Office of Compliance Sector Notebook Project: Profile of the Oil and Gas Extraction Industry," U.S.
Environmental Protection Agency, October 2000,Accessed 8 October 2007, p. 46-50
.
304"Fact Sheet—Beneficial Reuse of Drilling Wastes, " Drilling Waste Management Information System, Accessed
October 8 2007 .
305	"Fact Sheet—The First Step: Separation of Mud from Cuttings, " Drilling Waste Management Information
System, Accessed October 8 2007 .
306	John A. Veil, "Costs For Off-Site Disposal of Nonhazardous Oil Field Wastes: Salt Caverns Versus Other
Disposal Methods," Argonne National Laboratory, April 1997, Accessed October 10 2007
.
307	Dee Ann Sanders and John N. Veenstra, "Pollution Prevention and Reuse Alternatives for Crude Oil Tank-
Bottom Sludges," Oklahoma State University, 2001 .
309	Manny Gonzales, Wayne Crawley, and Dennis Patton, "New Reduce, Reuse, Recycle Drilling Waste Treatment
Technologies and Programs," 13th Annual International Petroleum Environmental Conference, October 2006,
Accessed 15 October 2007 .
310	Manny Gonzales, Wayne Crawley, and Dennis Patton, "New Reduce, Reuse, Recycle Drilling Waste Treatment
Technologies and Programs," 13th Annual International Petroleum Environmental Conference, October 2006,
Accessed 15 October 2007 .
311	"Waste Minimization in the Oil Field: Appendix F, Minimization Opportunities for Wastes Generated in Oil and
Gas Operations," Railroad Commission of Texas, July 2001, Accessed 4 January 2007
.
312	"Fact Sheet—Beneficial Reuse of Drilling Wastes," Drilling Waste Management Information System, 22
December 2006, Accessed 10 October 2007 .
313	"Texas Administrative Code: Title 16, Part 1, Chapter 4, Subchapter B," 28 December 2006
.
314	Manny Gonzales, Wayne Crawley, and Dennis Patton, "New Reduce, Reuse, Recycle Drilling Waste Treatment
Technologies and Programs," 13th Annual International Petroleum Environmental Conference, October 2006,
Accessed 15 October 2007 .
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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315	Dee Ann Sanders and John N. Veenstra, "Pollution Prevention and Reuse Alternatives for Crude Oil Tank-
Bottom Sludges," Oklahoma State University, 2001, Accessed 17 October 2007
.
316	"Waste Minimization in the Oil Field: Appendix F, Minimization Opportunities for Wastes Generated in Oil and
Gas Operations," Railroad Commission of Texas, July 2001, Accessed 4 January 2007
.
317	Wyoming Department of Environmental Quality, "Petroleum Refining and Petroleum Distribution Systems,"
Pollution Prevention. September 1991, Accessed 15 October 2007 .
318	Wyoming Department of Environmental Quality, "Petroleum Refining and Petroleum Distribution Systems,"
Pollution Prevention. September 1991, Accessed 15 October 2007 .
319	Wyoming Department of Environmental Quality, "Petroleum Refining and Petroleum Distribution Systems,"
Pollution Prevention. September 1991, Accessed 15 October 2007 .
320
"2004 County Business Patterns: Geography Area Series: County Business Patterns for the U.S," U.S. Census
Bureau, 2004, Accessed 27 January 2007 .
321	"Responses to Disposal of Industrial Wastes and Recycling Measures," 2006 Showa Shell Corporate Social
Responsibility Report, 2006, Accessed 17 October 2007 .
322	American Petroleum Institute estimates that in both 1987 and 1988 (latest data available), the petroleum refining
industry recycled approximately 1 million tons, or 7% of the total waste quantity, of RCRA hazardous waste,
nonhazardous solid waste, and wastewaters. As found in "Petroleum Refining and Petroleum Distribution Systems,"
Pollution Prevention. Wyoming Department of Environmental Quality, September 1991, Accessed 17 October 2007
.
323	"Petroleum Refining and Petroleum Distribution Systems," Pollution Prevention. Wyoming Department of
Environmental Quality, September 1991, Accessed 17 October 2007 .
324	"Caustic Management Services," Merichem, 2005
.
325	Washington State Department of Ecology."Water Pollution Prevention Opportunities in Petroleum Refineries,"
Washington State Department of Ecology, November 2002, Accessed 5 January 2007, p. 21.
.
326	"UOP Sulfide Oxidation Process for Treating Spent Caustic, " UOP LLC, 2007, Accessed 10 October 2007
.
327	Dee Ann Sanders and John N. Veenstra, "Pollution Prevention and Reuse Alternatives for Crude Oil Tank-
Bottom Sludges," Oklahoma State University, 2001 .
328	Washington State Department of Ecology. Water Pollution Prevention Opportunities in Petroleum Refineries.
November 2002. Ecology Publication No.02-07-017. p. 21. http://www.ecv.wa.gov/pubs/0207Q17.pdf. Accessed 5
January 2007.
329	USEPA. Final Standards Promulgated for Petroleum Refining Waste. EPA530-F-98-014
July 1998. http://www.epa.gov/epaoswer/hazwaste/id/petroleum/petrofs6.pdf. Accessed 5 January 2007.
HO
Georgia Department of Community Affairs. MSW and C&D Landfill Tipping Fees 2005 Solid Waste
Management Update.
www.epa.gov/sectors/pdf/ironandsteel.pdf#search=%22iron%20and%20steel%20reuse%20%22. Accessed 10
February 2007.
331	National Center for Environmental Innovation, "NCEI issue Forum: Addressing Barriers to Reduction and Reuse
of Industrial Wastes," 5 Nov. 2003, 15 Oct. 2007 .
332	Prahalad and Hamel. "The Core Competence of the Corporation." Harvard Business Review. May-June 1990.
333	Texas Department of Transportation. Recycled Materials in TxDOT Specifications.
http://www.dot.state.tx.us/gsd/recvcle/speclist2.htm. Accessed 4 January 2007.
334	U.S. Census Data.
335	U.S. EPA, "Waste and Materials-Flow Benchmark Sector Report: Beneficial Use of Secondary Materials - Coal
Combustion Products," February 12, 2008.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
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336	U.S. EPA, "Waste and Materials-Flow Benchmark Sector Report: Beneficial Use of Secondary Materials - Coal
Combustion Products," February 12, 2008.
337	U.S. EPA, "Waste and Materials-Flow Benchmark Sector Report: Beneficial Use of Secondary Materials -
Foundry Sand," February 12, 2008.
Beneficial Reuse of Industrial Byproducts in the Gulf Coast Region
February 2008
Endnotes-16

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