3208 MessageID: <F02997AEB76B9C48AE88B3C6A73C437501CCF3F36D@DOTSCOEXMAIL01.fdot.dot.state.fl.us> From: "Malerk, Tom" <Tom.Malerk@dot.state.fl.us> Sent: 07/30/2010 11:49:35 AM Subject: Attention Docket ID No. EPA-HQ-RCRA-2009-0640

Attention Docket ID No. EPA-HQ-RCRA-2009-0640

The Florida Department of Transportation’s (FDOT) State Materials Office has been a nationally recognized leader in materials testing and research for the State of Florida for over 70 years. This Office also has a responsibility to develop future long-term solutions for the State’s ever-changing transportation needs. Therefore, on behalf of the FDOT, I am writing this letter in support of the continued use of coal combustion fly ash as a recyclable material. Since the early 1950s, fly ash has been used in roadways and interstate highways. In 1974, the Federal Highway Administration further encouraged its use in concrete pavements with Notice N 5080.4, which urged states to allow partial substitution of fly ash for cement where feasible. By 1983, the Environmental Protection Agency (EPA) published federal comprehensive procurement guidelines for cement and concrete containing fly ash to encourage the utilization of fly ash and to establish compliance deadlines.

Today, the FDOT primarily uses coal combustion fly ash in concrete when it is used as a replacement for Portland cement. This fly ash is a manufactured product that comes from specific sources that must meet strict chemical and physical requirements outlined by the American Society for Testing and Materials (ASTM C618). The primary benefits to the use of fly ash include a stronger, more durable concrete; the production of a concrete that uses less water; and a reduction in the use of natural resources. In some instances, ash products may not be suitable for use in concrete. In an effort to further expand this usage, the FDOT has conducted research and carefully gathered information on the engineering properties of many of these materials.

The EPA’s recent proposal to reclassify coal ash as a hazardous waste material would ultimately undermine the successful recycling efforts of the past 60 years. As power plants continue to expand their use of coal to produce the majority of the electricity in the United States, the long-term need to responsibly dispose of the byproducts will remain. In addition, an increase in landfill costs; a growing interest in sustainable development; the need for a reduction in greenhouse gas emissions; and a variety of other environmental considerations will further promote the need to permanently address this important issue.

Therefore, with a clearly defined vision to repurpose this versatile material, state transportation agencies can successfully support the long-term recycling of coal combustion fly ash. The use of this material in concrete is critical to the future of Florida's transportation system and its long-term goal to preserve the State’s environment and communities. Therefore, I respectfully ask that you please carefully consider each of the previously mentioned issues to help make this vision a reality.

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Sincerely,

Thomas O. Malerk
Director, Office of Materials
Florida Department of Transportation

Materials Research Park

5007 NE 39th Avenue

Gainesville, FL 32609

352.955.6620

tom.malerk@dot.state.fl.us

Thomas O. Malerk
Director, Office of Materials
Florida Department of Transportation

Materials Research Park

5007 NE 39th Avenue

Gainesville, FL 32609

352.955.6620

tom.malerk@dot.state.fl.us

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