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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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