United States Environmental Protection Agency 

in conjunction with the 

U.S. Department of Transportation and the U.S. Department of Energy 

Study on Increasing the Usage of Recovered Mineral 

Components in Federally Funded Projects Involving 

Procurement of Cement or Concrete 

to Address the 

Safe, Accountable, Flexible, Efficient Transportation 

Equity Act: A Legacy for Users 

Report to Congress

June 3, 2008 

EPA530-R-08-007 
i 

TABLE OF CONTENTS 

Executive Summary...................................................................................................................ES-1 

1.0 Introduction...................................................................................................................... 1-1 

1.1 Background and Organization ............................................................................. 1-1 

1.2 The Comprehensive Procurement Guidelines and Federal Requirements 

Governing the Use of Recovered Mineral Components (RMCs) in Federal 

Cement and Concrete Projects............................................................................. 1-2 

1.3 RMCs Analyzed................................................................................................... 1-7 

2.0 Industry Overview, Materials Evaluated, and Current RMC Substitution Levels .......... 2-1 

2.1 RMCs Identified by Congress.............................................................................. 2-2 

2.2 Other Materials Evaluated ................................................................................. 2-12 

2.3 Summary of RMC Generation and Beneficial Use............................................ 2-21 

3.0 Energy and Environmental Benefits of RMC Use in Federal Concrete Projects .............3.1 

3.1 Introduction.......................................................................................................... 3-1 

3.2 Analytical Approach and Model.......................................................................... 3-1 

3.3 Current and Expanded Use Scenarios.................................................................. 3-3 

3.4 RMC Unit Impact Savings................................................................................... 3-7 

3.5 Historical Energy and Environmental Impacts of RMC Beneficial Use ............. 3-9 

3.6 Projected Energy and Environmental Impacts of RMC Beneficial Use............ 3-12 

4.0 Barriers to Increased RMC Substitution...........................................................................4.1

4.1 Technical Barriers................................................................................................ 4-2 

4.2 Legal, Regulatory Policy, and Contractual Barriers ............................................ 4-4 

4.3 Economic Barriers ............................................................................................... 4-7 

4.4 Perceived Safety and Health Risk Barriers........................................................ 4-11 

5.0 Mechanisms to Increase the Beneficial Use of RMCs..................................................... 5-1 

5.1 Procurement Policies and Material Use Standards .............................................. 5-1 

5.2 Education, Technical Assistance, and Recognition Programs............................. 5-9 

5.3 Economics.......................................................................................................... 5-15 

6.0 Conclusions...................................................................................................................... 6-1 

References....................................................................................................................................R-1 

Glossary ...................................................................................................................................... G-1 

Abbreviations and Acronyms .................................................................................................. AA-1 
ii

Appendix A: Overview of Portland Cement and Concrete 

Appendix B: Background of Recovered Mineral Components 

Appendix C: Cement and RMC Producers 

Appendix D: RMC Beneficial Use Model - Technical Approach 

Appendix E: Summary of Industry Representative Comments on Mechanisms to Increase RMC 

Substitution
ES-1 

EXECUTIVE SUMMARY 

Section 6017(a) of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 

Legacy for Users, P.L. 109-59, Aug. 10, 2005 (SAFETEA-LU), directs the U.S. Environmental 

Protection Agency (EPA or the Agency) to, “...conduct a study to determine the extent to which 

procurement requirements, when fully implemented...may realize energy savings and 

environmental benefits attainable with substitution of recovered mineral components in cement 

used in cement or concrete projects.” 

SAFETEA-LU directs EPA to submit a report to Congress within 30 months of the enactment of 

SAFETEA-LU that addresses the following requirements: 

(A) Quantify (i) the extent to which recovered mineral components are being substituted 

for portland cement, particularly as a result of current procurement requirements; and (ii) 

the energy savings and environmental benefits associated with that substitution; 

(B) Identify all barriers in procurement requirements to greater realization of energy 

savings and environmental benefits, including barriers resulting from exceptions from 

current law; and 

(C) (i) Identify potential mechanisms to achieve greater substitution of recovered mineral 

components in types of cement and concrete projects for which recovered material 

components historically have not been used or have been used only minimally; (ii) 

evaluate the feasibility of establishing guidelines or standards for optimized substitution 

rates of recovered material component in those cement and concrete projects; and (iii) 

identify any potential environmental or economic effects that may result from greater 

substitution of recovered mineral components in these cement and concrete projects. 

Energy savings and environmental benefits associated with substitution. Recovered mineral 

component (RMC) use yields positive environmental benefits through lower resource 

consumption. To overcome procurement data limitations, for ground granulated blast-furnace 

slag (GGBFS), coal combustion fly ash (coal fly ash) , and silica fume, the report derives 

estimates of their use in Federal projects by roughly apportioning total volumes to Federal and 

non-Federal projects (based upon the estimated proportion of total cement demand related to 

federally-funded projects). For the years 2004 and 2005, our life cycle analysis indicates that the 

use of GGBFS, coal fly ash, and silica fume in Federal concrete projects alone resulted in 

significant reductions in greenhouse gas (GHG) emissions, criteria air pollutants, and energy and 

water use. For these two years combined, the analysis indicates reduced energy use of 31.5 

billion megajoules, avoided CO2 equivalent air emissions of 3.8 million metric tons, and water 

savings of 2.1 billion liters. The report further illustrates how these benefits may accrue over a 

longer time period (through 2015) given alternative use scenarios. This aspect of the analysis 

also links to issue C noted above. 

With respect to the issues identified under parts (B) and (C), research suggests that while a 

number of barriers impede the beneficial use of RMCs through procurement requirements, a 

variety of potential mechanisms exist for addressing these barriers. Specifically: 
ES-2 

• Procurement policies and material standards initiatives, including ongoing 

assessment and refinement of EPA’s Comprehensive Procurement Guidelines 

(CPGs), refinement of engineering standards governing substitution of RMCs, 

and development and application of green building standards. 

• Education, technical assistance, and recognition programs, such as EPA’s 

foundry sand outreach efforts and public/private partnerships, such as the Coal 

Combustion Products Partnership (C2P2) to encourage the beneficial use of coal 

combustion products (CCPs). 

• As part of education, technical assistance, and recognition, ongoing 

research and pilot projects are critical to advancing the use of RMCs. 

• Economic incentives, such as using transportation funding mechanisms to 

increase RMC use and providing incentives related to various components of the 

RMC generation and use chain.1

The CPG program is part of EPA's continuing effort to promote the use of materials recovered 

from solid waste and by-products.2 Under this program, EPA designates products that are made 

with recovered materials, and recommends practices for buying these products by procuring 

agencies.3 Once a product is designated, procuring agencies are required to purchase it with the 

highest recovered material content level practicable (e.g., the highest material content level that 

can be economically obtained and can provide the needed product specifications). EPA has 

issued guidelines for procurement of cement and concrete containing coal fly ash, and has further 

designated cenospheres4

 and silica fume as RMCs for cement and concrete. 

This report presents EPA’s analysis and discussion of the requirements contained in SAFETEA -

LU. Consistent with SAFETEA-LU, this Report reflects the input of multiple Federal partners in 

addition to EPA, including the U.S. Department of Transportation (DOT), the U.S. Department 

of Energy (DOE), the General Accountability Office (GAO), the United States Geological 

Survey (USGS) and the Office of the Federal Environmental Executive (OFFE). In addition, the 

Report also reflects comments and information from state entities and certain industry sources, 

such as the American Coal Ash Association (ACAA), the Slag Cement Association (SCA), the 

Silica Fume Association (SFA), the National Slag Association (NSA) - Edw. C. Levy Co., 

Headwaters, Inc., Venable LLP, and Holcim, Inc. We summarize the salient features of the 

report below. 

 

1

 These incentives are presented for Congressional consideration only. We recognize that the Department of 

Transportation does not currently have the legal authority to use transportation funding mechanisms to help increase 

RMC use. 

2

 EPA also issues guidance on buying recycled-content products in Recovered Materials Advisory Notices 

(RMANs). The RMANs recommend recycled-content ranges for CPG products based on current information on 

commercially available recycled-content products. 

3

 Procuring agencies include: (1) any federal agency, (2) any state or local agency using appropriated federal funds 

for procurement, or (3) any contractors to these agencies who are procuring these items for work they perform 

under the contract. 

4

 Cenospheres are a very specialized product used in a number of different industries. Cenospheres are also 

sometimes called microspheres. 
ES-3 

Industry Overview, Materials Evaluated, and Current Recovered Mineral Component 

Substitution Levels 

Provisions of SAFETEA- LU identified certain RMCs for further study, and directed EPA to 

identify and consider other waste and byproduct materials diverted from solid waste that should 

be considered as “recovered mineral components.”5 The four congressionally-identified mineral 

components include: GGBFS; coal fly ash; blast furnace slag aggregate (BFSA)6

; and silica 

fume. Congress specifically excluded lead slag from this Report. The other by-product 

materials identified by EPA for evaluation include: foundry sand, cenospheres, flue gas 

desulfurization (FGD) gypsum, flue gas desulfurization (FGD) dry scrubber material, power 

plant bottom ash, power plant boiler slag, steel furnace slag, and cement kiln dust (CKD). Table 

ES-1 provides a description of each of the RMCs and their general uses. Table ES-2 identifies 

the estimated annual quantities available for each RMC (including both domestic production and 

imports), and summarizes the positive environmental impacts and product enhancements 

associated with use of these materials. 

 

5

 Section 6017 (a) of SAFETEA-LU defines recovered mineral components as “(A) ground granulated blast furnace 

slag other than lead slag; (B) coal combustion fly ash; (C) blast furnace slag aggregate other than lead slag 

aggregate; (D) silica fume; and (E) any other waste material or byproduct recovered or diverted from solid waste 

that the Administrator, in consultation with an agency head, determines should be treated as recovered mineral 

component under this section.” 

6

 Also known as Air Cooled Blast-Furnace Slag (ACBF Slag) 
ES-4 

Table ES-1: Summary of RMCs 

RMC Description Uses/Ap

RMCs Named by Congress

Ground granulated blastfurnace slag (GGBFS) A ferrous slag produced during the production of iron as a result of removing impurities from iron ore. Quick quenching (chilling) of 

molten slag yields glassy, granular product which can be ground to a fine, powdered hydraulic cement. 

GGBFS can be used as partial reor, if not finely ground, as concr

Coal combustion fly ash A finely-divided mineral residue from the combustion of ground or 

powdered coal in coal-fired power plants. 

Partial replacement for portland Can be used as a raw material in cement clinker or as an inter-grocementitious material (SCM) in cements. 

Blast furnace slag aggregate (BFSA) 

Produced by allowing molten slag to cool and solidify slowly. Also commonly referred to as: air cooled blast-furnace slag (ACBF 

slag). 

After crushing and screening, us

such as concrete, asphalt, rail bain shingle coating, and glass ma

Silica fume A very fine, dust-like material generated during alloyed metal 

production. 

Concrete additive used to increa

Other RMCs Identified by EPA

Foundry sand Silica sand that is a byproduct of both ferrous and nonferrous metal 

castings. 

Can be used in the manufacture ingredient in concrete. 

Cenospheres Small, inert, lightweight, hollow, "glass" spheres composed of silica 

and alumina and filled with air or other gases. They occur naturally in coal fly ash. 

Used in concrete production to idecreasing shrinkage and weigh[Cenospheres may also be used from paints and finishes to plast

Flue gas desulfurization (FGD) gypsum 

FGD by-products are generated by air pollution control devices used at some coal-fired electric power plants. Forced oxidation wet FGD 

systems create gypsum as a by-product. 

Replacement for natural gypsum grinding with clinker to produce 

Flue gas desulfurization (FGD) dry scrubber material 

Dry FGD systems remove sulfur dioxide (SO2)from coal-fired power 

plant flue gas. Main constituents of resulting byproduct include calcium sulfite, fly ash, portlandite, calcite, calcium sulfate. 

Dry FGD material is used in consubstitute aggregate material. Dused for embankments and road

Power plant bottom ash A coarse, solid mineral residue that results from the burning of coal in 

utility boilers. 

Used as aggregate in concrete, o

compacted base course. Also usclinker manufacture as alternativand calcium. 

Power Plant Boiler slag A coarse, hard, black, angular, glassy material, produced from slag in 

wet-bottom boilers. 

Owing to its abrasive propertiesexclusively in the manufacture oas raw feed component to make 

Steel furnace slag A by-product from the conversion of iron to steel in a basic oxygen 

furnace or the melting of scrap to make steel in an electric arc furnace. 

Used as raw material substitute Also used in aggregate base, fill 

Cement kiln dust (CKD) The fine-grained, solid, highly alkaline material removed from cement 

kiln exhaust gas by air pollution control devices. 

Material is primarily recycled throucement kiln. Small amounts used amaterial (SCM) for blended and/or used as a soil liming agent. 

Note: Congress specifically excluded lead slag from this Report. 
ES-5 

Table ES-2: RMC Generation and Benefits of Use 

RMC 

Annual Quantity Generated, 2004. 

(excludes stockpiles) 

(million metric tons) Benefits of Use 

RMCs Named by Congress

Ground Granulated Blast Furnace Slag (GGBFS)

3.6a Use of GGBFS in concrete results in environmental benefits from avoided virgin materials ex

portland cement. These benefits include reduced energy use and associated greenhouse gas (Guse and reduced air pollution. In addition, the beneficial properties of concrete mixes containistrength, improved workability, lower heat of hydration, lower permeability, improved resista

resistance to sulfate attack. Use of GGBFS creates more concrete from the same amount of p

Coal Combustion Fly Ash

64.2 b Use of coal combustion fly ash in concrete results in environmental benefits from avoided virg

manufacturing of portland cement. These benefits include reduced energy use and associated Guse and reduced air pollution. In addition, certain performance benefits can be attained throug

including greater workability in the mixed concrete and higher strength and increased longevicreates more concrete from the same amount of portland cement. Can also be used as a raw mportland cement clinker or as an inter-ground or blended supplementary cementitious material blended cements. 

Blast Furnace Slag Aggregate (BFSA) (ACBF slag) 

8.1a As an aggregate in concrete mixes, BFSA reduces the need to quarry, crush, sort, and transpor

resulting in reduced energy use and associated GHG emissions, reduced water use and reduce

Silica Fume 0.10 – 0.12c The beneficial properties of concrete mixes containing silica fume include decreased water ble

reduced permeability to corrosive chemicals. Use of silica fume in concrete also reduces the recement for a specific quantity of concrete. Silica fume concrete is used in high-performance adurability and strength performance is required. 

Other RMCs Identified by EPAFoundry Sand 8.5d Use of foundry sand in concrete results in environmental benefits from avoided virgin sand ex

reduced energy use and associated GHG emissions, reduced water use and reduced air pollutio

Cenospheres 0.0052e (sold only) 

(Total not available) 

When incorporated into special light weight concrete or other cementitious materials mixes as 

and can decrease shrinkage and weight. Use of cenospheres can also offset the production of 

manufactured glass, calcium carbonate, clays, talc, and other silicas. 

Flue Gas Desulfurization (FGD) Gypsum

10.8c Use of FGD gypsum in wallboard production and as an additive in cement production results 

avoided extraction of virgin gypsum. These benefits are likely to include reduced energy use a

reduced water use and reduced air pollution. 

Flue Gas Desulfurization (FGD) Dry Scrubber Material 

1.7b Use of dry FGD material as a substitute for virgin aggregate results in environmental benefits 

extraction and aggregate production. These benefits include reduced energy use and associateuse and reduced air pollution. Use of dry FGD as a substitute (partial or total) for natural gyp

finish mill (to control the setting time of the portland cement). 

Power Plant Bottom Ash 

15.6b Use of bottom ash in concrete results in environmental benefits from avoided aggregate produ

reduced energy use and associated GHG emissions, reduced water use and reduced air pollutio
ES-6 

RMC 

Annual Quantity Generated, 2004. 

(excludes stockpiles) 

(million metric tons) Benefits of Use 

of bottom ash also makes it useful in lightweight concrete and concrete block applications. As manufacture, the bottom ash can supply some of the necessary oxides (thus saving on virgin r

lower energy cost and with reduced emissions than for some virgin materials. 

Boiler Slag 2.0b Boiler slag can reduce the need for virgin materials used as a raw feed for clinker production. 

manufacture of blasting grit. 

Steel Furnace Slag 9.0a Use of steel slag in clinker manufacturing helps to reduce energy use, decrease CO2 and NOX 

capacity, and reduce virgin limestone extraction. As an aggregate, steel slag reduces virgin ag

of avoided limestone or other types of aggregate extraction include reduced energy use and aswater use and reduced air pollution. 

Cement Kiln Dust (CKD) 

12.0 – 15.0f Use of CKD as a filler or cementitious extender for finished cement can offset virgin material

to landfills. Other beneficial uses of off-site CKD include stabilization of sludges, wastes, and 

also be used for land reclamation, livestock feed ingredient, and as daily landfill cover. 

Notes: 

a Hendrik G. van Oss, 2004b, values given are amount sold, as the industry does not report on actual production. Sales include imports of gro

that are ground domestically into GGBFS. Van Oss (2006) estimates total blast furnace slag production in 2004 to be 12-14 million metric tomillion metric tons), but this figure does not distinguish between GBFS, GGBFS, and BFSA. 

b American Coal Ash Association (ACAA). 2004 Coal Combustion Product (CCP) Production and Use Survey. c Kojundic, 8/30/2006 d Oman, Alicia, American Foundry Society (AFS), September 18, 2007. Personal Communication. Foundry Sand data are annual average for e American Coal Ash Association (ACAA). 2004 Coal Combustion Product (CCP) Production and Use Survey. Reported as sold only. f van Oss, 2005. The industry does not report total CKD production. A majority of this material is known to be recycled back into the kiln. A

approximately 1.2 million metric tons was beneficially reused (other than in kilns) and 1.4 million metric tons was landfilled (PCA, 2006. Su

Dust and Clinker Production) Congress specifically excluded lead slag from this Report.
ES-7 

Energy and Environmental Benefits of RMC Use in Federal Cement and Concrete Projects 

As indicated in Table ES-2, the use of RMCs can decrease the demand for certain virgin 

materials and decrease the demand for the use of portland cement. This leads to decreased 

resource consumption, namely energy and water. Lower resource consumption can yield, in 

turn, reductions in various pollutants and other positive environmental impacts, such as a 

reduction in GHG emissions. To assess these potential benefits further, this analysis provides 

quantified estimates of the environmental impacts and benefits for three RMCs: coal fly ash, 

GGBFS, and silica fume.7

 Consistent with the Congressional mandate to examine "recovered 

mineral components in cement used in cement or concrete projects," these estimates focus 

specifically on the impacts resulting from the use of these three mineral components as a partial 

replacement for, or supplement to, portland cement in Federal construction projects involving 

concrete. The assessed metrics include resource savings (e.g., reduced energy and water 

consumption), various avoided priority air pollutants (e.g., NO2, PM10, SOx, Hg, Pb), and 

various measures of avoided GHG emissions (e.g., CO2, CF4, CH4, N2O), which we further 

translate into equivalent metrics of avoided gasoline and oil consumption, and vehicles removed 

from the road.8

The analysis employs three primary steps in modeling the environmental benefits of using RMCs 

in Federal concrete applications: (1) development of RMC substitution scenarios; (2) use of lifecycle analysis to estimate quantified environmental impacts associated with the substitution of 

one unit (metric ton) of RMC; and, (3) calculation of the environmental impact profile for the 

total quantities of substituted RMC. 

Concerning RMC substitution scenarios, the report first focuses on past years for which actual 

use data can be estimated (2004 and 2005). The report then develops multiple projected use 

scenarios for the years 2006 through 2015 based upon existing trends (i.e., baseline) and 

expanded use based upon attainment of certain program goals (e.g., attainment of the C2P2 goal 

of 16.9 million metric tons of coal fly ash use in concrete by 2011). Because data concerning the 

volume of these RMCs procured by the Federal government are unavailable, the report derives 

an estimate based on a rough measure of the proportion of the total volume of cement demand 

attributable to Federal concrete projects (equal to approximately 20% of the annual totals). 

Chapter 3 and Appendix D provide detailed background on the derivation of RMC use scenarios 

for Federal concrete projects. 

For purposes of illustrating the general magnitude of potential impacts, Table ES-3 shows 

projected quantities of coal fly ash, GGBFS and silica fume used in Federal concrete projects for 

one scenario -- "baseline" usage. Chapter 3 and Appendix D provide detailed results for all 

 

7

 The report focuses on these three RMCs due to the fact that more robust data sources and modeling resources exist 

with respect to material volumes and their use in federally-funded concrete projects. While it is likely that other 

materials used to supplement or substitute for portland cement would have similar benefits, it is difficult to 

extrapolate results from the RMCs addressed here because quantities in use are uncertain and different processing 

requirements for different materials can have a significant impact on the magnitude of environmental benefits. 8

 Additionally, unquantified benefits may be associated with improved performance of concrete and resulting 

decreases in the materials and energy needed to repair, replace, and upgrade road beds. Evaluation of these benefits, 

however, would require more robust estimates of average changes in management required for different concrete 

uses. To date, this type of information has been too limited to support a national estimate. 
ES-8 

scenarios. The shaded area, covering years 2004 and 2005, represents the historical period. As 

the table shows, under this scenario, the forecast estimates that coal fly ash use in Federal 

concrete projects will grow from approximately 2.6 million metric tons in 2004, to 3.3 million 

metric tons in 2015. The GGBFS forecast contemplates lower growth, from approximately 0.7 

million metric tons in 2004 to 0.9 million metric tons in 2015. Coal fly ash shows higher 

utilization growth potential as this RMC is currently used at lower rates compared to the highlyutilized GGBFS. Overall volumes of silica fume use are lower relative to coal fly ash and 

GGBFS. 

Table ES-3: Use Projections for Fly Ash, GGBFS, and Silica Fume in Federal Concrete 

Projects (baseline scenario) 

Year 

Federal Demand for 

Portland Cement 

Coal Fly Ash used in Federal 

Projects - 

Baseline Scenario 

GGBFS used in Federal 

Projects - 

Baseline Scenario 

Silica Fume used in 

Federal Projects - 

Baseline Scenario 

-----------------------------------------million metric tons------------------------------------------------ 

2004 24.4 2.6 0.7 0.01 

2005 25.1 2.7 0.7 0.01 

2006 25.7 2.8 0.7 0.01 

2007 26.2 2.8 0.7 0.01 

2008 26.8 2.9 0.8 0.01 

2009 27.4 3.0 0.8 0.01 

2010 27.9 3.0 0.8 0.01 

2011 28.5 3.1 0.8 0.01 

2012 29.0 3.1 0.8 0.01 

2013 29.6 3.2 0.8 0.01 

2014 30.1 3.3 0.8 0.01 

2015 30.7 3.3 0.9 0.01 

Notes:

(1) These figures reflect use of materials as a supplement to or partial replacement for portland cement in Federal projects only.

(2) Shaded area represents "historical" period for which actual use data are estimated. Unshaded area represents the 

 "forecast" period. 

Table ES-4 presents the results of a life cycle inventory analysis of the use coal of fly ash, 

GGBFS and silica fume in Federal concrete projects under the baseline usage scenarios 

described above. These results are aggregated estimated benefits covering the historical period 

(2004 and 2005) and projected over the full time frame, 2004 through 2015. For a detailed 

description of the modeling approach, please refer to Appendix D. 
ES-9 

Table ES-4: Estimated Environmental Benefits of Using Coal Fly Ash, GGBFS, and Silica 

Fume as a Substitute for, or Supplement to Portland Cement in Federal Concrete Projects, 

Baseline Scenario9

Metric (units) 

Historical 

Environmental 

Benefits: 2004-

2005 

Projected 

Environmental 

Benefits: Baseline 

Scenario 2004-2015a

Energy Savings (billion megajoules) 31.5 212.1 

Water Savings (billion liters) 2.1 14.1 

Avoided C02 equivalent (GHG) (million metric tons) 3.8b 25.7b

 Passenger cars not driven for one yearc (million) 0.8b 5.7b

 Passenger cars and light trucks not driven for one yearc 

(million) 0.7b

 4.7b

Avoided criteria pollutants (air) (thousand metric tons) 31.3 209.7 

Avoided Hg (air) (metric tons) 0.3 1.9 

Avoided soil emissions (metric tons) 0.0* 0.0* 

Avoided end of life waste (metric tons) 0.0 0.0 

Notes:

a. Calculated as the sum of impacts for coal fly ash current use baseline, and GGBFS and silica fume current 

use scenarios. 

b. Results reflect only coal fly ash impacts. 

c. These metrics are equivalent expressions of the avoided greenhouse gas metrics and do not represent 

additional benefits. 

* Negligible. 

We also developed representative benefits estimates for use of BFSA as an aggregate. See Appendix D.

As shown in Table ES-4, the use of coal fly ash, GGBFS and silica fume as a partial substitute 

for, or supplement to, portland cement in Federal concrete projects yield energy and water 

savings, as well as avoided criteria pollutant emissions. In addition, use of coal fly ash alone 

may result in 3.8 million metric tons of avoided carbon dioxide equivalent in the years 2004 to 

2005. This savings is equivalent to removing 0.8 million passenger cars from the road for one 

year. Through the year 2015 under this scenario, we estimate that the use of such RMCs in 

Federal concrete projects may result in reduced CO2 emissions of over 25.7 million metric tons, 

which is equivalent to removing 5.7 million passenger cars from the road for one year. Impacts 

on the reuse on soil and end of life waste are not significant because the use and disposal of 

portland cement and concrete are not affected by RMC use. 

It is difficult to quantify the incremental contribution to RMC use that may be attributable to any 

particular relevant procurement requirements. A number of economic, operational, and 

regulatory factors combine to influence procurement behavior, and data limitations prevent the 

 

9

 Blast furnace slag aggregate (BFSA) is primarily used as a source of aggregate in concrete and does not act as a 

supplementary cementitious material, or substitute for portland cement. Our assessment focuses on the benefits of 

substitution for portland cement. However, an illustration of the types and magnitude of benefits that can be 

achieved by using BFSA as a substitute for virgin aggregate in concrete mixtures, in asphalt mixtures, or as 

roadbase, can be found in Appendix D. 
ES-10 

type of detailed analysis that would support attribution of specific behavior changes to specific 

programs. In general terms, however, the analysis identifies the combined impact of the CPG, 

state, Federal government, industry, and market-driven influences on the use of RMCs in Federal 

concrete projects. 

Barriers to Increased RMC Substitution 

Consistent with Part (B) of the Congressional mandate, this report describes barriers to increased 

RMC use, focusing specifically on the RMCs identified in the report for which current supply 

significantly exceeds current use. (i.e., coal fly ash, foundry sand, FGD gypsum, FGD dry 

scrubber material, power plant bottom ash, and CKD). Barriers to the increased use of RMCs in 

cement and concrete projects fall into four main categories: 

• Technical barriers; 

• Legal, regulatory, and contractual barriers; 

• Economic barriers; and 

• Perceived safety and health risk barriers. 

These categories can include a range of specific issues that have the potential to limit the use of 

an RMC. For example, regulatory barriers may include certain state and local-level regulations 

and procedures governing the use of RMCs in various applications. Technical issues that limit 

the use of RMCs include the variability of standards for use of RMCs in portland cement and 

concrete and operational constraints with materials not typically used as RMCs; variation in 

RMC properties; and the availability of consistent, high-quality materials. Potential economic 

factors limiting RMC substitution include the RMC value to the supplier, transportation costs, 

the market price of RMCs, and disposal costs. Safety and health risk perception barriers include 

a lack of understanding of the potential and proper use, features, and risks associated with 

RMCs. 

In addition to external barriers, the CPG provides that a procuring agency need not procure 

RMCs if certain criteria are met. If these criteria are over-interpreted by project managers, it 

could result in lower usage rates of RMCs than are technically and economically feasible. That 

is, while the CPG requires Federal agencies to procure products containing certain RMCs, the 

guidelines allow that such RMCs do not have to be procured if they: (1) are not available within 

a reasonable period of time; (2) fail to meet the performance standards set forth in the applicable 

specifications or fail to meet the reasonable performance standards of the procuring agencies; or 

(3) are only available at an unreasonable price. Additional limitations of the CPG include a lack 

of awareness of CPG requirements and products, the perception that CPG is not mandatory, and 

the cost and availability of CPG materials. 

Mechanisms to Increase RMC Substitution 

EPA, in collaboration with a variety of stakeholders, has identified a number of mechanisms that 

may serve to address the barriers noted above. These mechanisms are particularly focused on 
ES-11 

RMCs with high reuse potential, but which appear to be under-utilized. For example, coal fly 

ash exists in large quantities, but is currently (2006) used in portland cement and concrete at a 

rate of roughly 13.6 million metric tons per year out of a generation of roughly 65.7 million 

metric tons. The report focuses on current and potential mechanisms to increase substitution 

rates relevant to these materials, specifically in Federal cement and concrete projects.10

Central to this report, and RMC use in Federal concrete projects, is the role of the CPG. As 

noted, the extent to which major Federal procuring agencies have purchased products containing 

RMCs is difficult to measure because few data systems identify purchases of specific recycledcontent designated products. However, the multi-faceted approach to green purchasing 

implemented under the CPG has led to many successes, including influencing the amount of 

RMCs procured for use in concrete products. As one example, for FY 2003, more than 80% of 

the concrete purchases made by NASA, DOE, and GSA contained coal fly ash or slag. The CPG 

program, therefore, represents a critical mechanism to achieve higher RMC reuse levels. 

To continue and expand upon this progress, the procurement guidelines and their implementation 

are the focus of ongoing improvement efforts (e.g, updating of CPG Supplier database). Further, 

a number of other potential mechanisms exist for addressing barriers. Chapter 5 provides a 

detailed listing of these potential mechanisms. In summary, the current and potential 

mechanisms for increasing RMC use include: 

• Procurement policy initiatives, including improved procurement data systems, 

allowing for the identification and tracking of cement and concrete purchases 

using RMCs; enhanced CPG compliance and implementation procedures; and, 

delivery of effective information resources, training, and outreach to Federal 

agency contracting, purchase card, and program personnel. 

• Material standards optimization, including refinement of engineering standards 

governing substitution of RMCs, development and application of green building 

standards, and incorporation of these considerations into contract bidding 

specifications and procedures. 

• Education and recognition programs, such as EPA’s CCPs outreach efforts and 

public/private partnerships, such as the FHWA, ACAA, DOE, the Electric Power 

Research Institute (EPRI), the United States Department of Agriculture (USDA), 

and the Utility Solid Waste Activities Group (USWAG) collaboration on C2

P2 to 

promote the beneficial use of CCPs.

• Technical assistance and research, such as FHWA's ongoing research on the 

beneficial use of RMCs in highway construction projects, which includes primary 

research concerning material specifications and guidance on their use.

 

10 We also note that the amount of certain RMCs produced annually in the U.S. surpasses the amount that can be 

incorporated into Federal cement and concrete projects alone. Although Federal projects currently comprise a 

moderate percentage of U.S. cement and concrete projects, increasing reuse rates to higher levels will require greater 

reuse among both Federal and non-Federal cement and concrete projects. To that end, many of the mechanisms 

contemplated here can apply to non-federal, as well as Federal projects. 
ES-12 

• Economic incentives, such as using transportation funding mechanisms to 

increase RMC use and enhancing the economic viability of various components 

of the RMC generation and use chain. 

The linkages between these mechanisms and barriers are complex and varied. For example, 

some barriers related to inaccurate perceptions concerning RMC use may be overcome relatively 

easily through education or outreach efforts. These mechanisms, however, would be less 

effective in instances where strong economic disincentives to RMC use are present. In addition, 

implementation of many of these mechanisms is subject to resource availability and active 

participation by a broad range of entities. These factors all indicate that increasing RMC use in 

concrete products requires an ongoing, multi-faceted approach. 
1-1 

1.0 INTRODUCTION 

1.1 Background and Organization 

Section 6017(a) of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 

Legacy for Users, P.L. 109-59, Aug. 10, 2005 (SAFETEA-LU)11, directs the U.S. Environmental 

Protection Agency (EPA or the Agency) to, “...conduct a study to determine the extent to which 

procurement requirements, when fully implemented...may realize energy savings and 

environmental benefits attainable with substitution of recovered mineral components in cement 

used in cement or concrete projects.” 

SAFETEA-LU directs EPA to submit a report to Congress within 30 months of the enactment of 

SAFETEA-LU that addresses the following requirements: 

(A) Quantify (i) the extent to which recovered mineral components are being 

substituted for portland cement, particularly as a result of current procurement 

requirements, and (ii) the energy savings and environmental benefits associated 

with that substitution; 

(B) Identify all barriers in procurement requirements to greater realization of energy 

savings and environmental benefits, including barriers resulting from exceptions 

from current law; and 

(C) (i) Identify potential mechanisms to achieve greater substitution of recovered 

mineral component in types of cement or concrete projects for which recovered 

mineral components historically have not been used or have been used only 

minimally; (ii) evaluate the feasibility of establishing guidelines or standards for 

optimized substitution rates of recovered mineral component in those cement or 

concrete projects; and (iii) identify any potential environmental or economic 

effects that may result from greater substitution of recovered mineral component 

in those cement or concrete projects. 

This report contains EPA’s analysis of the information addressed in SAFETEA-LU. The report is 

organized into six sections: 

• The Introduction discusses EPA’s existing comprehensive procurement 

guidelines (CPGs), presents an overview of the screening process that EPA used 

to identify and prioritize the analysis of specific recovered mineral components 

(RMCs), and outlines the current state of different types of specifications for 

various RMCs. 

 

11 SAFETEA-LU and the Energy Policy Act of 2005, P.L. 109-58, August 8, 2005 (EPACT), include similar 

provisions amending Subtitle F of the Solid Waste Disposal Act that direct EPA to conduct this study and submit a 

Report to Congress. SAFETEA-LU was enacted later in time and, therefore, impliedly repealed EPACT. 
1-2 

• Chapter 2 responds to Part (A) of the Congressional charge by describing the 

current industry, uses, and substitution levels of the specific RMCs identified in 

the Introduction (Section 1). 

• Chapter 3 responds to Part (A) of the Congressional charge by analyzing the 

energy and environmental impacts associated with the beneficial use of three 

specific RMCs identified by Congress. 

• Chapter 4 addresses Part (B) of the Congressional charge by identifying and 

describing various barriers to increased RMC substitution. 

• Chapter 5 addresses Part (C) of the Congressional charge by identifying and 

describing various mechanisms to increase RMC substitution. 

• Chapter 6 presents the report’s conclusions. 

Consistent with SAFETEA-LU, this Report reflects the input of multiple Federal partners in 

addition to EPA, including the U.S. Department of Transportation (DOT); the Department of 

Energy (DOE); the General Accountability Office (GAO); the United States Geological Survey 

(USGS); and the Office of the Federal Environmental Executive (OFEE). In addition, the Report 

also reflects comments and information from various states and certain industry sources. Such 

sources include, but are not limited to: the American Coal Ash Association (ACAA); the Slag 

Cement Association (SCA); the Silica Fume Association (SFA); the National Slag Association 

(NSA) - Edw. C. Levy Co.; Headwaters, Inc.; Venable LLP; and Holcim, Inc. 

1.2 The Comprehensive Procurement Guidelines and Federal Requirements Governing 

the Use of Recovered Mineral Components (RMCs) in Federal Cement and 

Concrete Projects 

The CPG program is part of EPA's continuing effort to promote the use of materials recovered 

from solid waste and by-products. Buying recycled-content products enhances the likelihood 

that recyclable materials will be used again in the manufacture of new products. 

The CPG program is mandated by Congress under Section 6002 of the Resource Conservation 

and Recovery Act (RCRA). Over the years, CPG implementation has been bolstered by 

presidential Executive Orders, the most recent being Executive Order 13423.12 Under this 

program, EPA designates products that are made with recovered materials, and recommends 

practices for procuring agencies13 to procure these products. Once a product is designated, 

procuring agencies are required to purchase it with the highest recovered material content level 

 

12 On January 24, 2007, the President signed Executive Order (E.O) 13423 “Strengthening Federal Environmental, 

Energy, and Transportation Management.” E.O. 13423 consolidates and strengthens five previously enacted 

executive orders. For more details on E.O. 13423, see (http://www.epa.gov/oaintrnt/practices/eo13423.htm). 

13 Procuring agencies include: (1) any federal agency, (2) any state or local agency using appropriated federal funds 

for procurement, or (3) any contractors to these agencies who are procuring these items for work they perform under 

the contract. 
1-3 

practicable (e.g., the highest material content level that can be economically obtained and can 

meet the needed specifications). 

In 1983, EPA issued guidelines for the procurement of cement and concrete containing fly ash 

(40 CFR Part 249, 48FR 4230, January 28, 1983). The Agency later amended the rule in CPG 

IV to add cenospheres, ground granulated blast-furnace slag (GGBFS), and silica fume as RMCs 

for cement and concrete. Thus designated by EPA, cement and concrete containing RMCs are to 

be preferentially procured by procuring agencies, as required by statute and Executive Order. 

To aid procuring agencies, EPA also has issued guidance on buying recycled-content products in 

Recovered Materials Advisory Notices (RMANs). The RMANs recommend recycled-content 

ranges for CPG products based on current information on commercially available recycledcontent products. RMAN levels are updated as marketplace conditions change. 

1.2.1 Recovered Materials Content14

In the CPGs for cement and concrete, EPA advises procuring agencies to prepare or revise their 

procurement programs for cement and concrete, or for construction projects involving cement 

and concrete, to allow for the use of coal fly ash, GGBFS, cenospheres, or silica fume, as 

appropriate.15,16 Recovered materials are frequently used as substitutes for or supplements to 

portland cement when mixing concrete. Some recovered materials can also be used in the 

manufacture of portland cement itself, by replacing other raw materials used in making clinker 

(the intermediate product in portland cement manufacturing) and also in the later blending stages 

of the cement manufacturing process. The blended cement produced by this process is then used 

in concrete in place of straight portland cement. Finally, many recovered materials can be used 

as a direct substitute for the aggregate (i.e., non-cement) portion of concrete. 

The CPGs require that procuring agencies consider the use of all of these recovered materials 

and choose the one (or mixture) that meets their performance requirements, consistent with 

availability and price considerations. EPA recommends that procuring agencies specifically 

include provisions in all construction contracts to allow for the use, as optional or alternate 

materials, of cement or concrete which contains coal fly ash, GGBFS, cenospheres, or silica 

fume, where appropriate. Due to variations in cement, strength requirements, costs, and 

construction practices, EPA does not recommend specific RMC content levels for cement or 

concrete containing coal fly ash, GGBFS, cenospheres, or silica fume. However, EPA provides 

the following information about recovered materials content:17

 

14 Information on recovered materials content reproduced from: http://www.epa.gov/cpg/products/cement.htm,

accessed June 4, 2007. 

15 While the EPA language cited here (accessible at: http://www.epa.gov/cpg/products/cemspecs.htm) uses the 

general term “cement,” the discussion targets materials and practices that generally refer to portland cement. In 

subsequent, related documents, including Federal Register documents, the Agency specifies portland cement. 

16 EPA's published information sometimes refers to ground granulated blast-furnace slag as "GGBF slag." For 

consistency, we have changed this terminology to GGBFS, even when quoting Agency material. A commonly used 

industry term for this material is “slag cement.” 

17 The following bullets are reproduced from: http://www.epa.gov/cpg/products/cement.htm, accessed July 3, 2007, 

with modifications to the first bullet to include portland cement and reflect the distinction between blended cements 

and concrete. Two additional bullets are added to show how slag aggregate can be used in concrete. 
1-4 

• Replacement rates for portland cement in concrete generally do not exceed 20% 

to 30%. Blended cements are produced at a cement kiln where fly ash is added at 

the kiln ranging from zero to 40% coal fly ash by weight, according to the 

American Society for Testing and Materials (ASTM). These levels are identified 

under ASTM C 595 for cement Types IP and IS(PM).18 Fifteen percent is a more 

accepted rate when coal fly ash is used as a partial cement replacement as an 

admixture in concrete. (See also: ASTM C 1157 Standard Performance 

Specification for Hydraulic Cement.) 

• According to ASTM C 595, GGBFS may replace up to 70% of the portland 

cement in some concrete mixtures.19, 20 Most GGBFS concrete mixtures contain 

between 25% and 50% GGBFS by weight. EPA recommends that procuring 

agencies refer, at a minimum, to ASTM C 989 for the GGBFS content appropriate 

for the intended use of the cement and concrete. 

• According to industry sources, there are some cases where slag aggregate can 

replace 100% of the virgin aggregate in concrete. 21

• According to industry sources, cement and concrete containing cenospheres 

typically contains a minimum of 10% cenospheres by volume.22

• According to industry sources, cement and concrete containing silica fume 

typically contains silica fume that constitutes five to 10% of cementitious material 

on a dry weight basis.23

• According to ASTM C33, Standard Specifications for Concrete Aggregate. 

BFSA may be used as aggregate for concrete, as can recycled crushed concrete, 

sand, gravel, crushed gravel, or crushed stone in concrete mixes. 

 

18 Note that ASTM standards may be updated or revised over time. 

19 According to Hendrik van Oss of the USGS, GGBFS may also replace up to 70 % of the portland cement in some 

cement blends. 

20 Recent changes to ASTM C595 have removed the limit of GGBFS in Type I(S) cement. GGBFS is now governed 

by ASTM C989. Now there are industry guidelines for “normally accepted” substitution rates. The SCA publishes 

such guidance in its information sheet SCIC #2: Concrete Proportioning available at: 

http://www.slagcement.org/image/123800_c_sU128801_s_i185530/No2_Proportioning.pdf. 

21 June 27, 2007 statement from Rich Lehman of the Edw. C. Levy Company.. 22 Refer to 69 FR 24041, published on April 30, 2004 for more information. Note that this information is consistent 

with the generation rates for cenospheres and silica fume published in Background Document for the Final 

Comprehensive Procurement Guideline (CPG) IV and Final Recovered Materials Advisory Notice (RMAN) IV, U.S. 

Environmental Protection Agency, April 2004 (EPA 2004).

23 Silica fume use in cement is different than other RMCs because it can be added as a supplement to a final cement 

product to help reduce permeability and increase durability, without replacing virgin portland cement. In addition, 

silica fume can be used as a substitute for portland cement. 
1-5 

1.2.2 Specifications 

1.2.2.1 Coal Fly Ash and GGBFS 

Under the CPG, EPA recommends that procuring agencies revise their specifications to require 

that contracts for individual construction projects or products allow for the use of coal fly ash or 

GGBFS, unless the use of these materials is technically inappropriate for a particular 

construction application. According to the CPG, procuring agencies should use the existing 

voluntary consensus specifications referenced below for cement and concrete containing coal fly 

ash and/or GGBFS24. 

• Federal and State Specifications: EPA advises procuring agencies to consult 

Federal and state sources to identify established specifications for coal fly ash or 

GGBFS in cement and concrete. For example, the Federal Highway 

Administration (FHWA) maintains a database of state highway agency material 

specifications.25 AASHTO specifications are another source. Furthermore, the 

states of Alabama, Connecticut, Florida, Georgia, Illinois, Indiana, Maryland, 

Michigan, North Carolina, North Dakota, Ohio, Pennsylvania, South Carolina, 

Virginia, West Virginia, and the District of Columbia all have adopted 

specifications that allow the use of GGBFS in one or more applications.26 

Procuring agencies may obtain these specifications from the respective state 

transportation departments and adapt them for use in their programs for cement 

and concrete, as appropriate. 

• Contract Specifications: EPA advises procuring agencies that prepare or review 

"contract" specifications for individual construction projects to revise those 

specifications, as appropriate, to allow for the use of cement and concrete 

containing coal fly ash or GGBFS as optional or alternate materials for the 

targeted project. These revisions should be consistent with the agencies' 

performance and price objectives. 27

• Performance Standards: EPA advises procuring agencies to review and, if 

necessary, revise performance standards relating to cement or concrete 

construction projects. This should be done to ensure that existing standards do 

not arbitrarily restrict the use of coal fly ash or GGBFS, either intentionally or 

inadvertently, unless the restriction is justified on a job-by-job basis: (1) to meet 

 

24 Although not referenced in the current CPG, BFSA is recognized by AASHTO, ASTM, and many procuring 

agencies as an appropriate coarse aggregate for use in concrete mixes, and for other aggregate uses. 25 www.specs.fhwa.dot.gov 26 For a detailed table of state DOT specifications, refer to “Engineering and Environmental Specifications of State 

Agencies for Utilization and Disposal of Coal Combustion Products: Volume 1 – DOT Specifications,” 2005. 

Dockter, B. and Diana M. Jagiella, Table 3, Page 32. 

27 Chapter 5 provides further detail concerning RCRA §6002 requirements related to material and contract 

specifications. 
1-6 

reasonable performance requirements for the cement or concrete, or, (2) because 

the use of coal fly ash or GGBFS would be inappropriate for technical reasons. 

This justification should be documented based on specific technical performance 

information. 

• Mix Design: Existing cement ratios could potentially unfairly discriminate 

against the use of coal fly ash or GGBFS if design specifications specify 

minimum portland cement or maximum water content; such specifications should 

be reevaluated in order to allow the partial substitution of coal fly ash or GGBFS 

for portland cement in the concrete mixture, unless technically inappropriate. 

Cement ratios can be retained, as long as they reflect the cementitious 

characteristics that coal fly ash or GGBFS can impart to a concrete mixture (e.g., 

by considering portland cement plus coal fly ash or portland cement plus GGBFS 

as the total cementitious component). 

• Quality Control: The RMAN does not relieve the contractor of responsibility for 

providing a satisfactory product. Cement and concrete suppliers are already 

responsible both for the quality of the ingredients of their product, and for 

meeting appropriate performance requirements. This will continue to be the case 

under the RMAN, with no shift in normal industry procedures for assigning 

responsibility and liability for product quality. Procuring agencies should 

continue to expect suppliers of blended cement, coal fly ash or GGBFS, and 

concrete to demonstrate (through reasonable testing programs or previous 

experience) the performance and reliability of their product and the adequacy of 

their quality control programs. 

1.2.2.2 Cenospheres and Silica Fume 

For cement and concrete containing cenospheres, EPA advises that procuring agencies contact 

cenosphere suppliers to obtain specifications, such as material safety data sheets for assisting 

with use of cenospheres in cement and concrete. 

For cement and concrete containing silica fume, procuring agencies can refer to the following 

national specifications and guidelines, which enable procuring agencies to buy high-performance 

concrete containing silica fume of a standard quality: ASTM C1240, AASHTO M307, and ACI 

234R-06.28 In addition, ACI 234R-06 also describes the properties of silica fume; how silica 

fume interacts with cement; the effects of silica fume on the properties of fresh and cured 

concrete; typical applications of silica fume concrete; and recommendations on proportions, 

specifications, and handling of silica fume in the field. 

 

28 For more information, see: U.S. Department of Transportation, Federal Highway Administration (FHWA), April 

2005. “Silica Fume Users Manual.” (Publication No. FHWA-IF-05-016) 
1-7 

1.3 RMCs Analyzed 

The language in SAFETEA-LU defines RMCs as follows: 

A. Ground granulated blast-furnace slag (GGBFS) (other than lead slag);29

B. Coal combustion fly ash; 

C. Blast-furnace slag aggregate (BFSA or air-cooled blast-furnace slag) (other than 

lead slag aggregate);30 

D. Silica fume; and, 

E. Any other waste material or byproduct recovered or diverted from solid waste that 

the Administrator, in consultation with an agency head, determines should be 

treated as recovered mineral component under this section. 

Based on a review of construction materials standards and other information collected from a 

range of industry sources, the Agency created and applied selected criteria to determine which 

other waste materials or byproducts recovered or diverted from solid waste, as identified under 

point “E” above, should be included in the study for evaluation. We have further determined that 

it is most beneficial to focus on materials that embody greater potential for beneficial use, and 

for which data currently exists. Therefore, to be included in this study, we concluded that a 

material should be evaluated against the following four screening criteria. 

• Be a potential waste material or byproduct recovered or diverted from solid waste; 

• Have a total annual generation greater than 0.9 million metric tons (1 million 

short tons); 

• Be addressed in a national cement or concrete standard, (e.g., ASTM31, ACI32, or 

AASHTO33); and, 

 

29 GGBFS is a product of the iron smelting process and is addressed in this evaluation, along with boiler slag from 

power plants and steel furnace slag. Lead slag is from an entirely different metallurgical source. 30 EPA interprets the term “blast-furnace slag aggregate” to mean nongranulated blast-furnace slag that is used as 

aggregate in concrete as a replacement for other mineral aggregates. Steel furnace slag, made during the conversion 

of iron to steel and used primarily as an aggregate in base and asphalt, among other uses, and boiler slag, produced 

during the combustion of coal in power plants and used primarily in the manufacture of blasting grit, are addressed 

separately from blast-furnace slag. Pelletized slag works well as a lightweight aggregate (for lightweight concrete) 

and in mineral wool used in thermal and heat insulation. 

31 ASTM standards can be found in the “Annual Book of ASTM Standards,” Available from ASTM International at 

www.astm.org. Construction materials standards are contained in Section 4 – Construction. 32 American Concrete Institute, www.concrete.org. 

33 American Association of State Highway and Transportation Officials, www.transportation.org. 
1-8 

• Have data available which may be capable of supporting a more detailed analysis, 

including annual data on the quantity of material sent to cement or concrete 

manufacturers for five years up to 2004, and life cycle inventory data to support 

analysis of the substitution of the material using existing modeling platforms. 

Based on our review of the available information, EPA identified the following additional 

materials for screening and possible evaluation as “other potential RMCs”: 

• Foundry sand; 

• Cenospheres; 

• Flue gas desulfurization (FGD) gypsum; 

• Flue gas desulfurization (FGD) dry scrubber material; 

• Bottom ash from power plants; 

• Boiler slag from power plants; 

• Steel furnace slag; and 

• Cement kiln dust (CKD). 

EPA applied the screening criteria to the four materials identified by Congress, as well as the 

eight materials identified as “other potential RMCs.” Table 1-1 presents all of the mineral 

components considered for possible evaluation in this report, including those that did not meet 

all the screening criteria. Table 1-1 indicates that the four materials identified by the Congress 

generally satisfy the criteria. To make projections, it is important for the base year to be 

consistent across the RMCs. The 2004 quantity data represent the most recent year for which 

estimates for all four identified RMCs are available. A more detailed discussion of each 

material, including information on production, properties, and beneficial uses in cement and 

concrete production, is presented in Chapter 2. 

While none of the “other potential RMCs” identified by EPA meets all four of the specified 

screening criteria, this report provides an initial summary of all materials screened. The 

summary describes the volumes generated and beneficially used, as well as the characteristics of 

the beneficial reuse markets for each of these materials. However, the quantitative assessment of 

energy and environmental benefits in this report is limited to three materials for which there are 

sufficient data and existing modeling frameworks: coal fly ash, GGBFS, and silica fume. 

Although data exist for BFSA, power plant bottom ash, and boiler slag, available modeling 

frameworks do not support analysis of their energy and environmental impacts. The three 

materials examined in detail (coal fly ash, GGBFS, and silica fume) are all among those 

specified as RMCs by the language in SAFETEA-LU. 

 
1-9 

Table 1-1: Mineral Components Screened for Inclusion in Report 

Screening Criteria 

Material 

Estimated 

Annual 

Quantity 

Generated, 

2004a

(million metric 

tons) 

Estimated 

Quantity 

Beneficially Used, 

2004 

(million metric 

tons) 

Exists as 

Byproduct 

Produce > 

0.9 million 

metric 

tons/year 

Subject of 

National 

Standard1

Data Sufficient for 

Analysis 

RMCs NAMED BY CONGRESS 

Ground Granulated Blastfurnace Slagb 3.60 3.60 X X X X 

Coal Combustion Fly Ash c 64.20 25.50 X X X X

Blast-furnace Slag 

Aggregateb, d (ACBF Slag) 8.10 8.10 X X X h

Silica Fume e 0.10 – 0.12 0.08 X X X 

OTHER RMCs IDENTIFIED BY EPA 

Foundry Sand f 8.50 2.40 X X X 

Cenospheres c N.A. 0.0052 

(sold only) X X 

Flue Gas Desulfurization 

(FGD) Gypsum c 10.80 8.20 X X X 

Flue Gas Desulfurization 

(FGD) Dry Scrubber 

Material c

1.70 0.16 X X Xg

 

Power Plant Bottom Ash c 15.60 7.40 X X X h

Power Plant Boiler Slag c 2.00 1.80 X X X h

Steel Furnace Slag b 9.00 9.00 X X X 

Cement Kiln Dust (CKD) i 12.00 – 15.00 

1.20 

(excludes reuse back 

into kiln) 

X X 

Notes: 

a The estimated annual quantity available does not reflect stockpiled quantities. b van Oss, 2004b, values given are amount sold, as the industry does not report on actual production. These sales figures include imported 

materials. For example, an estimated one million tons of ferrous slag (i.e., granulated blast-furnace slag) were imported into the U.S. in 

2004; of this, approximately 75% was then ground to produce GGBFS domestically prior to sale. c ACAA, 2004. 2004 Coal Combustion Product (CCP) Production and Use Survey. d BFSA, while categorized as an evaluated material, was not fully modeled due to data and modeling limitations. A modified assessment of 

BFSA benefits is presented in Appendix D.

e

Kojundic, 8/30/2006 

f Oman, Alicia. American Foundry Society (AFS). Personal communication September 18, 2007. Foundry Sand data are annual 

average for 2005/06.

g ASTM C1157 sets a performance-based standard for blended hydraulic cement. There are no restrictions on the composition of the 

cement. These materials may be used in a concrete project that allows use of ASTM C1157. h While this information has recently become available, these materials have not been incorporated into current modeling platforms (e.g., 

BEES), and therefore are not included in the materials subject to a more detailed evaluation. However, as indicated above, a modified 

assessment of BFSA benefits is presented in Appendix D. i

 van Oss, 2005 (total estimate). The industry does not report CKD production. A majority of this material is known to be recycled back into 

the kiln. According to PCA, in 2006 approximately 1.2 million metric tons was beneficially reused (other than in kilns) and 1.4 million 

metric tons was landfilled (PCA, 2006. Summary of 2006 Cement Kiln Dust and Clinker Production). 

1 The Agency recognizes that, in general, most raw materials (e.g., limestone, sand, clay) used in portland cement manufacture are not 

subject to a national standard. However, the characteristics and specifications of raw materials are generally understood and commonly 

accepted. 

N.A.– Data not available. 

Congress specifically excluded lead slag from this Report
2-1 

2.0 INDUSTRY OVERVIEW, MATERIALS EVALUATED, AND CURRENT 

RMC SUBSTITUTION LEVELS 

This section provides a summary of the production and beneficial uses associated with the 

RMCs identified in the Introduction (Section 1). This includes RMCs specifically identified 

by Congress for further study, as well as the “other potential RMCs” identified by EPA. 

These topics are consistent with Part (A) of the Congressional mandate, which instructs EPA 

to analyze “...the extent to which recovered mineral components are being substituted for 

portland cement, particularly as a result of current procurement requirements....” 

The four mineral components identified by Congress include GGBFS, coal fly ash, BFSA, 

and silica fume. The other materials identified by EPA for consideration as RMCs include 

foundry sand, cenospheres, flue gas desulfurization (FGD) gypsum, flue gas desulfurization 

(FGD) dry scrubber material, power plant bottom ash, power plant boiler slag, steel furnace 

slag, and cement kiln dust (CKD). Descriptions and definitions of the materials and terms 

discussed in this section, and throughout the report, are provided in a glossary at the end of 

this report. 

All of the materials examined in this section are currently being reused as material substitutes 

in the cement manufacturing process or the concrete mixing process (or both).34 The degree 

to which these materials are being used in cement and concrete production ranges from 

relatively low (i.e., approximately 10% to 15%) to 100%. When used appropriately, these 

materials enhance the performance, handling, and durability of finished concrete products; 

this section qualitatively describes these benefits. In addition, the use of these materials in 

cement and concrete production yields a number of environmental and economic benefits, 

which we analyze and quantify in Section 3. Furthermore, using RMCs helps limit the 

amount of virgin material that must be mined or imported to meet U.S. demand for cement. 

In its simplest form, concrete is a mixture of cementitious material, water, and aggregates. 

The principal cementitious material in concrete is portland cement. When portland cement is 

combined with water, a chemical reaction called hydration occurs that causes the cement and 

hence the concrete to harden and strengthen over time into a rock-like mass. 

The concrete manufacturing process involves the production of portland cement and the 

mixing of cement with water and aggregates. This process can be summarized in the 

following steps: 

• Clinker Production: Cement making raw materials are proportioned, 

crushed, and ground into a raw material mix or meal that is used to make 

portland cement (e.g., limestone, shale, clay, sand, iron, etc.) and then fed into 

a large rotary kiln. As the raw mix moves through the kiln, the temperature of 

the mix is gradually raised to 1400-1450 degrees Celsius, which cause 

 

34 RMCs often have other applications as substitutes for aggregate in various applications (including concrete 

and unencapsulated uses, such as flowable fill and granular or stabilized road base) and other applications, such 

as blasting grit and soil amendments. However, consistent with the focus of the Congressional mandate, this 

report focuses on uses associated with cement and concrete. 
2-2 

volatiles (especially CO2) to be given off, while the remaining chemical 

oxides in the mix recombine into new compounds that exhibit hydraulically 

cementitious properties. These new compounds (“cement or clinker 

minerals”) exist together as semifused nodules of clinker that are up to about 4 

inches in diameter. 

• Grinding: The clinker is combined with other materials, such as gypsum, or 

another RMC, and fed into a cement mill where it is very finely ground into a 

powder-like consistency to form portland cement or blended cement.

• Concrete Mixing: Portland cement (plus any RMC incorporated as a partial 

substitute), fine and course aggregate, and water are mixed together in large 

drums to produce concrete. Soon after the aggregates, water, and the cement 

are combined, the mixture starts to harden. The concrete must be mixed 

thoroughly to coat all of the aggregate particles with cement paste.

The principal cementitious material in concrete is portland cement, but other supplementary 

cementitious materials (SCMs) can be used to partially offset portland cement in concrete. 

Some SCMs are called pozzolans, which by themselves do not have any cementitious 

properties, but when used with portland cement, react to form cementitious material. Other 

materials, such as slag, do exhibit cementitious properties. When SCMs are combined with 

portland cement in dry form prior to mixing in concrete, the result is a blended cement. 

Appendix A provides further technical detail on cement and concrete manufacturing.

2.1 RMCs Identified by Congress 

2.1.1 Blast-furnace Slag 

Blast-furnace slag is a byproduct of the process for smelting iron from iron ore. Various 

types of slags are produced when slagging agents (primarily limestone or dolomite) or 

fluxing materials are added to iron ores in blast furnaces to remove impurities. The fluxing 

process lowers the boiling point and increases the ore’s fluidity. In the process of reducing 

iron ore to iron, a molten slag forms as a non-metallic liquid (consisting primarily of silicates 

and aluminosilicates of calcium and other bases) that floats on top of the molten iron. The 

molten slag is then separated from the liquid metal and cooled. Depending on the cooling 

process used, either granulated blast-furnace slag (GBFS) or BFSA is produced. 

GBFS is produced by quickly quenching (chilling) molten slag to produce a glassy, granular 

product. The most common process is quenching with water, but air or a combination of air 

and water can be used. This rapid cooling allows very little mineral crystallization to take 

place and produces sand-sized particles of glassy material. When the cooled material is 

ground very finely into GGBFS, also known as slag cement, the disordered structure of the 

material gives it moderate hydraulic cementitious properties, meaning it will hydrate and 

gain strength when mixed with water, though at a much slower rate than portland cement. 

When used in concrete mixes with portland cement, however, the GGBFS combines with the 

free lime generated by partial portland cement hydration processes and hardens at an 
2-3 

accelerated rate. When used in this manner, GGBFS develops strong hydraulic cementitious 

properties and can be used with portland cement in concrete manufacture. GGBFS can 

represent 20% to 80% of the total cementitious material used in concrete mixes, depending 

upon the application and engineering requirements. GGBFS is discussed in more detail in 

section 2.1.1.1. 

Unground or less finely ground slag (GBFS) can also be used as aggregate in concrete mixes. 

Due to the greater cost of the granulation process compared to air-cooling, however, it is 

unlikely that newly created or high quality GBFS would be used in low-value applications, 

such as aggregate. The growing price for GGBFS further limits the opportunities for its use 

as an aggregate. Previously stockpiled or low-quality GBFS is more likely to be used as an 

aggregate. 

BFSA, also referred to as air-cooled blast-furnace slag (ACBFS), is produced by allowing the 

molten slag to cool and solidify slowly under ambient (atmospheric) conditions. This is 

typically done by pouring the molten blast-furnace slag into pits for slow cooling. Once 

cooled, it is crushed, screened, and used as aggregate in applications, such as road base, 

concrete, asphalt concrete, rail ballast, roofing, shingles, mineral wool, and glass making. 

ACBFS also can be used as a raw material in clinker manufacture. This material is discussed 

in greater detail in section 2.1.1.2. 

The iron and steel industries do not collect data on the total quantity of blast-furnace slag 

produced in the United States. The USGS estimates, however, that the quantity of blastfurnace slag produced is equivalent to 25% to 30% of crude iron (i.e., pig iron) production 

(van Oss, 2004b). In addition, USGS collects data on sales of slag. In 2004, U.S. sales of 

blast-furnace slag were valued at approximately $289 million. Most of the slag produced is 

air-cooled slag (approximately 75% by tonnage), with a lesser amount of granulated slag 

(approximately 25%) and a small amount of pelletized slag. Some is also used as lightweight 

aggregate for concrete. A significant quantity of the GGBFS sold in the United States is 

produced by grinding imported material. 

USGS estimates that approximately one million metric tons of blast-furnace slag were 

imported into the United States in 2005, including about 760,000 metric tons of granulated 

slag. Table 2-1 summarizes the estimated total blast-furnace slag production in the United 

States for 2000 through 2005 (van Oss, 2006, unless otherwise noted). Table 2-1 also 

includes U.S. sales of GBFS and BFSA. Sales of GGBFS in 2004 were approximately 3.6 

million metric tons out of a total GBFS sales of 4.1 million metric tons. 
2-4 

Table 2-1: U.S. Iron Blast-furnace Slag Domestic Production and Sales (iron only) 

Estimated Slag 

Production Sales of GBFS 

Sales of GGBFS 

(subset of GBFS) 

Sales of BFSA 

(ACBFS)

Year ---------------------------------million metric tons-------------------------------------- 

2000 12.0–14.5 2.3* 2.0*** 8.9 

2001 10.5–12.5 2.3* 2.4*** 8.1 

2002 10.0–12.0 3.7 3.3 ** 

2.9 *** 

7.4 

2003 10.0–12.0 3.6 3.5 ** 

3.1 *** 

7.3 

2004 12.0–14.0 4.1 3.6 ** 

3.5 *** 

8.1 

2005 9.0–11.0** 4.4** 3.7** 8.4** 

* 2000 and 2001 sales were believed to be underreported 

** van Oss, 2002, 2003, 2004, 2005, 2006. 

*** National Slag Association Data, as reported by van Oss, 2002, 2003 and 2004b and Slag Cement Association, 

2006. 

Note: Sales of GGBFS includes imported material that is ground in the U.S. 

As of December 31, 2005, 16 integrated steel mills located in nine different states were in 

operation in the United States (Wagaman, 2006). 35 According to USGS, 44 facilities were 

processing blast-furnace slag in the United States in 2004.36 Five of these facilities produced 

GBFS (Wierton, West Virginia; South Chicago, Illinois; Gary, Indiana; Sparrows Point, 

Maryland; and Birmingham, Alabama). In addition, some grinding facilities only grind 

imported GBFS or are exploiting old slag piles from past years’ production (van Oss, 2004b). 

Figure B-1 in Appendix B shows the geographic distribution of cement plants that use slag as 

a raw material in clinker production and blend slag into finished cement products. Also, a 

table containing additional information on these locations can be found in Appendix C. 

2.1.1.1 Granulated Blast-furnace Slag (GBFS)37

According to the USGS, approximately 4.1 million metric tons of GBFS were sold in the 

United States in 2004 (see Table 2-2). The total value of these sales was approximately $236 

million, the majority of which was represented by sales of GGBFS. Average sales prices for 

GBFS were $61.50 per metric ton, with a reported range of $22.05 per metric ton for 

unground GBFS to $71.65 per metric ton for GGBFS. This range does not include old, 

weathered GBFS from existing stockpiles that is sold as fine aggregate for a few dollars per 

metric ton. The prices for GBFS are rising, are much higher than for other slag types and 

GGBFS tends to sell for 75%-80% of the price of cement (von Oss, 2007). In 2004, 

approximately 91% of GBFS (3.73 million metric tons) was sold for cementitious uses. This 

included approximately 104,000 metric tons of GBFS used in the manufacture of clinker, and 

 

35 An integrated steel mill is one that smelts iron ore into liquid iron in blast furnaces and uses basic oxygen 

furnaces to refine this iron into steel. 

36 Since slag producers can have contracts with multiple processors at the same location, some of these facilities 

might be doubled counted. 

37 Data presented in this section address GBFS, which includes ground and unground blast-furnace slag. 

Separate data are not available for GGBFS, but GGBFS is known to account for the majority of GBFS. 
2-5 

approximately 345,000 metric tons used in the manufacture of blended cement. The 

remaining GBFS sold for cementitious uses (3.28 million metric tons) was used directly in 

concrete as a substitute for portland cement. The majority of materials not sold for 

cementitious uses (i.e., the 9% of the 4.1 million metric tons sold in 2004) were old and poor 

quality material mined from existing slag piles; this material was sold for use as a fine 

aggregate (van Oss, 2004b). Although no data exist on the disposal or landfilling of blastfurnace slag, it is likely that the utilization of GBFS is nearly 100% of U.S. production, 

which reflects the high value of these materials as SCMs, aggregates, or components of 

blended cements. In fact, granulated slag is currently being imported into the U.S. in order to 

meet the needs of the U.S. construction industry. 

Table 2-2 summarizes GBFS (both ground and unground) sales and usage in clinker and 

cement manufacture for 2000 through 2005 based on data from the USGS (van Oss, 2004, 

2004b, 2003, 2003b, 2002, 2002b, 2001). GBFS usage in concrete is estimated by subtracting 

total usage in clinker and cement manufacture from total sales. 

Table 2-2: Granulated Blast-furnace Slag (GBFS) Usage 

Estimated GBFS 

Sales

GBFS Usage in 

Clinker 

Manufacture 

GBFS Usage in 

Cement 

Manufacture 

GBFS Usage in 

Concrete

Year ----------------------------------million metric tons-----------------------------------

2000 2.3* -- 0.303 

0.105*** 1.997**

2001 2.3* -- 0.300 

0.154*** 2.0**

2002 3.7 0.060 0.369 

0.157*** 3.271**

2003 3.6 0.017 0.333 

0.157*** 3.25** 

2004 4.1 0.104 0.345 

0.159*** 3.651** 

2005 4.4 0.144 0.521 3.735** 

Source: USGS data 

* 2000 and 2001 sales were believed to be underreported. 

**Estimated by subtraction. 

*** Slag Cement Association, 2006. 

The primary benefit of using GGBFS as a SCM is that it allows the same amount of portland 

cement to yield more yards of concrete, increasing productivity and reducing the total 

quantity of portland cement required to meet demand for certain types of concrete. The 

beneficial properties of concrete mixes containing GGBFS include the following: 

• Strength Development: Concrete containing GGBFS develops strength at a 

somewhat slower rate than concrete containing only portland cement, but 

ultimately can develop equivalent or even superior strength. The reduced 

early strength can be a concern where early strength development is 

important, such as for non-heat cured pre-cast concrete or where rapid repairs 
2-6 

are sought on busy highway structures. Low temperatures generally have a 

more adverse impact on strength development with concrete containing 

GGBFS than concrete containing only portland cement. However, the higher 

ultimate strength development in concrete with GGBFS can allow for 

reductions in the portland cement component in a concrete mixture for a given 

ultimate (28-day) strength level. 

• Workability: Concrete containing GGBFS as a partial cement replacement 

has longer-lasting workability and low slump loss during hot weather 

construction (though this can be a detriment during cold weather 

construction). Concrete containing GGBFS is also easier to finish. 

• Heat of Hydration: Concrete with high replacement rates of GGBFS (i.e., 

approximately 70%) exhibits a lower heat of hydration than conventional 

portland cement concrete; this characteristic is an advantage for large mass 

concrete applications, but can be a disadvantage for some projects in colder 

climates. 

• Permeability: Concrete containing GGBFS has significantly reduced 

permeability, which keeps moisture and harmful constituents out of the 

concrete 

• Corrosion Resistance: The reduced permeability of concrete containing 

GGBFS can protect reinforcing steel in reinforced concrete from corrosion for 

much longer periods of time than concrete without GGBFS. 

• Alkali-Silica Reaction: The use of GGBFS blended with portland cement in 

concrete reduces the alkali content of the cement paste and reduces 

permeability and water ingress, thus mitigating the potential of developing 

adverse reactions between alkalis in the cement paste and certain forms of 

silica present in some aggregates.38

• Sulfate Resistance: Use of GBFS with portland cement can give concrete 

moderate to high resistance to sulfate attack. 

• White Color: GGBFS is a much lighter color than most other commonly 

used cementitious materials (i.e., grey portland cement, silica fume, coal fly 

ash). Thus, it measurably lightens the concrete and increases its solar 

reflectivity which provides benefits, such as greater safety at night, reduced 

lighting requirements, and preferred architectural finishes. It also can help 

reduce the urban heat island effect through higher albedo. 

 

38 Holcim (US) Inc. commented that, in addition to the more common alkali-silica reaction, “alkali-aggregate 

reaction includes a particular, but little seen, reaction known as alkali-carbonate reaction,” and it was its 

“understanding that slag [i.e., GGBFS containing] concrete shows some effectiveness in resisting this form of 

alkali-aggregate reaction, but there is no large volume of work on the topic.” 
2-7 

According to the SCA, some laboratory testing has indicated that concrete containing 

GGBFS (and coal fly ash) might be more susceptible to salt scaling when deicer salts are 

applied and the concrete undergoes freeze-thaw cycling. On the other hand, other studies 

have not found this to be the case, or have even found improved performance. (Scaling is the 

loss of a thin layer, usually less than 1/4 inch of surface paste/mortar, sometimes exposing 

larger aggregates beneath.) To clarify this issue, FHWA and SCA, in conjunction with the 

Iowa State University’s Center for Portland Cement Concrete Pavement Technology (PCC 

Center) are collaborating on a project to document the performance of GGBSF-containing 

concrete exposed to cyclical freeze-thaw cycles in the presence of deicing chemicals.39

2.1.1.2 Blast-furnace Slag Aggregate (Air-Cooled Blast-Furnace Slag)

BFSA, also known as air-cooled blast-furnace slag, emerges from iron furnaces in a molten 

state and is air-cooled. It is produced by pouring molten blast-furnace slag into outdoor pits 

and allowing it to cool and solidify slowly under atmospheric conditions. Small quantities of 

water are sprayed on top to induce fractures during the final cooling stages. Once cooled, 

BFSA is crushed and screened to produce a material similar to gravel that is used as a 

construction aggregate for road base, concrete, asphalt, rail ballast, roofing, granules for 

roofing shingles, and glass making. 

Sales of BFSA for all uses for 2003 and 2004 are shown in Table 2-3. In 2004, BFSA sales 

were 8.1 million metric tons, with a total value of $49 million. Average sales prices of BFSA 

in 2004 were $6.50 per metric ton, with a range of $1.54 to $17.35 per metric ton. Total 

usage of BFSA in cement and concrete products (including clinker manufacture) for 2004 

was approximately 2.08 million metric tons, which accounts for about 26% of annual U.S. 

sales. 

Table 2-3: Sales of Blast-furnace Slag Aggregate (BFSA) by Use in 2003 and 2004 

2003 2004*** 

BFSA Use Percent 

Quantity 

(million metric 

tons) Percent 

Quantity 

(million metric 

tons)

Ready-Mixed Concrete 9.3 0.68 20.4 1.65 

Concrete Products 6.4 0.47 3.5 0.28 

Clinker Raw Material 5.7 0.42 1.9 0.15 

Other Uses* 78.6 5.73 74.2 6.00 

Total** 100 7.3 100 8.1 

Source: van Oss, 2004b 

* Primarily as construction aggregate for granular and bound road base and asphalt road surfaces. 

** Data may not add to total due to rounding. Data reporting on slag uses is biased towards major uses. 

*** Recently received data show a total of 7.3 million metric tons of BFSA were sold in 2006, indicating declining 

usage.(Pulipaka, Aswani S., et.al.) 

 

39 For more information, refer to: American Concrete Institute, “Proposed Changes to ACI 318-05” accessible 

at: http://www.concrete.org/Technical/FlashHelp/Proposed_Changes_to_318-05.htm. 
2-8 

As indicated in Table 2-3, 100% of BFSA is currently believed to be utilized40, with its 

largest use as aggregate in road bases and surfaces, including use in asphaltic concrete. Its 

next largest use is primarily as an aggregate in concrete mixes and aggregate base (20.4% in 

2004). When used in this capacity, it reduces the need to quarry, crush, sort, and transport 

virgin aggregate. Small amounts of BFSA also are used to replace raw feed in the clinker 

production process (less than 2% in 2004) and used as an aggregate in concrete products 

(3.5% in 2004). 

2.1.2 Coal Fly Ash 

Coal fly ash is the finely divided airborne mineral residue generated by the combustion of 

ground or powdered coal in coal-fired power plants. Four basic types of coal-fired boilers 

operate in the United States: 1) pulverized coal (PC) boilers, 2) stoker-fired or traveling grate 

boilers, 3) cyclone boilers, and 4) fluidized-bed combustion (FBC) boilers. The PC boiler is 

the most widely used, especially for large electric generating units. The other boilers are 

more common at industrial or cogeneration facilities. Typically, in a PC boiler, coal is 

pulverized and blown with air into the boiler’s combustion chamber where it immediately 

ignites, generating heat and producing a molten mineral residue. Boiler tubes extract the heat 

from the boiler, cooling the flue gas and causing the molten mineral residue to harden and 

form ash. Coarse ash particles, referred to as bottom ash or boiler slag, fall to the bottom of 

the combustion chamber, and the lighter fine ash particles (coal fly ash) remain suspended in 

the flue gas. Prior to exhausting the flue gas to the atmosphere, coal fly ash is removed by 

particulate emission control devices, such as electrostatic precipitators or fabric filtration 

baghouses. 

According to the ACAA survey data, of the 64.2 million metric tons of coal fly ash produced 

in the United States in 2004, approximately 40% (25.5 million metric tons) was beneficially 

used, while the remaining 60% (approximately 38.8 million metric tons) was disposed of in 

land disposal units. Utilization of coal fly ash has increased through 2006 to nearly 45%. 

Table 2-4 illustrates the major uses of coal fly ash for the years 2002 through 2006. 

Table 2-4: Major Uses of Coal Fly Ash 

Year 

2002 2003 2004 2005 2006 

Production and Usage --------------------million metric tons---------------------- 

Total U.S. Production 69.401 63.640 64.230 64.502 65.680 

Utilization: 

Concrete/Concrete Products/Grout 11.412 11.127 12.811 13.599 13.645 

Cement/Raw Feed for Clinker 1.740 2.744 2.128 2.571 3.765 

All Other Uses 11.006 10.388 10.525 10.246 12.004 

Total Utilization 24.158 24.259 25.464 26.416 29.414 

 Percent Utilization 34.8% 38.1% 39.6% 41.0% 44.8% 

Source: ACAA, 2002, 2003, 2004, 2005, and 2006. 

 

40 Recently identified data indicate that BFSA may be utilized at less than 100% of generation. However, these 

data are from the year 2000 (Pulipaka, A. S., et. al., undated). 
2-9 

Typically, coal fly ash is used in construction applications. Both Class C and F coal fly ash 

can serve as substitutes for conventional materials in construction projects.41 The most 

common beneficial use of coal fly ash is as a SCM in concrete. Coal fly ash is also used as a 

raw material in the production of cement clinker and as an additive to blended cements. The 

consistency and abundance of coal fly ash in many areas present unique opportunities for use 

in many construction applications, including pavements and highway and transportation 

structures, and can generate environmental benefits when used as a replacement for virgin 

materials (e.g., portland cement). Reported coal fly ash generation and use in cement 

manufacture and in concrete for the years 2000 through 2006 are summarized in Table 2-5. 

Table 2-5: Coal Fly Ash Generation and Sales for Utilization in Cement, Clinker, and 

Concrete 

Coal Fly Ash Utilization in Cement and 

Clinker Manufacture 

Coal Fly Ash 

Generation 

(ACAA) USGS ACAA 

Coal Fly Ash 

Utilization in 

Concrete (ACAA) 

Year --------------------------------------million metric tons--------------------------------

2000 No Data 1.77 No Data No Data 

2001 61.8 1.67 0.94 11.2 

2002 69.4 2.02 1.74 11.4 

2003 63.6 2.29 2.74 11.1 

2004 64.2 2.97 2.13 12.8 

2005 64.5 3.10 2.57 13.6 

2006 65.7 ------ ------ 13.6 

Sources: ACAA, USGS, and van Oss, 2001, 2002b, 2003b, 2004; ACAA, 2001, 2002, 2003, 2004, 2005, 2006. 

Certain performance benefits can be attained through the use of coal fly ash in concrete, 

including greater workability, higher strength, and increased longevity in the finished 

concrete product. Specifically: 

• Spherical particle shape allows the coal fly ash to flow and blend freely in 

mixtures improving mixing and handling. 

• Ball bearing effect creates a lubricating action when concrete is in its plastic 

state; as a result, pumping is easier because less energy is required and longer 

pumping distances are possible. 

• Strength increases as it continues to combine with free lime, increasing the 

structural strength over time. 

• Reduced permeability and increased durability. 

• Reduced shrinkage from the lubricating action of coal fly ash reduces water 

content and drying shrinkage. 

 

41 The chemical composition of coal fly ash varies greatly depending on the type of coal used. Two types of 

coal fly ash, Class C fly ash and Class F fly ash, are included in the American Society for Testing and 

Materials’ technical requirements for concrete. Information on these standards is available at 

<www.astm.org>. Additional information on coal fly ash is provided in Appendix B. Other coal fly ash 

classification standards are being considered to facilitate the best uses for coal fly ash. Examples include the 

CSA Canadian standards. 
2-10 

• Reduced heat of hydration reduces thermal cracking (e.g., for dams and other 

mass concrete placements). 

• Improved workability makes concrete easier to place. 

• Where sharp, clear architectural definition is easier to achieve, finishing is 

improved with less concern about in-place integrity. 

• Reduced susceptibility to chemical attack (e.g., sulfate attack) (IEA, 2005). 

There are a few potential issues with the use of coal fly ash in concrete, including: 

• Lack of uniformity and consistency between coal fly ash sources, possibly 

requiring users to test each source. 

• Slower setting and early-are strength gain in cool weather concreting. 

• Loss of air entrainment caused by the fine structure of coal fly ash and/or 

residual unburned carbon content; this property requires additional air 

entrainment to maintain concrete strength and durability. 

• Reduced freeze/thaw and scaling resistance is possible when a major part of 

the cementitious material is replaced with coal fly ash. However, if the 

strength and air-void properties of the concrete mixture are kept constant, no 

major effect on the freeze-thaw resistance has been observed. 

• Reduced abrasion resistance in concrete mixtures where coal fly ash 

comprises greater than 50% of the cementitious material. Concrete mixtures 

with coal fly ash representing less than 40% of the cementitious material show 

no decrease in abrasion resistance. 

2.1.3 Silica Fume 

Silica fume, also referred to as microsilica or condensed silica fume, is a very fine, dust-like 

material generated during silicon metal and ferrosilicon and related ferroalloys production. 

Specifically, it is produced by the reduction of high purity quartz with coal or coke and wood 

chips in an electric arc furnace during silicon metal or ferrosilicon alloys production. The 

glassy, spherical particles are extremely small, measuring less than 1 micrometer (μm) in 

diameter, with an average diameter of about 0.1 μm. Silica fume particles are composed 

primarily of silicon dioxide (usually more than 85%). The silica fume is collected in electric 

arc furnace stack filters and recovered for reuse as a pozzolan in high performance concrete 

(HPC). Silica fume is sold in the United States in powder form and is often made denser by 

tumbling it in a silo, which leads to the build-up of surface charges and an agglomeration of 

particles. 

ACI estimates that global silica fume production is approximately 900,000 metric tons per 

year and that at least 120,000 metric tons are used in concrete worldwide (ACI, 2006). The 

SFA estimates that silica fume production in the United States in 2004 was between 100,000 

and 120,000 metric tons. Of that amount, an estimated 20,000 metric tons were used in 

clinker manufacturer, while less than 3,000 metric tons were used in blended cement 

production and approximately 60,000 metric tons were used in concrete manufacture. The 

SFA also estimates that about 25,000 metric tons of silica fume were landfilled in 2004 and 

that less than 16,000 metric tons will be landfilled in 2006 in the U.S. (Kojundic, 2006). 
2-11 

Table 2-6 summarizes silica fume production and usage in cement and concrete for the years 

2000 through 2004. 

Table 2-6: U.S. Silica Fume Production and Usage in Cement and Concrete 

Year 

2000 2001 2002 2003 2004 

----------------------------------metric tons----------------------------------------------

Production No Data No Data No Data No Data 100,000 - 

120,000 

In Clinker 18,000 19,000 19,000 19,000 20,000 

In Cement No Data No Data No Data No Data <3,000 

In Concrete 55,000 56,000 51,000 53,000 60,000 

Source: The Silica Fume Association accessed at www.silicafume.org and Kojundic, 8/30/2006. 

Silica fume’s physical and chemical properties confer several benefits to finished concrete 

when used with portland cement in concrete mixes, including: 

• Increased compressive strength and abrasion resistance: Significant 

improvements in compressive strength can be realized through the addition of 

silica fume to concrete, making silica-fume concrete particularly useful in 

applications, such as columns in high-rise buildings, girders in HPC bridges, 

and abrasion-resistant pavements or floors.

• Reduced Bleeding: Silica fume reduces the bleeding in concrete that leads to 

the formation of capillary channels, which can increase chloride intrusion in 

finished concrete. Eliminating bleeding also allows concrete to be finished 

earlier. 

• Permeability: Reduced permeability of concrete containing silica fume limits 

intrusion of chloride ions from deicing chemicals and helps resist attack from 

chemicals, such as sulfates leading to increased durability. 

• Corrosion Resistance: Reduced chlorine ion intrusion protects the 

reinforcing steel from corrosion and helps extend the life of structures. 

• Single-Pass (One-Pass) Finishing: Silica fume concrete can utilize singlepass finishing whereby the finishing is condensed into a single operation that 

shortens finishing time. 

Increased modulus of elasticity (with use of silica fume), however, makes the concrete more 

brittle and can result in additional cracking. 
2-12 

2.2 Other RMCs Evaluated

The discussion below reviews the generation and beneficial use of the “other potential 

RMCs” selected for this analysis. These RMCs were identified through the screening 

procedures described in Section 1.3. 

2.2.1 Foundry Sand 

Foundry sand is high-quality silica sand used in the production of both ferrous and 

nonferrous metal castings. The physical and chemical characteristics of foundry sand depend 

on the type of casting process and industry sector from which it originates. Industry sources 

estimate that approximately 90 million metric tons of foundry sand are used in production 

annually. Of that amount, approximately 8.5 million metric tons of foundry sand are 

discarded as "spent" in a year; the remainder is recycled and put back and reused in the 

foundry process. A survey by the American Foundry Society (AFS) estimates that 2.4 

million metric tons of the spent foundry sand were beneficially used, suggesting that about 

six million metric tons may be available to be recycled into other products or used by other 

industries (U.S. EPA, 2007). A small percentage (approximately 2%) of the spent foundry 

sand are considered hazardous waste due to metal contaminants (U.S. EPA, 1998). 

Some spent foundry sands that use organic binders also have been found to contain trace 

amounts of hazardous organic compounds, though most of these constituents have been 

found to be well below regulatory levels (U.S. EPA, 2002). 

Spent foundry sand can be used in the manufacture of portland cement clinker. Most foundry 

sands are high in silica content and can serve as a potential alternative silica source in 

portland cement clinker production. In addition, portland cement clinker production requires 

certain minerals, such as iron and aluminum oxides, both of which are found in many spent 

foundry sands. Some foundry sands however, can have materials in it that are not 

appropriate for use in kilns and therefore may not be utilized. 

Combined data for total quantities of sand and calcium silicate used in the production of 

cement clinker in the United States are available from the USGS for the years 2000 through 

2004 and are provided in Table 2-7 (van Oss, 2004, 2003b, 2002b, 2001). These data may 

include the beneficial reuse of spent foundry sand, although the industry does not identify the 

quantity of spent foundry sand being used in cement kilns. The tonnages shown in Table 2-7 

primarily consist of silica sand, as the amount of calcium silicates is generally insignificant 

(USGS, 2001-2004). 

Table 2-7: Sand and Calcium Silicate Utilization in Cement Kilns

Year 

2000 2001 2002 2003 2004 

-------------million metric tons---------- Sand and Calcium Silicate Used 

3.142 3.500 2.960 2.860 3.150 

Source: USGS, 2001 – 2004 (van Oss, 2004, 2003b, 2002b, 2001). 
2-13 

Spent foundry sand can be reused to replace virgin sand in both the cement clinker 

manufacturing process and in concrete mixing. The use of spent foundry sand eliminates the 

need to mine and mill virgin materials, saving energy and other resources. However, the 

amount of available foundry sand varies widely by region of the country. In many regions, 

foundry sand is not available in the quantities necessary for controlled production processes. 

2.2.2 Cenospheres 

Cenospheres are very small (10 to 350 μm in diameter), inert, lightweight, hollow, “glass” 

spheres composed of silica and alumina filled with air or other gases. They occur naturally 

in coal fly ash and are recovered from the ash for use as aggregate (filler) in many 

applications such as concrete and plastic products. Cenospheres are not usually intentionally 

manufactured. Their principal source is coal fly ash. The characteristics of and amount of 

cenospheres produced in coal fly ash varies depending upon the type of coal used, the plant 

type, and the firing conditions under which the spheres are formed. 

The percentage of cenospheres used in concrete varies depending on the application and 

desired performance characteristics of the concrete. However, according to industry sources, 

the typical content of cenospheres in concrete ranges from 10% to 40% by volume. Concrete 

containing cenospheres also often contains coal fly ash. 

ACAA began reporting cenosphere sales in its annual coal combustion product production 

and use survey in 2004. ACAA reports that approximately 5,200 metric tons of cenospheres 

were sold in the United States in 2004, 7,00042 metric tons were sold in 2005, and 5,000 

metric tons were sold in 2006. Actual annual cenosphere production is much greater than the 

volumes being sold, as not all cenospheres are separated from the coal fly ash for use. No 

current data are available on annual cenosphere production, and it is questionable whether 

sufficient data exist to allow a meaningful estimate of the cenosphere content of airborne 

particulates (i.e., percent of cenospheres to weight of coal fly ash). However, ACAA 

indicated that between 570,000 and 2,900,000 metric tons of cenospheres were generated in 

1998 in the United States, of which 23,000 to 41,000 metric tons were separated from coal 

fly ash and recycled (EPA, 2004). Cenospheres that are not separated and reused are 

recycled or landfilled with the coal fly ash from which they are derived. 

When incorporated into concrete mixes as fillers or extenders, cenospheres increase the 

strength of the concrete and decrease shrinkage and weight. However, cenospheres may also 

react in the concrete. Cenospheres are 75% lighter than other minerals currently used as 

fillers, which reduces the final concrete mix’s weight and increases their thermal stability and 

overall durability. Cenospheres can be used in concrete with other recovered materials, such 

as coal fly ash and silica fume.43 

 

42 This is an adjusted figure. The 2005 ACAA report: “2005 Coal Combustion Product (CCP) Production and 

Use Survey” erroneously reported this figure as 70,918 metric tons (78,174 U.S. tons). 

43 Cenospheres also are often used in other industrial filler applications replacing other filler materials, such as 

manufactured glass, calcium carbonate, clays, talc, and other silicas. 
2-14 

2.2.3 Flue Gas Desulfurization (FGD) Materials 

Flue gas desulfurization (FGD) byproducts are generated by air pollution control devices 

used at any sulfur dioxide (SOx ) producing emissions source that has an appropriate 

scrubber, like some coal-fired electric power plants. Power plants and other types of 

facilities (e.g., some cement plants) use a number of FGD processes to control sulfur oxide 

(SOx) emissions from the combustion of coal. FGD processes spray lime or limestone 

reagents into the exhaust gas, which removes and converts the SO2 to sludge or a semi-sludge 

byproduct. In 2006, more than 27 million metric tons of FGD byproducts were produced in 

the United States (ACAA, 2006). 

FGD processes are characterized as either wet or dry processes. Wet FGD scrubbers use 

aqueous solutions of either slaked lime (calcium hydroxide, Ca(OH)2), or limestone 

(principally calcium carbonate, CaCO3) to saturate the exhaust gas in a spray tower. These 

solutions react with and oxidize the SO2 particles creating a byproduct known as scrubber 

sludge. Dry FGD systems use less water and generate a byproduct with different attributes. 

Two types of wet FGD processes are used today—natural oxidation and forced oxidation. In 

natural oxidation, only the oxygen naturally occurring in the flue gas is used to remove SO2. 

The resulting byproduct consists mostly of calcium sulfite (CaSO3). In forced oxidation, 

additional air is supplied by blowers, which creates a byproduct consisting primarily of 

calcium sulfate dihydrate (CaSO4·2H2O), or gypsum. While FGD sludge produced using 

natural oxidation has limited beneficial use options, gypsum from forced oxidation (also 

referred to as synthetic gypsum) is readily used as a direct replacement for natural gypsum in 

wallboard production and grinding with clinker to produce finished cement. The Portland 

Cement Association (PCA) reports that in 2005, 21 portland cement plants were using FGD 

sludge in the manufacture of cement (see Appendix B, Figure B-8) (PCA, 2005). 

Table 2-8 summarizes FGD production for the years 2001 through 2006 (ACAA, 2001, 2002, 

2003, 2004, 2005, and 2006). Additional discussion of the production and uses for FGD 

gypsum and dry scrubber material can be found in the sections that follow. FGD sludge from 

natural oxidation processes is not discussed further, as this material has seen little use in 

cement manufacture or in concrete. 
2-15 

Table 2-8: U.S. Flue Gas Desulfurization (FGD) Material Production 

Wet Scrubber Material 

Forced Oxidation 

(FGD Gypsum) 

Natural 

Oxidation 

(CaSO3) 

FGD Dry 

Scrubber 

Material Other FGD Total FGD 

Year -----------------------------------million metric tons-----------------------------

2001* No Data No Data No Data No Data 25.840 

2002 10.342 15.332 0.849 -- 26.522 

2003 10.796 15.740 1.310 0.152 27.998 

2004 10.841 15.876 1.660 0.105 28.482 

2005 10.864 16.057 1.295 -- 28.216 

2006 10.977 14.787 1.351 0.271 27.386 

Source: American Coal Ash Association (ACAA), 2001, 2002, 2003, 2004, 2005, and 2006. 

* No breakout of FGD materials by type was reported for 2001. 

2.2.3.1 Flue Gas Desulfurization (FGD) Gypsum 

According to ACAA, U.S. coal-fired power plants produced approximately 11.0 million 

metric tons of FGD gypsum in 2006, with approximately 8.7 million metric tons being 

reused—approximately 79%. Of this amount, approximately 81% is used in wallboard 

manufacturing, about 16% is used in concrete, concrete products and grout, and about 3% is 

interground with clinker to produce finished cement. This indicates that while there is FGD 

gypsum available for increased use, only a minimal amount may potentially be used in 

cement and concrete. Table 2-9 summarizes ACAA data on the production and utilization of 

FGD gypsum for the years 2002 through 2006 (ACAA, 2002, 2003, 2004, 2005, 2006). 

Table 2-9: FGD Gypsum Production and Utilization 

Year 

2002 2003 2004 2005 2006 

Production and Usage ----------------------million metric tons----------------------- 

Total Production 10.3421 10.7957 10.841 10.8637 10.9769 

Utilization 

Concrete/Concrete Products/Grout 0.0550 0.0595 0.2644 0.2982 1.3988 

Cement/Raw Feed for Clinker* 0.2756 0.3811 0.4074 0.3608 .2400 

All Other Uses (primarily wallboard) 6.7183 7.0883 7.5338 7.7493 7.0352 

Total Utilization 7.0489 7.5289 8.2056 8.4083 8.6740 

 Percent Utilization 68.2% 69.7% 75.7% 77.4% 79.0% 

* FGD Gypsum is primarily interground with clinker to produce finished cement, not as a raw feed in clinker 

production. 

Source: ACAA, 2002, 2003, 2004, 2005, and 2006. 

The availability of FGD gypsum is expected to grow as more scrubbers are installed 

nationally, potentially allowing for increased use. According to DOE, Energy Information 

Administration (DOE EIA-767), 32 facilities reported that they produced approximately 9.4 

million metric tons of FGD gypsum in 2004 (DOE, 2004). Table B-5, found in Appendix B, 

indicates production and disposition of FGD gypsum by state for 2004. Also, a listing of 

FGD gypsum producers in 2004 is contained in Appendix C. 
2-16 

The handling of FGD gypsum can be problematic because it is abrasive, sticky, 

compressible, and much finer than natural gypsum. These difficulties are often offset by the 

resource’s proximity to manufacturing facilities. While the majority of FGD gypsum 

produced is used in wallboard production, a small percentage is used in finished cement 

products. In the cement production process, FGD gypsum use has the benefit of replacing 

virgin gypsum that is ground with clinker to regulate the setting time of finished portland 

cement. Gypsum cement, a strong type of plaster, can also be made from FGD gypsum. 

2.2.3.2 Flue Gas Desulfurization (FGD) Dry Scrubber Material 

Dry FGD systems remove SO2 emissions, such as from coal-fired power plant flue gas by 

contacting a lime or limestone sorbent slurry. The most common dry FGD design is the 

spray dryer system in which a slaked lime slurry is sprayed into the flue gas. The dry FGD 

process still uses water, although much less than wet processes, and it does not saturate the 

flue gas as the wet processes do. The resulting byproduct, formed by the reaction of the 

slurry and SO2, is dried by the heat of the flue gas and collected with the coal fly ash in a 

particulate control device (either a fabric filter/baghouse or an electrostatic precipitator). 

Some dry FGD byproducts can contain high concentrations of sulfur materials that may form 

ettringite, a hydrophilic material, which expands when hydrated. As a result, these 

byproducts may not be suitable for use in concrete and are not suitable for foundation or 

paving use. 

In 2006, about 1.35 million metric tons of dry FGD materials were produced in the United 

States (ACAA, 2006) and about 9,000 metric tons of dry FGD material was used in concrete 

products. The material not reused is primarily stored and/or disposed of in land disposal 

units. Table 2-10 summarizes dry FGD material production and usage for the years 2002 

through 2006 (ACAA, 2002, 2003, 2004, 2005, 2006). 

Table 2-10: Dry Flue Gas Desulfurization (FGD) Material Production and Usage 

Year 

2002 2003 2004 2005 2006 

Production and Usage -----------------------thousand metric tons------------------ 

Total Production 848.6 1,310.2 1,660.0 1,294.8 1,350.8 

Utilization 

Concrete/Concrete Products/Grout 32.1 31.1 33.9 12.7 8.7 

Cement/Raw Feed for Clinker 2.7 2.2 -- -- -- 

All Other Uses 302.1 145.9 127.1 131.7 115.2 

Total Utilization 336.9 179.2 161.0 144.4 123.9 

 Percent Utilization 39.7% 13.7% 9.7% 11.2% 9.2% 

Source: ACAA, 2002, 2003, 2004, 2005, and 2006. 

2.2.4 Power Plant Bottom Ash 

Power plant bottom ash is the coarse, solid mineral residue that results from the burning of 

coal in utility boilers. The material is removed from the bottom of the boilers either in a wet 

or dry state and transported to handling areas by conveyor or pipe. Bottom ash has a similar 
2-17 

chemical composition to coal fly ash, but is produced in size grades ranging from fine sand to 

medium gravel. Although larger in particle size, bottom ash has a smaller reactive surface 

area than coal fly ash. Because of its much larger particle sizes, bottom ash has a smaller 

total reactive surface area, for the same weight, as coal fly ash. With this and other 

characteristics, bottom ash does not have sufficient cementitious properties to be used as a 

replacement for cement, although it can be used in clinker manufacture as an alternative 

source for silica, alumina, iron and calcium. 

Due to its salt content and, in some cases, its low pH, bottom ash also can exhibit corrosive 

properties (FHWA, 1998). As a result, the potential for corrosion of metal structures that 

come into contact with bottom ash should be evaluated when using this material in structural 

applications. 

In 2006, nearly 17 million metric tons of bottom ash were produced in the United States, 7.6 

million metric tons of which were beneficially used (ACAA, 2006). Table 2-11 summarizes 

bottom ash production and usage in clinker production and concrete for the years 2002 

through 2006 (ACAA, 2002, 2003, 2004, 2005, 2006). 

Table 2-11: Power Plant Bottom Ash Production and Utilization 

Year 

2002 2003 2004 2005 2006 

Production and Utilization --------------------million metric tons----------------------- 

Total Production 17.963 16.420 15.604 15.967 16.874 

Utilization 

Concrete/Concrete Products/Grout 0.369 0.271 0.716 0.926 0.542 

Cement/Raw Feed for Clinker* 0.531 

0.990a

0.448 

1.100a

0.558 

1.050a

0.852 

1.210a

0.840 

All Other Uses 6.076 6.763 6.122 5.064 6.219 

Total Utilization 6.976 7.482 7.396 6.842 7.601 

 Percent Utilization 38.8% 45.6% 47.4% 42.9% 45.0% 

*Bottom ash used only in clinker production. 

a USGS 2006. 

Source (unless noted): ACAA, 2002, 2003, 2004, 2005, and 2006. 

In contrast to the above data from ACAA, data from DOE EIA-767 indicate that 

approximately 20.4 million metric tons of bottom ash were produced at 410 facilities 

reported to produce bottom ash in 2004 (DOE 2004). 

Bottom ash can be used as a replacement for aggregate in concrete and is usually sufficiently 

well graded in size to avoid the need for blending with other fine aggregates to meet 

gradation requirements. The porous surface structure of bottom ash particles make this 

material less durable than conventional aggregates and better suited for use in base course 

and shoulder mixtures or in cold mix applications, as opposed to wearing surface mixtures. 

The porous surface structure also makes this material lighter than conventional aggregate and 

useful in lightweight concrete applications. Bottom ash also can be used as a raw material in 

clinker production as an alternative source of silica, alumina, iron, and calcium. 
2-18 

2.2.5 Power Plant Boiler Slag 

Boiler slag is a byproduct of the combustion of coal in power plants. It is produced in wetbottom boilers, which have a solid base with an orifice that can be opened to allow the 

molten ash that has collected at the base to flow into an ash hopper below. There are two 

types of wet-bottom boilers—slag-tap boilers and cyclone boilers. Slag-tap boilers burn 

pulverized coal (coal ground to a fine powder so that at least 70% passes through a 200-mesh 

sieve), while cyclone boilers burn crushed coal (coal milled to 0.25 inch maximum size) 

(Bolumen). In each of these types of boilers, the bottom ash is kept in a molten state and 

tapped off as a liquid. This molten slag is quenched with water, which causes it to fracture 

instantly, crystallize, and form pellets. The resulting power plant boiler slag, often referred 

to as “black beauty,” is a coarse, hard, black, angular, glassy material (FHWA, 1998). 

Owing to its abrasive properties, power plant boiler slag is used in the manufacture of 

blasting grit and roofing granules for asphalt shingles. However, smaller amounts of it also 

are used (or have been used) as an aggregate in concrete and as a raw feed for clinker 

production. In 2005, about 38,600 metric tons (approximately 2% of all power plant boiler 

slag used) were used as a raw feed in clinker production. 

Utilization of power plant boiler slag, as a percentage of production, is the highest among all 

coal combustion products. In 2006, nearly 84% of all power plant boiler slag was 

beneficially used (ACAA, 2006); down from a high of nearly 97% in 2005 (ACAA, 2005). 

Though power plant boiler slag is in high demand for beneficial use, its supplies are expected 

to decrease in the future due to the removal from service of the aging power plants that 

produce it. Table 2-12 summarizes U.S. production and usage of power plant boiler slag for 

the years 2002 through 2006 (ACAA, 2002, 2003, 2004, 2005, 2006). 

Table 2-12: Boiler Slag Production and Utilization 

Year 

2002 2003 2004 2005 2006 

Production and Utilization ------------------million metric tons---------------------- 

Total Production 1.741.4 1.6658 1.9979 1.7757 1.8380 

Utilization 

Concrete/Concrete Products/Grout 0.0082 0.0144 - - - 

Cement/Raw Feed for Clinker* - 0.0143 0.0304 0.0386 0.0161 

All Other Uses 1.3979 1.5643 1.7599 1.6767 1.5179 

Total Utilization 1.4061 1.5930 1.7903 1.7153 1.5340 

 Percent Utilization 80.7% 95.6% 89.6% 96.6% 83.46% 

* Boiler slag is used only in clinker production. 

Source: ACAA, 2002, 2003, 2004, 2005, and 2006. 

PCA (2005b) reported that 21 portland cement plants utilized power plant bottom ash and 

power plant boiler slag in the production of clinker in 2005 (no further breakout by material 

type was provided). Figure B-9 in Appendix B shows the locations of these plants. 
2-19 

2.2.6 Steel Furnace Slag 

Steel furnace slag, commonly referred to as steel slag, is a byproduct from either the 

conversion of iron to steel in a basic oxygen furnace (BOF) or the melting of scrap to make 

steel in an electric arc furnace (EAF). Similar to iron blast-furnace slag, steel slag is 

produced when slagging agents and/or fluxing materials are added to molten metals to 

remove impurities. Unlike iron blast furnaces, steel furnaces typically use lime as the 

slagging agent instead of limestone and /or dolomite. The liquid silicate slag floats on the 

molten metal and is separated and cooled. Steel slag is cooled in pools in a similar fashion as 

BFSA from iron blast furnaces. 

No reliable data exist on the amounts of steel slag produced annually in the United States 

because not all of the slag produced during steel production is tapped, and the amount of 

steel slag tapped is not routinely measured. Hendrik G. van Oss (2005) estimates, however, 

that steel slag production is between 10% and 15% of crude steel output. This estimate 

translates to 11 million to 16 million metric tons produced in 2004, of which nine million 

metric tons were sold for reuse (van Oss, 2004b). Table 2-13 summarizes steel slag 

production and usage for the years 2000 through 2005, as well as steel slag usage in cement 

and clinker manufacture (Kalyoncu, 2001; van Oss 2002, 2002b, 2003, 2003b, 2004, 2004b). 

In 2004, total U.S. steel slag sales were valued at about $39 million. Sales prices for steel 

slag ranged from $0.22 to $7.89 per metric ton, with an average of $4.32 per metric ton (van 

Oss 2004b). 

Table 2-13: U.S. Steel Slag Production and Usage 

Estimated Steel Slag 

Production 

Estimated Steel 

Slag Sales 

Steel Slag Usage in Cement and 

Clinker Manufacture 

Year --------------------------------million metric tons----------------------------------

2000 No Data 5.2 0.805 

2001 No Data 6.5 0.500 

2002 9-14 8.0 0.481 

2003 9-14 8.8 0.448 

2004 11-16 9.0 0.401 

2005 10-14 8.7 0.525 

Source: Kalyoncu, 2001; van Oss, 2002, 2002b, 2003, 2003b, 2004, and, 2004b. 

According to USGS, steel slag was processed at 99 locations in the United States in 2004. 

Some duplication in these locations exists, since steel slag producers can have contracts with 

multiple processors at the same location (van Oss, 2004b). Table 3 in Appendix C contains 

additional information on these locations. 

Steel slag has been successfully used as a raw material substitute in clinker manufacturing. 

The economic and environmental benefits of the utilization of steel furnace slag in Portland 

cement manufacturing may include energy savings, decreased CO2 and NOX emissions, and 

increased production capacity. 
2-20 

Because of its expansive characteristics, steel slag is not typically used as an aggregate in 

concrete for fixed-volume applications. Steel slag is useful as an aggregate in granular base 

applications,44 and can be processed into a coarse or fine aggregate material for use in hot 

mix asphalt concrete pavements and in cold mix or surface treatment applications. 

2.2.7 Cement Kiln Dust (CKD) 

CKD is the fine-grained, solid, highly alkaline material removed from the cement kiln 

exhaust gas by scrubbers (filtration baghouses and /or electrostatic precipitators). The 

composition of CKD varies among plants and over time at a single plant. Much of the 

material comprising CKD is actually incompletely reacted raw material, including a raw mix 

at various stages of burning, and particles of clinker. 

Because of the high percentage of raw mix and clinker in CKD, large amounts are put back 

into the production process through closed loop processes. CKD not returned to the 

production process is either landfilled or sold for other beneficial uses (PCA, 2006). 

Because of the high rate of direct reuse, CKD generation rates are not routinely measured, 

and limited data are available. One recent estimate, based upon informal conversations with 

U.S. cement kiln industry personnel, is that CKD generation (including material returned to 

the kiln) is equivalent to approximately 15% to 20% (by weight) of total annual clinker 

production. This amount translates into approximately 12 million to 15 million metric tons 

per year (van Oss, 2005). 

USGS domestic survey data show that in 2003, at least 289,000 metric tons of CKD captured 

by air emission control devices were used in clinker manufacture, and another 149,000 

metric tons were used in cement manufacture. In 2004, these amounts were at least 333,000 

metric tons in clinker manufacture and 165,000 metric tons in cement manufacture (van Oss, 

2004). As discussed by van Oss (2004), and based upon PCA data and discussions with 

industry personnel, these figures appear to grossly underreport the actual rate of reuse. As 

discussed previously, direct reuse of CKD in the manufacturing process is common, but 

largely unreported. 

Table 2-14 presents a breakdown of the amount and percent of the beneficially used CKD 

(and not returned to the kiln) by use in 2006 (PCA, 2006). Nearly half of the CKD 

beneficially used in 2006 was used for soil or clay stabilization. Approximately 16% was 

used as a cement additive or for blending. CKD in concrete mixes generally increases the 

water demand, decreases workability, retards setting time, and decreases concrete strength. 

Research into this use for CKD has suggested, however, that limited substitution of CKD for 

portland cement can create undiminished concrete mixes. Studies suggest that effective 

substitution rates range from as low as 5% to as much as 50% for certain concrete 

applications (EPA, 1993). Other beneficial uses for CKD include waste stabilization, mine 

reclamation, agricultural soil amendment, and in pavement manufacturing. 

 

44 This use must take into account volume expansion tendencies where the granular material is confined. 
2-21 

Table 2-14: Estimated Beneficial Uses of CKD Beneficially Reused, 2006 

Beneficial Use 

Quantity

(Metric Tons) 

Percent of CKD Total 

Beneficially Used 

(not returned to the kiln) 

Soil/Clay Stabilization 533,365 46% 

Waste Stabilization/Solidification 213,675 18% 

Mine Reclamation 152,756 13% 

Cement Additive/Blending 183,228 16% 

All Other Uses 76,987 7% 

Total 1,160,011 100% 

Source: Portland Cement Association. Summary of 2006 Cement Kiln Dust and Clinker Production, CKD Beneficially Reused. 

Note: CKD recycled into the kiln is under a closed loop process, not removed from the kiln system, and is not considered a 

beneficial reuse for purposes of this document.

 

2.3 Summary of RMC Generation and Beneficial Use

The RMCs examined in the study vary widely in terms of their generation and beneficial use 

rates. Table 2-15 summarizes total generation and beneficial use (all uses) of the RMCs in 

2004. By quantity, the most significant materials beneficially used are coal fly ash, BFSA, 

and flue gas desulfurization (FGD) gypsum. Several materials – including GGBFS, BFSA, 

power plant boiler slag, and steel furnace slag from electric arc furnace facilities– have 

beneficial use rates at or near 100%. Table 2-15 provides summary information on the 

generation and beneficial use for the RMCs addressed in this Report. 
2-22 

Table 2-15: Summary of RMC Generation and Beneficial Use (2004) 

Material 

Estimated Annual 

Quantity Generated, 2004 

(million metric tons) 

Estimated Quantity 

Beneficially Used, 2004 

(million metric tons) 

Percent 

Beneficially 

Used 

 (all uses) 

Beneficial 

Use Rate in 

Cement or 

Concrete 

RMCs Named by Congress 

Ground Granulated Blastfurnace Slag (excluding 

lead slag) 

3.60 3.60 100% High 

Coal Combustion Fly Ash 64.20 25.50 40% Moderate 

Blast-furnace Slag 

Aggregate (excluding lead 

slag) 

8.10 8.10* 100% Moderate 

Silica Fume 0.10 – 0.12 0.08 67%-80% Moderate 

Other RMCs Identified by EPA 

Foundry Sand 8.5 2.40 28% Low 

Cenospheres N.A. 

0.0052 

(reported sales) N.A. Moderate 

Flue Gas Desulfurization 

(FGD) Gypsum 10.80 8.20 76% Low 

Flue Gas Desulfurization 

(FGD) Dry Scrubber 

Material

1.70 0.16 9% Low 

Power Plant Bottom Ash 15.60 7.40 47% Low 

Power Plant Boiler Slag 2.00 1.80 90% Low 

Steel Furnace Slag ** 9.00 9.00 100% Low 

Cement Kiln Dust (CKD) 12.00 – 15.00 1.20 

(excludes reuse back into kiln N.A. Low 

Note: Data sources and caveats discussed in detail in section 1, and earlier in this section. 

* Recently received information indicates that BFSA may be used at around 85% (Kiggins, 2007). However, this is 

based on a single data point. 

** Includes both EAF and BOF steel furnace slag. BOF steel furnace slag may be used at less than 100% (Lehman, 

Rich. October 3, 2007)
3-1

3.0 ENERGY AND ENVIRONMENTAL BENEFITS OF RMC USE IN FEDERAL 

CONCRETE PROJECTS

3.1 Introduction

This section further addresses Part (A) of the Congressional mandate, which also requires EPA 

to quantify the energy savings and environmental benefits associated with the substitution of 

RMCs for portland cement. Specifically, we address three of the four RMCs identified by 

Congress for further study: coal fly ash, GGBFS, and silica fume.45 The analysis provides 

quantified estimates of energy savings and environmental benefits resulting from the substitution 

of these mineral components for finished portland cement in Federal construction projects 

involving concrete. RMCs can be used to offset virgin materials at more than one point in the 

cement production process. It is important to note that we are modeling the use of RMCs as a 

direct replacement for finished portland cement in concrete; this analysis does not evaluate the 

use of RMCs in clinker production due to current modeling limitations. The metrics used to 

describe impacts include resource savings (e.g., energy and water consumption), avoided air 

pollutant emissions, various measures of avoided GHG emissions, avoided water emissions, 

avoided soil emissions, and avoided end of life waste. 

This section begins with a brief overview of the analytical approach and model used to respond 

to the Congressional mandate. We then describe the methodology used to develop estimates of 

the quantities of coal fly ash, GGBFS, and silica fume substituted for finished portland cement in 

Federal projects. We then present unit impact values related to the substitution of one metric ton 

of each RMC for finished portland cement in concrete. Finally, we present aggregated impact 

results for historical Federal RMC use quantities (years 2004 and 2005), and project RMC use 

quantities (years 2004 to 2015). Appendix D provides detailed results of the analysis, along with 

a technical discussion of the modeling inputs and calculations. 

3.2 Analytical Approach and Model 

Our methodology for evaluating the benefits associated with RMC use in Federal concrete 

applications first involves selecting an appropriate life cycle modeling tool to address a range of 

RMCs and impacts. We then use the model to implement a three-step analytic approach: 

 

1) development of RMC substitution scenarios; 

2) use of life-cycle inventory data to estimate environmental impacts associated with 

the substitution of one unit (metric ton) of RMC; and 

3) calculation of the environmental impact profile for the total quantities of 

substituted RMCs. 

We use a life-cycle analysis (LCA) approach to estimate the environmental benefits of 

substituting RMCs for finished portland cement. LCA allows estimation of a range of 

 

45 BFSA, a material identified by Congress, is a source of aggregate in concrete and does not act as an SCM or 

substitute for portland cement. We focus this assessment on the benefits of substitution of portland cement. 

However, an illustration of the types and magnitude of benefits that can be achieved by using BFSA as a substitute 

for virgin aggregate in concrete, or as roadbase, can be found in Appendix D. 
3-2

environmental impacts of a product across all stages in the product’s life, from resource and raw 

material extraction through disposal. By comparing the impacts across different beneficial use 

scenarios in which portland cement is being replaced, it is possible to provide an estimate of the 

impacts associated with increases in the beneficial use of RMCs. 

The analysis relies primarily on data derived from the Building for Environmental and Economic 

Sustainability (BEES) model. We employ the BEES model because it can be used to evaluate 

three of the RMCs identified by Congress (coal fly ash, GGBFS, and silica fume), providing a 

consistent modeling platform and set of results across the RMCs. Our comprehensive review of 

existing LCA models identified a number of other models that address individual RMCs, 

including the Waste Reduction Model (WARM) and the Pavement Life-Cycle Assessment Tool 

for Environmental and Economic Effects (PaLATE). Two key differences between WARM and 

BEES led us to select BEES for the benefits analysis in this study. First, WARM evaluates only 

lifecycle energy and GHG impacts in its outputs, while BEES evaluates energy, GHG, and 

several other environmental impacts, such as water use and pollutant emissions to air and water. 

In addition, the WARM model addresses only one RMC used in concrete - coal fly ash. 

PaLATE is another life cycle analysis tool useful for modeling energy and environmental 

impacts. However, at the time of this analysis, the PaLATE model had not been formerly peer 

reviewed under Agency guidelines. Furthermore, as with WARM, PaLATE does not allow for 

the consistency and comparability across all three RMCs46. Because these models use different 

data and methodologies to calculate the impacts of RMC substitution, we opted to use BEES to 

evaluate coal fly ash, GGBFS, and silica fume to assure consistency and comparability across the 

RMCs analyzed.47

It is important to emphasize the purpose and limitations of the application of life cycle modeling 

in this context. Our approach is to generally characterize the potential suite of environmental 

impacts related to reuse of certain materials, and to illustrate the potential magnitude of these 

impacts. As noted, we rely primarily on the BEES model (version 3.0) to generate this 

illustration, and then use the WARM model to corroborate the results for coal fly ash. The life 

cycle inventories of material and resource use embedded in these models are representative of 

productive processes in place at a given point in time. As these processes evolve, the existing 

life cycle inventories may become less representative and require updating.48 As a result, the 

long-range projections of materials reuse and related impacts based upon current life cycle 

inventories should be considered with due care and in the appropriate context. For example, the 

 

46 Understanding the material use, modeling, and comparative limitations, we applied the PaLATE model in an 

effort to estimate the potential types and magnitude of benefits that can be achieved by using BFSA as a substitute 

for virgin aggregate in concrete, or as roadbase. This analysis can be found in Appendix D 47 Appendix D of this report includes a comparison of BEES and WARM results for energy and GHG impacts when 

coal fly ash is used in concrete. This comparison indicates that BEES and WARM result in roughly comparable 

energy and GHG impacts per metric ton of coal fly ash used as an SCM in concrete. We did apply the PaLATE 

model in an effort to estimate the potential types and magnitude of benefits that can be achieved by using BFSA as a 

substitute for virgin aggregate in concrete, or as roadbase. This analysis can be found in Appendix D 

48 For example, NIST recently released BEES version 4.0 subsequent to the completion of the analysis presented in 

this chapter. BEES version 4.0 utilizes updated life cycle inventories that differ in certain respects from version 3.0. 

These differences, however, do not yield material changes in the relative magnitude of impacts for the RMCs 

evaluated. 

 
3-3

primary focus should be on the categories of impacts and their direction (i.e., positive versus 

negative impacts), as opposed to the absolute magnitude of impacts, which may change over 

time. 

As noted previously, our analysis quantifies the benefits only for coal fly ash, silica fume, and 

GGBFS use in concrete, and further limits consideration to those benefits associated with the use 

of these RMCs as a replacement for portland cement in concrete as an SCM, and not an input 

into the clinker or cement manufacturing process. This analysis does not consider the use of 

other RMCs (e.g., BFSA, foundry sand, FGD gypsum, bottom ash, and power plant boiler slag) 

because current data and modeling capabilities do not allow the Agency to conduct a detailed 

analysis of these other RMCs. Finally, we are unable to extrapolate the impacts calculated for 

coal fly ash, GGBFs, and silica fume to these other RMCs because the impacts modeled for 

portland cement replacement are not representative of the processes required to use these 

materials in cement and concrete applications.49 

Nevertheless, the analysis provides an estimate of a portion of the benefits associated with 

certain RMCs, and also reflects a transparent and readily accepted approach for estimating 

potential benefits. 

3.3 Current and Expanded Use Scenarios 

To evaluate the environmental benefits of using RMCs in concrete, both at current use levels and 

under Federal initiatives to increase beneficial use rates, EPA first developed projections of 

future RMC use through 2015 under a variety of scenarios. The current use scenarios reflect 

RMC use under existing conditions and initiatives. The expanded use scenarios assume 

implementation of Federal initiatives to increase beneficial use rates. We then apply the 

environmental unit impact measures to these estimates to quantify the potential environmental 

benefits of historical and future RMC substitution. 

Our analysis uses 2004 as a base year for projections because 2004 is the most recent year for 

which use data are available for the three RMCs evaluated. The benefits of RMC use in Federal 

concrete projects are assessed for both historical (years 2004 and 2005) and projected (years 

2006 to 2015) substitution levels.50 We discuss these scenarios in further detail below. 

3.3.1 Current Use Practices 

To implement the analysis, we first estimate the proportion of portland cement and RMCs used 

in Federal concrete projects. Specifically, to estimate the proportion of RMCs used in all 

Federally funded concrete projects, we use an FHWA estimate that approximately 20% of U.S. 

 

49 To the extent that these materials offset extraction and processing of virgin materials, however, there are likely to 

be positive environmental life cycle impacts associated with their use in cement or concrete. At a minimum, the 

environmental benefits associated with the use of other RMCs are likely to be consistent with the energy savings and 

reduced impacts associated with avoiding the production of an equal quantity of virgin material. 

50 2006 is not considered a “historical year” in this analysis because at the time of this analysis, 2006 use data were 

not available for all three RMCs being evaluated. Thus, it was necessary to develop projections of RMC use 

beginning in 2006. 
3-4

concrete construction projects involve Federal funds.51 Therefore, in this analysis, we assume: 

(1) that Federal projects are using RMC at the same “rate” as the national average, and (2) that 

the Federal projects incorporate 20% of RMCs used as a substitute for finished portland cement 

in concrete. Appendix D presents a detailed discussion of how this estimate was derived. 

We then use available data from industry and government sources on historical and future 

portland cement demand to develop the following approaches: 

• Future GGBFS Use: We assume that annual demand for GGBFS will increase 

proportionate to the overall U.S. demand for portland cement. PCA estimates that 

U.S. portland cement demand will be 195 million metric tons in 2030 (PCA, 

2006a). For this analysis, we assume that demand for portland cement will 

increase linearly to the PCA estimated rate by 2030, or approximately 2.2% per 

year beyond 2005 (the last year for which actual portland cement use data are 

available). We apply the 2.2% growth rate to the base year (2004) quantity of 

GGBFS used in U.S. concrete projects (3.46 million metric tons), which equals an 

annual increase of approximately 76,000 metric tons. While this approach does 

not attempt to address a number of industry-specific uncertainties related to 

GGBFS supply, it is generally consistent with the estimates of potential GGBFS 

production and sales provided by the USGS. Future GGBFS use, depends on a 

number of factors, including import patterns and demand for GGBFS relative to 

demand for BFSA and GBFS (GGBFS, GBFS and BFSA are all made from the 

same supply of iron slag). The SCA projects higher GGBFS use based on an 

assumed increase in imports and a significant investment in grinding equipment.52

For the purposes of this report, however, we use more conservative projections 

based on U.S. portland cement demand that do not assume a market shift. These 

projections comport with a USGS estimate that a maximum of six million metric 

tons of GGBFS could be available in the U.S. in the next 10 to 20 years through 

combined imports and domestic production.53 

• Future Silica Fume Use: We assume that domestic silica fume supply is 

inelastic, as a result of relatively inelastic global supply of silicon metal and 

ferrosilicon and related ferroalloys production. Therefore, we assume that current 

(i.e., base year) rates of silica fume use in U.S. concrete projects will remain 

constant into the future (i.e., roughly 60,000 metric tons per year).54

• Future Coal Fly Ash Use: We employ a different approach to estimate future 

use of coal fly ash because current government and industry initiatives are 

designed to increase beneficial use rates. Specifically, using selected 

mechanisms, as outlined in Chapter 5, the C2

P2 program has an aggressive goal of 

 

51 Personal communication with Jon Mullarky, FHWA, July 17, 2007. 

52 Personal communication with Jan Prusinski, Slag Cement Association, June 6, 2007. 

53 Personal communication with Hendrik van Oss, USGS, July 12, 2007. 

54 Personal communication with Hendrik van Oss, USGS, July 12, 2007, and analysis of data from USGS 2005

Minerals Yearbook – Ferroalloys, accessed at: 

http://minerals.usgs.gov/minerals/pubs/commodity/ferroalloys/feallmyb05.pdf. 
3-5

increasing coal fly ash use in portland cement to 18.6 million short tons (16.9 

million metric tons) by 2011.55 We therefore use constant progress toward this 

goal to estimate coal fly ash use for the years 2005 through 2011. For the years 

2012 through 2015, we then estimate that coal fly ash use under C2

P2 will 

increase at the same rate as U.S. portland cement demand over 2004 levels (2.2%, 

or approximately 333,000 metric tons per year).56 In order to estimate coal fly ash 

use in the absence of C2

P2, we also employ a current use scenario in which we 

assume that the use of coal fly ash as a partial portland cement replacement will 

increase linearly for the years 2005 to 2011 at the same rate as U.S. cement 

demand. This scenario recognizes that meeting the C2

P2 goals is dependent upon 

overcoming a number of the barriers, as identified in Chapter 4. 

3.3.2 Expanded Use Scenarios 

In addition to the current use estimates, we also developed expanded use estimates for coal fly 

ash as an SCM in concrete to capture incremental changes in use from current levels. These 

scenarios are designed to provide insight into the specific impacts of ongoing and emerging 

efforts by EPA and other Federal agencies and stakeholders to increase the beneficial use of coal 

fly ash. We limit our evaluation of an expanded use scenario to coal fly ash because, unlike 

GGBFS and silica fume, coal fly ash is currently underutilized (with respect to supply 

availability) and therefore has the capacity for expanded use if barriers to its increased use are 

removed.57 

We employ two expanded use scenarios to estimate the potential impacts and benefits due to 

initiatives to increase the use of coal fly ash. Under the first expanded use scenario (the “15 

percent scenario”), coal fly ash substitution in Federal projects is assumed to increase from the 

current use rates (approximately 10%) to the 15% level recommended under the CPG program. 

Under the second alternative use scenario (the “30% scenario”), coal fly ash substitution for 

portland cement in Federal projects (i.e., 20% of total U.S. estimates) is assumed to increase 

from the current use rates to the maximum levels recommended under the CPG program (i.e., 

30%). 58, 59 For non-Federal projects, our scenarios assume that RMC use would be the same as 

under the current use analysis. For both scenarios, we assume that the increase in use will be 

linear starting in the year 2009 and continuing through the year 2015.60 Tables 3-1 and 3-2 

present the current and future use estimates (incorporating the 20% adjustment factor) for coal 

 

55 See www.epa.gov/epaoswer/osw/conserve/c2p2/pubs/facts508.pdf. 56 Comments and information from Hendrik van Oss of the USGS suggest that developing any trend in future coal 

fly ash beneficial use is subject to significant uncertainty. We therefore use EPA goals and cement industry 

projections as a likely high-end estimate of potential growth. 

57 Close to 100% of GGBFS and silica fume currently generated in the U.S. is believed to be beneficially used. 58 Note that an increase to 15% coal fly ash substitution represents an optimistic Agency goal. Therefore, the 30% 

scenario represents a possible, though unlikely, maximum target for increased substitution. The results of the 30% 

scenario should be taken as an upper bound estimate of possible environmental benefits. 

59 Both the 15% and 30% scenarios assume full attainment of the CPG recommended beneficial use levels, but do 

not necessarily reflect current barriers to the expanded use of coal fly ash. Additionally, the C2

P2 scenario is an 

expanded use scenario using the goals set forth under the program. Therefore, the volumes beneficially used in these 

scenarios are optimistic Agency goals. 

60 SAFETEA-LU instructs all agency heads to implement recommendations of the 30 month study with regard to 

procurement guidelines no later than one year after the release of the study, or approximately early to mid 2009. 
3-6

fly ash, GGBFS, silica fume, and total portland cement (including both “virgin” portland and 

blended cements), as well as the expanded use estimates for coal fly ash. 

Table 3-1: U.S. Portland Cement Demand and RMC Use in Cement and Concrete 

Products, Under Current and Expanded Use Scenarios 

 Cement Coal Fly Ash GGBFS Silica Fume 

All All 

Total U.S. Demand 

Current Use 

Baseline 

Current Use 

C2

P2

15% 

Scenario 

30% 

Scenario Scenarios Scenarios 

Year -----------------------------------------million metric tons------------------------------------------------

2004 122.0 12.8 12.8 12.8 12.8 3.5 0.06 

2005 125.7 13.6 13.6 13.6 13.6 3.5 0.06 

2006 128.5 13.9 14.2 14.2 14.2 3.6 0.06 

2007 131.2 14.2 14.8 14.8 14.8 3.7 0.06 

2008 134.0 14.5 15.4 15.4 15.4 3.8 0.06 

2009 136.8 14.8 15.9 16.3 17.7 3.8 0.06 

2010 139.6 15.1 16.4 17.2 20.0 3.9 0.06 

2011 142.3 15.4 16.9 18.1 22.3 4.0 0.06 

2012 145.1 15.7 17.2 18.9 24.6 4.1 0.06 

2013 147.9 16 17.5 19.8 27.0 4.1 0.06 

2014 150.6 16.3 17.9 20.6 29.5 4.2 0.06 

2015 153.4 16.6 18.2 21.5 32.0 4.3 0.06 

Notes: 

(a) These figures include both Federal and non-Federal projects. For purposes of this analysis, we assume that Federal 

projects represent approximately 20% of the total quantities; non-Federal projects make-up the remaining 80%. 

(b) The C2

P2, 15%, and 30% scenarios represent aggressive policy goals. 
3-7

Table 3-2: Federal Portland Cement and RMC Use Under Current and Expanded Use 

Scenarios 

 Cement Coal Fly Ash GGBFS Silica Fume 

All All 

Federal Demand 

Current Use 

Baseline 

Current Use 

C2

P2

15% 

Scenario 

30% 

Scenario Scenarios Scenarios 

Year -----------------------------------------million metric tons------------------------------------------------

2004 24.4 2.6 2.6 2.6 2.6 0.7 0.01 

2005 25.1 2.7 2.7 2.7 2.7 0.7 0.01 

2006 25.7 2.8 2.8 2.8 2.8 0.7 0.01 

2007 26.2 2.8 3.0 3.0 3.0 0.7 0.01 

2008 26.8 2.9 3.1 3.1 3.1 0.8 0.01 

2009 27.4 3.0 3.2 3.4 4.1 0.8 0.01 

2010 27.9 3.0 3.3 3.7 5.1 0.8 0.01 

2011 28.5 3.1 3.4 4.0 6.1 0.8 0.01 

2012 29.0 3.1 3.4 4.3 7.2 0.8 0.01 

2013 29.6 3.2 3.5 4.6 8.3 0.8 0.01 

2014 30.1 3.3 3.6 4.9 9.4 0.8 0.01 

2015 30.7 3.3 3.6 5.3 10.6 0.9 0.01 

Notes:

These figures reflect Federal projects only. 

GGBFS and silica fume data equal 20% of the USA totals. 

3.4 RMC Unit Impact Savings 

RMC unit impacts represent the energy and environmental effects of using one unit of coal fly 

ash, GGBFS, or silica fume in place of an equivalent unit of finished portland cement in a 

specified concrete application.61 The unit impact values for each RMC provide a basis for 

converting Federal RMC use quantities in Table 3-2 into measures of environmental benefits. 

Table 3-3 presents the unit impact values applied in our model. These values are derived from 

BEES life cycle inventory data and represent the total life cycle savings of using RMCs as a 

replacement for one metric ton of finished portland cement in concrete.62 

 

61 Silica fume does not replace portland cement in a 1:1 ratio (as is the case with coal fly ash and GGBFS). The 

addition of silica fume to concrete has a synergistic effect on compressive strength, making the replacement ratio 

complex. For simplicity, however, BEES assumes a 1:1 replacement ratio for silica fume and portland cement in 

concrete when modeling life cycle impacts. This is likely to over state the benefits of using this material as an SCM. 62 See Appendix D for the detailed calculations of the RMC unit impact values. 
3-8

Table 3-3: Life Cycle Impacts per Metric Ton of RMC Substituted for Finished Portland 

Cement in Concrete 

-----------------------Material --------------------- 

Metric Coal Fly Asha

 GGBFS Silica Fumeb

Energy Savings (megajoules) 4,695.9 4,220.9 32,915.0

Energy Savings (US $) 129.1 116.1 905.2

Water Savings (Liter) 376.3 145.2 -5,111.4

Water Savings (US $) 0.2 0.1 -3.2

Avoided CO2 Equivalent (GHG) (grams)c 718,000.0 Not calculatede

Avoided CO2 Emissions (grams) 701,377.7 668,889.1 699,923.3

Avoided CF4 Emissions(grams) 0.0

Avoided CH4 Emissions (grams) 594.8

Avoided N2O Emissions (grams) 13.2

Passenger cars not driven for one yeard 0.2

Passenger cars and light trucks not driven for one yeard 0.1

Avoided gasoline consumption (liters)d 310.0

Avoided oil consumption (barrels) b 1.7

Not calculatede

Avoided NOx Emissions (grams) 2,130.2 2,014.8 28,442.2

Avoided PM10 Emissions (grams) 0.0 0.0 -0.1

Avoided SOx Emission (grams) 1,673.9 1,605.8 42,560.1

Avoided CO Emissions (grams) 654.3 621.5 2,278.2

Avoided Hg Emissions (grams) 0.0 0.0 -0.3

Avoided Pb Emissions (grams) 0.0 0.0 0.6

Avoided biochemical oxygen demand in water (grams) 3.4 -0.8 -21.0

Avoided chemical oxygen demand in water (grams) 28.7 -6.5 -201.4

Avoided copper water emissions (grams) 0.0 0.0 0.0

Avoided suspended matter in water (grams) 15.4 -3.5 -55.1

Avoided emissions to soil (grams) 0.0 0.0 0.0

Avoided end of life waste (kilograms) 0.0 0.0 0.0

Notes: 

a. Impact metrics based upon representative concrete products. 

b. Negative values represent an incremental increase in impacts relative to the use of portland cement. 

c. Avoided CO2 equivalent is an expression of the cumulative global warming potential of all four greenhouse 

gasses for which BEES data were available (CO2, CF4, CH4, and N20). It can be calculated from the global warming 

potentials of individual greenhouse gasses, using the global warming potential of C02 as the reference point. 

Avoided CO2 equivalent was calculated using the Greenhouse Gas Equivalencies Calculator developed by the U.S. 

Climate Technology Cooperation (accessed at: http://www.usctcgateway.net/tool/). 

d. The greenhouse gas metrics taken from BEES were converted to equivalent impacts such as passenger cars 

removed from the road for one year, passenger cars and light trucks removed from the road for one year, avoided 

gasoline consumption, and avoided oil consumption, using the Greenhouse Gas Equivalencies Calculator. It is 

important to note that these metrics are equivalent expressions of the avoided greenhouse gas metrics reported by 

BEES; they do not represent additional benefits. 

e. GHG equivalency metrics were not calculated for GGBFS and silica fume, due primarily to the fact that use of 

these materials is unlikely to change significantly across scenarios. 
3-9

As shown in Table 3-3, use of one metric ton of RMC in place of one metric ton of finished 

portland cement results in a range of environmental benefits. For example, substituting one 

metric ton of coal fly ash results in 0.72 metric tons of avoided CO2 equivalent emissions, of 

which 0.70 metric tons is avoided CO2. In comparison, use of one metric ton GGBFS results in 

0.67 metric tons of avoided CO2 emissions. 

For all metrics, the energy and environmental benefits of using GGBFS in concrete are less than 

the benefits of using coal fly ash in concrete. GGBFS generally is produced by quenching molten 

slag with water and then grinding the cooled material to a fine cement-like consistency. The 

resource use and air emissions associated with the mechanical processing of GGBFS offset some 

of the environmental benefits from the avoided production of portland cement. In contrast, coal 

fly ash generally does not require grinding prior to its beneficial use in concrete and is therefore 

modeled as an environmentally “neutral” input to concrete production.63 Thus, the benefits of 

coal fly ash substitution directly represent the environmental benefits associated with avoiding 

the production of one metric ton of portland cement.

It is important to note that the unit impact values for silica fume are not directly comparable to 

the unit impact values for coal fly ash and GGBFS. Silica fume is not generally used as a direct, 

complete substitute for finished portland cement, but is instead a partial supplement that offsets 

some portland cement use, and also increases the strength and reduces the water permeability of 

concrete.64 Substitution of silica fume in concrete can yield both positive and negative 

environmental impacts. For example, its use as a partial substitute can lower energy 

consumption and carbon dioxide emissions relative to mixes with 100% portland cement. The 

most significant negative impact is increased water use when silica fume is used as a partial 

substitute in place of portland cement in concrete. As described in Appendix B of this report, the 

high surface area of silica fume increases water demand in concrete. 

3.5 Historical Energy and Environmental Impacts of RMC Beneficial Use 

To estimate energy and environmental benefits attributable to substitution of RMCs for portland 

cement in Federal concrete projects, we multiply the unit impact values identified in Table 3-3 

by the Federal RMC use quantities for 2004 and 2005 (presented in Table 3-2). As previously 

discussed, our historical impacts include both 2004 and 2005, while projections cover 2006 

through 2015. 

We summarize the historical energy and impact estimates briefly in the bullets below, with more 

detailed results presented in Table 3-4. 

• Coal Fly Ash: Federal concrete projects used an estimated 5.3 million metric 

tons of coal fly ash in 2004 and 2005 combined. This substitution yields a 

number of environmental benefits, including avoided energy use of approximately 

 

63Coal fly ash does require some quality control prior to use in concrete. Separation and beneficiation are widely 

practiced in the industry, but the energy impacts of these processes do not appear to be as clear or significant as the 

grinding required for GGBFS. As a result, many life cycle models, including BEES, do not attribute processing 

energy to coal fly ash. 

64 For a further explanation of the limitations of the unit impact estimates for silica fume, see Appendix D. 
3-10

25 billion megajoules; avoided water consumption of two billion liters; and 

avoided carbon dioxide equivalent emissions of 3.8 million metric tons. 

Energy and water savings represent two significant impacts that can be monetized 

using market prices. Results indicate that the beneficial use of coal fly ash in 

2004 and 2005 resulted in energy savings valued at approximately $0.7 billion, 

and water savings valued at approximately $1.2 million. 

• GGBFS: An estimated 1.4 million metric tons of GGBFS were used in Federal 

concrete projects in 2004 and 2005 combined. This substitution yields a suite of 

positive and negative environmental impacts, including avoided energy use of 

approximately six billion megajoules; avoided water consumption of 

approximately 0.2 billion liters; and avoided carbon dioxide emissions of 

approximately one million metric tons. The negative benefits include increased 

chemical oxygen demand and increased suspended matter in water discharges. 

• Silica Fume: The impact estimates for silica fume result from an estimated use of 

24,000 tons in 2004 and 2005. Consistent with the unit impact measures, silica 

fume substitution results in both positive and negative impacts, including avoided 

energy use of approximately one billion megajoules, increased water consumption 

of 0.1 billion liters, and positive and negative impacts across the various air 

emissions metrics. 
3-11

Table 3-4: Historical Impacts of Using Coal Fly Ash, GGBFS, and Silica Fume in Federal 

Concrete Projects (2004 plus 2005) 

COAL FLY 

ASH GGBFS SILICA FUME 

Beneficial Use Quantity (metric tons, 2004 plus 2005) 

5,282,000 1,399,000 24,000 

Environmental Metric Historical Energy and Environmental Impacts 

billion megajoules 24.8 5.9 0.8 

Energy Savings billion ($ 2006) 0.7 0.2 0.0 

billion ($ discounted @ 7%) 0.7 0.2 0.0 

billion liters 2.0 0.2 -0.1 

Water Savings million ($ 2006) 1.2 0.1 -0.1 

million ($ discounted @7%) 1.2 0.1 -0.1 

Avoided CO2 Equivalent (air) million metric tons 3.8 Not calculatedb

 Avoided CO2 million metric tons 3.7 0.9 0.0 

 Avoided CF4 metric tons 0.0 

 Avoided CH4 thousand metric tons 3.1 

 Avoided N2O metric tons 69.7 

Passenger cars not driven for one year million passenger cars 0.8 

Passenger cars and light trucks not 

driven for one year 

million passenger cars and light 

trucks 0.7 

Avoided gasoline consumption billion liters 1.6 

Avoided oil consumption billion barrels 0.0 

Not calculatedb

Avoided NOx (air) thousand metric tons 11.3 2.8 0.7 

Avoided PM10 (air) metric tons 0.1 0.0 0.0 

Avoided SOx (air) thousand metric tons 8.8 2.2 1.0 

Avoided CO (air) thousand metric tons 3.5 0.9 0.1 

Avoided Hg (air) metric tons 0.2 0.1 0.0 

Avoided Pb (air) metric tons 0.2 0.0 0.0 

Avoided biochemical oxygen demand 

(water) metric tons 17.9 -1.1 -0.5 

Avoided chemical oxygen demand 

(water) metric tons 151.4 -9.1 -4.8 

Avoided copper (water) metric tons 0.0 0.0 0.0 

Avoided suspended matter (water) metric tons 81.3 -4.9 -1.3 

Avoided soil emissions metric tons 0.0 0.0 0.0 

Avoided end of life waste metric tons 0.0 0.0 0.0 

Notes:

a. BEES reports CO separate from CO2 emissions, but it is important to note that the Intergovernmental Panel on 

 Climate Change (IPCC) considers CO emitted from portland cement manufacture a precursor to CO2. 

b. GHG equivalency metrics were not calculated for GGBFS and silica fume is part due to the fact that use of these 

 materials is unlikely to change significantly across scenarios. 
3-12

As shown in Table 3-4, the environmental benefits associated with the historical use of coal fly 

ash are significantly larger than the benefits associated with the historical use of GGBFS. These 

differences are a function of both the historical quantities of each RMC used in Federal concrete 

projects and the unit impacts for the use of one ton of each RMC in concrete. Specifically, 

greater quantities of coal fly ash have been used historically than GGBFS, and the unit impacts 

calculated for coal fly ash are higher than those of GGBFS. 

While avoided releases of different substances, and savings in energy and water use are generally 

additive, a full assessment of the economic benefits would require identifying the specific 

receptors (i.e., populations and water bodies) whose quality has been improved. Moreover, 

certain GHG equivalent metrics such as "avoided oil consumption" and cars removed from the 

road represent different ways of describing the same impact (i.e., avoided greenhouse gas 

emissions), and are not additive. 

3.6 Projected Energy and Environmental Impacts of RMC Beneficial Use 

In addition to assessing the historical benefits of the use of RMCs, this analysis also considers 

how the benefits may accrue over time under projected use scenarios. As described above, for 

each RMC analyzed, we developed projections, through the year 2015, of potential substitution 

levels based upon current use, forecasted supply, and potential demand of each RMC, as well as 

estimates based on alternative procurement goals. The projected annual substitution levels (in 

metric tons) are then multiplied by the unit impact values (i.e., impacts per metric ton of RMC) 

to derive projected environmental benefits. 

Table 3-5 below presents aggregate benefits and impacts summed across the years 2004 to 2015 

under the four beneficial use scenarios developed in this analysis (i.e. the baseline scenario, the 

C2

P2 goals scenario, the 15% expanded use scenario for coal fly ash, and the 30% expanded use 

scenario for coal fly ash). The results are presented in aggregate for the years 2004 to 2015 to 

show the total magnitude of possible impacts during the period of analysis. The results illustrate 

the incremental gains achieved by moving to higher levels of coal fly ash use. Appendix D 

presents these findings in more detail. 

As in the historical scenario, energy and water savings represent two major impacts, and 

illustrate the differences between the various scenarios. Results indicate that use of the analyzed 

RMCs (coal fly ash, GGBFS, and silica fume) in concrete from 2004 through 2015 may result in 

energy savings valued at nearly $6 billion (2006 dollars) under baseline conditions. Achieving 

the 15% substitution rate (coal fly ash for Portland cement) for coal fly ash would increase the 

value of energy savings to nearly $7 billion, and achieving a 30% substitution rate would 

increase benefits to an estimated $9.6 billion for the three RMCs. Water savings results for the 

three RMCs reflect a similar pattern, showing a 30% substitution rate for coal fly ash would save 

approximately 25 billion litres, compared with a 14.1 billion litre savings under baseline 

assumptions. 
3-13

Figures 3-1 through 3-3 below present graphic representations of the trends for selected energy 

and environmental metrics for all coal fly ash and GGBFS use scenarios.65 Consistent with the 

Congressional requirement, the metrics selected - energy savings, carbon dioxide emissions, and 

water use impacts, represent the largest environmental benefits associated with use of the RMCs 

in concrete. 

 

65 We do not present trend results for silica fume in these tables due to the higher degree of uncertainty associated 

with the silica fume analysis. 
3-14

Table 3-5: Total Projected Impacts of Using Coal Fly Ash, GGBFS, and Silica Fume in 

Federal Concrete Projects Under Current and Expanded Rate Use Scenarios for Years 

2004 – 2015 (Footnotes on next page) 

Metric Units 

Current Use Baseline 

Scenarioa

Current Use C2

P2 

Scenariob

Incremental Impactsc

(Current Use C2

P2 minus 

Current Use Baseline )

Expanded Use 15% 

Substitution Scenariod

Incremental Impactse

(15% Scenario minus 

Baseline Scenario)

Incremental Impactsf

(15% Scenario minus 

Current Use C2

P2

)

Expanded Use 30% 

Substitution Scenariog

Incremental Impactsh

(30% Scenario minus 

Baseline Scenario)

Incremental Impactsi

(30% Scenario minus 

Current Use C2

P2

)

Incremental Impactsj

(30% Scenario minus 

15% Scenario)

billion megajoules 212.1 223.2 11.2 252.5 40.4 29.3 348 135.9 124.8 95.5

billion ($ 2006) 5.8 6.1 0.3 6.9 1.1 0.8 9.6 3.8 3.4 2.6

Energy Savings 

billion ($ discounted @ 

7%) 4.5 4.7 0.2 5.2 0.7 0.5 6.8 2.3 2.1 1.6

billion liters 14.1 15 0.9 17.3 3.2 2.3 25 10.9 10 7.7

million ($ 2006) 8.7 9.3 0.6 10.7 2 1.4 15.4 6.7 6.2 4.7

Water Savings 

million ($ discounted @ 

7%) 6.7 7.1 0.4 7.9 1.2 0.9 10.8 4.1 3.7 2.9

Avoided CO2

Equivalent (air)k

 million metric tons 25.7 27.4 1.7 31.9 6.2 4.5 46.5 20.8 19.1 14.6

Avoided CO2 million metric tons 31.4 33.1 1.7 37.5 6.1 4.4 51.7 20.3 18.6 14.3

Avoided CF4 metric tons 0 0 0 0 0 0 0 0 0 0

Avoided CH4 thousand metric tons 21.3 22.7 1.4 26.4 5.1 3.7 38.5 17.2 15.8 12.1

Avoided N2O metric tons 471.9 503.3 31.4 585.4 113.5 82.2 853.7 381.8 350.5 268.3

Passenger cars not 

driven for one year million passenger cars 5.7 6.1 0.4 7.1 1.4 1 10.4 4.7 4.3 3.3

Passenger cars and 

light trucks not driven 

for one year 

million passenger cars 

and light trucks 4.7 5 0.3 5.8 1.1 0.8 8.4 3.7 3.5 2.6

Avoided gasoline 

consumption billion liters 11.1 11.8 0.7 13.8 2.7 1.9 20.1 9 8.2 6.3

Avoided oil 

consumption billion barrels 0.1 0.1 0 0.1 0 0 0.1 0 0 0

Avoided NOx (air) thousand metric tons 99.1 104.1 5.1 117.4 18.3 13.3 160.8 61.7 56.6 43.3

Avoided PM10 (air) metric tons 0.4 0.5 0 0.5 0.1 0.1 0.8 0.4 0.3 0.2

Avoided SOx (air) thousand metric tons 81 85 4 95.4 14.4 10.4 129.4 48.4 44.5 34.1

Avoided CO (air)l thousand metric tons 29.5 31.1 1.6 35.2 5.7 4.1 48.5 19 17.4 13.3

Avoided Hg (air) metric tons 1.9 2 0.1 2.2 0.3 0.3 3.1 1.2 1.1 0.9

Avoided Pb (air) metric tons 1.5 1.6 0.1 1.8 0.3 0.2 2.4 0.9 0.8 0.6

Avoided biochemical 

oxygen demand 

(water) metric tons 111 119.1 8.1 140.2 29.2 21.1 209.1 98.1 90 68.9

Avoided chemical 

oxygen demand 

(water) metric tons 936.2 1,004.40 68.2 1,183.00 246.8 178.6 1,766.20 830 761.8 583.2

Avoided copper 

(water) metric tons 0 0 0 0 0 0 0 0 0 0

Avoided suspended 

matter (water) metric tons 510.3 546.9 36.6 642.8 132.5 95.9 955.8 445.5 409 313.1

Avoided soil emissions metric tons 0 0 0 0 0 0 0 0 0 0

Avoided end of life 

waste metric tons 0 0 0 0 0 0 0 0 0 0
3-15

Notes:

a. Calculated as the sum of impacts for coal fly ash current use baseline, GGBFS and silica fume current use scenarios, years 2004 to 2015. 

b. Calculated as the sum of impacts for coal fly ash current use C2

P2, GGBFS and silica fume current use scenarios, years 2004 to 2015. 

c. Calculated as the difference between the current use baseline totals and the current use C2

P2 totals. This represents the impacts attributable to 

increased coal fly ash use under EPA’s C2

P2 program. 

d. Calculated as the sum of impacts for the coal fly ash 15% expanded use, GGBFS current use and silica fume current use scenarios for years 

2004 to 2015. Expanded use scenarios were not developed for GGBFS and silica fume. 

e. Calculated as the difference between 15% expanded use scenario totals and current use baseline totals. This represents the impacts achieved by 

moving from coal fly ash use levels without influence from EPA’s C2P2 program, to coal fly ash use levels under the CGP-recommended 15% 

substitution. 

f. Calculated as the difference between 15% expanded use scenario totals and current use C2P2 totals. This represents the impacts achieved by 

moving from coal fly ash use levels under EPA’s C2

P2 program, to coal fly ash use levels under the CGP-recommended 15% substitution. 

g. Calculated as the sum of impacts for the coal fly ash 30% expanded use, GGBFS current use and silica fume current use scenarios for years 

2004 to 2015. Expanded use scenarios were not developed for GGBFS and silica fume. 

h. Calculated as the difference between the 30% expanded use scenario totals and the current use baseline totals. This represents the impacts 

achieved by moving from coal fly ash use levels without influence from EPA’s C2

P2 program, to coal fly ash use levels under the CGP-maximum 

30% substitution. 

i. Calculated as the difference between the 30% expanded use scenario totals and the current use C2

P2 totals. This represents the impacts achieved 

by moving from coal fly ash use levels under EPA’s C2

P2 program, to coal fly ash use levels under the CGP-maximum 30% substitution. 

j. Calculated as the difference between 30% expanded use scenario totals and 15% expanded use scenario totals. This represents the impacts of 

moving from coal fly ash use levels under EPA’s C2

P2 program, to coal fly ash use levels under the CGP-maximum 30% substitution. 

k. For avoided CO2 equivalent, CF4, CH4, N2O, passenger cars removed, passenger cars and light trucks removed, and avoided gas and avoided oil 

consumption, impacts are attributable to coal fly ash only as these metrics were not evaluated for GGBFS or silica fume. 

l. BEES reports CO separate from CO2 emissions, but it is important to note that the Intergovernmental Panel on Climate Change (IPCC) 

considers CO emitted from portland cement manufacture a precursor to CO2. 
3-16

Figure 3-1: Avoided Energy Use for Coal Fly Ash and GGBFS, All Scenarios (Federally Funded Projects O

05

101520253035404550

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 

Year

Billion Megajoules

GGBFS Current UseFly Ash Current Use BaselineFly Ash Current Use C2P2Fly Ash Expanded Use 15%Fly Ash Expanded Use 30%
3-17

Figure 3-2: Avoided Water Use for Coal Fly Ash and GGBFS, All Scenarios (Federally Funded Projects O

0.00.51.01.52.02.53.03.54.04.5

2004 2005 2006 2007 2008 2009 2010 2011 2012 201

Year

Billion liters

GGBFS Current UseFly Ash Current Use BaselineFly Ash Current Use C2P2Fly Ash Expanded Use 15%Fly Ash Expanded Use 30%
3-18

Figure 3-3: Avoided CO2 Air Emissions for Coal Fly Ash and GGBFS, All Scenarios (Federally Funded Pr

012345678

2004 2005 2006 2007 2008 2009 2010 2011 2012 201

Year

Million metric tons

GGBFS Current UseFly Ash Current Use BaselineFly Ash Current Use C2P2Fly Ash Expanded Use 15% Fly Ash Expanded Use 30%
4-1

4.0 BARRIERS TO INCREASED RMC SUBSTITUTION 

This chapter addresses Part (B) of the Congressional mandate requiring EPA to “identify all 

barriers in procurement requirements to greater realization of energy savings and environmental 

benefits, including barriers resulting from exceptions from current law.” The discussion groups 

these barriers into four major categories: 

• Technical barriers; 

• Legal, regulatory, and contractual barriers; 

• Economic barriers; and 

• Perceived Safety and health risk barriers 

Several studies provide a discussion of barriers to increased RMC usage, especially as they apply 

to coal combustion products (CCPs).66 Specifically, DOE published a report to Congress in 1994 

entitled, Barriers to the Increased Utilization of Coal Combustion/Desulfurization Byproducts by 

Governmental and Commercial Sectors (DOE, 1994). The University of North Dakota Energy 

and Environmental Research Center (EERC) published an update to this report in 1998 (EERC, 

1999). In addition, EPRI published a report in 1992 entitled, Institutional Constraints to Coal 

Fly Ash Use in Construction (EPRI, 1992). EPA prepared two reports to Congress on wastes 

from the combustion of fossil fuels, the first of which, published in 1988, addressed wastes 

generated from the combustion of coal by electric utility power plants. The second, published in 

1999, addressed the remaining wastes not addressed in the 1988 report to Congress. More 

recently, the International Energy Agency (IEA) Clean Coal Centre published a report entitled 

Cement and Concrete—Benefits and Barriers in Coal Ash Utilization (IEA, 2005). 

Building on these publications, EPA and PCA held a workshop in 2005 focused on alternative 

fuels and raw materials used in portland cement manufacture. During this workshop, participants 

discussed barriers to increased RMC usage in portland cement manufacturing. Materials 

discussed included steel slag, foundry sands, and CCPs (EPA, 2005b). In addition to these 

sources, EPA and PCA consulted cement manufacturers and trade associations to solicit their 

perspectives on potential barriers to increased RMC usage. 

This section also incorporates additional information from research on individual state 

perspectives on CCP utilization. Specifically, EERC conducted state reviews addressing CCP 

utilization in Texas and Florida.67 These state reviews reveal benefits associated with the use of 

CCPs, as well as barriers to increased use (EERC, 2005). 

The following discussion contains selected excerpts from these documents, as well as industry 

perspectives to highlight barriers to increased RMC usage in Federally funded cement and 

concrete projects. Although some barriers have been reduced or eliminated since the publication 

of the reports identified above, a number of them still remain. Several of these barriers apply 

broadly to all RMCs; the discussion notes where barriers are specific to a particular material. 

 

66 This study also refers to CCPs as coal combustion byproducts (CCBs). 

67 Pennsylvania was the site of the third state review in December 2006. A synthesis report on the findings across 

the three states is forthcoming. 
4-2

Finally, not all of these barriers equally affect the level of RMC reuse, nor are they equally 

amenable to being addressed by policy mechanisms within the immediate purview of EPA. For 

example, strong technical or economic barriers to the use of a particular RMC in a specific 

application are generally going to be less influenced by a policy intervention than a barrier 

related to lack of awareness or information concerning a particular RMC use. 

4.1 Technical Barriers 

Technical barriers to the increased beneficial use of RMCs include: 

• Performance of products containing RMCs; 

• Acceptance of materials specifications; and 

• Consistency of RMC supply. 

4.1.1 Performance of Products Containing RMCs 

Product performance and quality concerns are known to prevent some potential RMC users from 

incorporating these materials into their portland cement or concrete products. These concerns 

may be related more to traditional terminology than actual performance. The term “recovered 

mineral content” refers to a material with a positive or beneficial use, regardless if the material 

was originally generated as a byproduct or waste. However, in many states, potential users and 

others appear to equate these materials with “wastes,” that do not or cannot have the same 

quality attributable to a virgin or manufactured material (Goss, 2006). Most RMCs, however, 

when used properly, will preserve or enhance final product quality and durability. 

Some specific concerns that have been identified include: 

• Some states prohibit the use of coal fly ash or slag after a certain calendar date 

each year (e.g., October 15), based on the concern that when coal fly ash or slag is 

used during cold weather, it can slow the set and strength gain of concrete and 

hence delay the project schedule.68 Conventional technologies, such as using a 

finer ground portland cement (Type III) or additional portland cement, 

accelerating admixtures, or using hot water for mixing could, in many cases 

overcome this concern, while maintaining the slag or coal fly ash content. 

• Some state DOTs limit the use of coal fly ash or GBFS due to engineering 

considerations such as curing time and the impact of cold weather on 

construction, and due to concerns about the availability of the materials that meet 

strict product specifications. 

 

68 This belief of slowed setting and rates of strength gain when using coal fly ash and slag in cement are repeated by 

(Lobo, 2006). 
4-3

• Use of GGBFS and coal fly ash at higher percent substitution rates for portland 

cement in concrete (greater than 50% for GGBFS and greater than 25% for coal 

fly ash) can reduce deicer salt scaling resistance (SCA, 2007).69 

• Foundry sands are typically a fine material and might not be suitable for use in 

concrete unless blended with other sands. In addition, the presence of clay and 

contaminants in foundry sands may also limit reuse opportunities (Mullarky, 

2006). 

As discussed further in the following section on mechanisms to address these barriers, research, 

testing, and pilot programs are being conducted by various industry and governmental entities to 

identify proper standards and specifications for RMC use in concrete applications. 

4.1.2 Acceptance of Materials Specifications 

Some of the most significant technical barriers related to performance are rooted in specific 

material specifications and how they are (or are not) applied. For example, many state 

departments of transportation (DOTs) do not accept ASTM’s performance specification for 

cement (C1157).70 This is a technical determination made by state DOTs. Compounding this is a 

lack of harmonization between the AASHTO and ASTM specifications.71 This leads to a lack of 

uniformity in the acceptance, specification, and utilization of RMCs among state DOTs. 

4.1.3 Consistency of RMC Supply 

One impediment to the increased use of coal fly ash in portland cement and concrete projects is 

the availability of required quantities of consistent, high-quality coal fly ash meeting the 

specifications for use in concrete (Mullarky, 2006). Different coal types produce different ashes, 

and an electric utility could switch among coal sources for various reasons (e.g., price, sulfur 

reduction) without consideration as to what this does to the ash characteristics. In addition, as 

discussed in Section 4.2.1, changes to air pollution control technology can affect the physical or 

chemical characteristics of RMCs. Lack of consistent quality of spent foundry sand is also likely 

to limit the development of its beneficial use market. 

The state CCP reviews help shed light on this potential barrier. The Texas CCP review notes 

that CCP generators and ash marketers each have stringent quality assurance/quality control 

(QA/QC) protocols, yet the Texas Department of Transportation (TX DOT) and ready-mix 

producers indicated that coal fly ash storage capacity is limited, affecting users’ ability to store 

consistent supplies, and the quality of coal fly ash on a truck-by-truck basis is not consistent. If 

there is a change in combustion operations, there is a resulting change in ash quality, making it 

 

69 Ongoing research at Iowa State University, sponsored by FHWA, several state DOTs, and industry is 

investigating the cause of scaling in GGBFS concrete. 

70 C1157-00 - Standard Performance Specification for Hydraulic Cement 

71 ASTM and AASHTO documents are now harmonized with respect to ASTM C 150 portland cement. However, 

AASHTO specifications as of this review do not include a performance cement specification analogous to ASTM C 

1157. 
4-4

difficult to produce a consistent product. In addition, TX DOT noted instances when coal fly ash 

was not available, even though it had been specified for a project. 

The Florida CCP review also points out that producing a good-quality, consistent CCP is not 

easy when plant operators at the utilities have not made this outcome a priority. Some Florida 

electric utilities are using or are considering investing in beneficiation systems to produce 

concrete-grade coal fly ash, which will allow some coal fly ashes with high unburned carbon or 

ammonia content to meet ASTM C618 specifications for use in concrete.72 

4.2 Legal, Regulatory Policy, and Contractual Barriers 

Laws, regulations, and contractual policies may pose inadvertent barriers to increased use of 

RMCs. In this section, we consider a diverse set of influences, including the following: 

• Air pollution regulations; 

• State solid waste regulations; 

• Bidding procedures and contractual constraints; and 

• Barriers associated with CPG 

4.2.1 Air Pollution Regulations 

Industry stakeholders, State of Florida officials (EERC, 2006), and other state agencies have 

stated that regulatory programs for the control of mercury and nitrogen oxides (NOx) in electric 

utility air emissions can result in increased carbon levels in coal fly ash that impact the ability to 

use the ash as a supplementary cementitious material. The increased carbon levels result from 

the addition of activated carbon to control mercury emissions, and low temperature boilers to 

control NOx emissions which also result in increased levels of unburned carbon in the ash. 

Industry representatives understand that there are technology choices that would minimize these 

impacts on the beneficial use of coal fly ash. However, they indicate that the selection of air 

emission controls to meet state and federal requirements is very complex, resulting in industry 

solutions that will be unit-specific. Industry further indicates that, in many cases, some facilities 

may lose anywhere between $40/ton and $80/ton of coal fly ash (Hg-CCP dialogue mtg. 

summary Final Draft, 1/14/08) if they are no longer able to sell high carbon fly ash as a 

supplementary cementitious material in the manufacture of concrete. This estimate also includes 

the additional costs associated with the need to dispose of a formerly marketable by-product. 

The Texas CCP review also notes that emissions control in the electric utility industry has had a 

subsequent impact on the type, quantity, and quality of the solid materials produced at a specific 

power plant (EERC, 2005). Officials indicate that the reduced supply of high quality coal fly ash 

already poses a threat to coal fly ash use in TX DOT projects, where high volumes of consistent 

quality coal fly ash are needed over the duration of large, long-term projects. 

 

72 One concern noted with respect to this consideration, however, is that any combustion facility associated with the 

use of carbon burnout (CBO) systems may be categorized by FDEP as a new NOX source. If categorized in this 

manner, the installation of CBO systems may trigger New Source Review (NSR) requirements under the Prevention 

of Significant Deterioration provisions of the Clean Air Act. 
4-5

EPA will continue to monitor the emission technologies the industry chooses to install and the 

impact on reuse potential. EPA believes that technology options are available to the industry, 

specifically for the application of NOx controls, which would minimize any impacts on the 

quality of fly ash. Technology solutions are being developed and deployed in the industry to 

minimize or avoid any such impacts from the use of mercury controls as well. 

4.2.2 State Solid Waste Regulations 

There are no uniform, national regulations for the beneficial use of recovered materials. Each 

state has its own regulatory program. Although many states are acting to facilitate the use of 

RMCs in concrete, some state solid waste regulations governing the management of RMCs may 

make it more difficult to beneficially use these materials. For example, in the Florida CCP 

review, some observers thought that state monitoring and other requirements were restricting 

beneficial use requests. In some cases, the Florida Department of Environmental Protection 

(FDEP) has required end users to install liners under temporary CCP storage areas as a 

precautionary measure. FDEP also requires the material to be covered. Additionally, there is 

hesitation from FDEP to allow CCP use in land applications, limiting the Florida Department of 

Transportation’s ability to use it in road-building applications. The Florida review notes that 

some commenters viewed these requirements as unnecessary because they do not apply to 

comparable materials, or even to materials that interviewees considered to be of greater threat of 

environmental contamination, such as coal or limerock. CCPs are essentially being treated as a 

regulated solid waste by FDEP in this regard (EERC, 2005). 

Experience with Florida’s beneficial use application regulations further highlights the influence 

of solid waste regulation on the beneficial use of RMCs. The Florida CCP review notes that 

FDEP does not have a formal process for approving new beneficial use applications. Florida 

statutes generally define “solid waste” to include any discarded material resulting from domestic, 

industrial, commercial, mining, agricultural, or governmental operations. This includes CCPs. 

However, there is another provision in Florida’s statutes that exempts certain materials from 

regulation as solid waste if: 

1. A majority of the industrial byproducts are demonstrated to be sold, used, or 

reused within one 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 in the 2007 Florida 

Statutes (Title XXIX, Chapter 403, Part IV, and Section 703.) 

Currently, FDEP does not have a rule implementing this section. Sometimes, FDEP points 

applicants to beneficial reuse guidance documents prepared for recovered screen material and 
4-6

waste-to-energy ash. Until a rule is promulgated, however, beneficial use projects are evaluated 

on a case-by-case basis. FDEP acknowledges that the current case-by-case approval procedure 

for CCP beneficial reuse is unclear. 

Texas was also selected as a pilot state for an in-depth review of its CCP programs, policies, and 

use practices because of its progressive approach to CCP utilization and its support network to 

implement such activities. Although the Texas state review discussed barriers for all 

applications, we summarize only those specific to CCP use in portland cement and concrete: 

• Virtually all of the utilities, ash marketers, and ready-mix producers mentioned 

attitude and education as key barriers. District and local highway personnel, 

architects, engineers, and contractors cited unfamiliarity, lack of knowledge, or 

unwarranted negative feelings toward CCPs as barriers to greater CCP utilization. 

• CCP generators and ash marketers each have stringent quality assurance/quality 

control (QA/QC) protocols, yet TX DOT and ready-mix producers indicated that 

fly ash storage is limited, and the quality on a truck-by-truck basis is inconsistent. 

If there is a change on the combustion side, there is a resulting change in ash 

quality, making it difficult to produce a consistent product. In addition, TX DOT 

noted instances when coal fly ash was specified for a project, but was not 

available. 

• By classifying CCPs as products, the material has the same advantages as all other 

recycled materials. However, liability lies primarily with generators and users 

because generators assume the responsibility of classifying the material in 

accordance with 30 Texas Administrative Code (TAC), Chapter 335.4, 

Subchapter R, and users take on the liability of using the material properly. 

In addition to identifying existing impediments, the Texas state review identified several 

emerging issues that may affect CCP use in the future. These include new pollution control 

requirements (as discussed in Section 4.2.1) and the ability to retain institutional knowledge of 

CCPs as staff is turned over at the Texas Commission on Environmental Quality (TCEQ) and the 

Texas Department of Transportation. 

4.2.3 Bidding Procedures and Contractual Constraints 

Bidding procedures and contractual rigidities associated with procurement of portland cement 

and other RMC-related products may inadvertently constrain the use of RMCs. Industry sources 

note that contracts generally discourage changes in cement mix design. To counter these 

concerns and provide a consistent product, a contractor might default to a portland-only mix or 

one that contains less of the RMC (e.g., out of a concern for seasonal shortages of the RMC). 

Contract specifications may force more competition among RMCs than necessary. Specifically, 

some specifiers (particularly some state DOTs) do not allow ternary mixtures (three-cementitious 

components) in concrete, so concrete is “forced” to use either coal fly ash or slag cement, if 

RMCs are to be used. However, ternary mixtures often provide performance benefits in 
4-7

concrete. Allowing ternary mixtures provides the possibility of using both coal fly ash and slag 

cement at significant rates in concrete, and also provides a way to replace greater levels of 

portland cement than just coal fly ash substitution alone. For instance, the Iowa DOT typically 

uses a mix of 15% coal fly ash and 20% slag cement; coal fly ash alone would likely not be used 

at a 35% replacement rate, but the two materials in combination works well for this DOT (SCA, 

2007).

In some cases, the beneficial use of RMCs is constrained by the lack of familiarity with the RMC 

or preference for a well-known RMC, and these tendencies are reflected in procurement 

procedures. For example, specifiers often do not understand the difference between slag cement 

and coal fly ash. Since slag cement is generally a “newer” material in markets, these 

practitioners are often reluctant to allow slag substitution rates at their optimal level (up to 50% 

for pavements and up to 80% for mass concrete). They are more accustomed to coal fly ash 

substitution rates of 15% to 30%. This is reflected in a number of State DOT specifications that 

do not allow more than 25% slag cement (Arkansas, Illinois, Missouri, New York, and 

Vermont). SCA is working with FHWA to produce a users’ manual for highway engineers about 

slag cement (SCA, 2007). 

4.2.4 Barriers Associated With CPG 

The CPG for cement and concrete require Federal agencies to give a procurement preference for 

recycled materials and products containing RMCs, when possible. However, a procuring agency 

might not always be able to purchase a CPG-designated item containing RMCs. RCRA Section 

6002(c)(1) allows a procuring agency the flexibility not to purchase an EPA-designated item 

with recovered materials content. According to the statute, the decision not to procure such items 

must be based on a determination that such procurement items: 

1. Are not available within a reasonable period of time; 

2. Fail to meet the performance standards set forth in the applicable specifications; 

3. Fail to meet the reasonable performance standards of the procuring agencies; or 

4. Are only available at an unreasonable price.73

Over or inappropriate use of these exemptions could contribute to unnecessarily reduced RMC 

usage. Similarly, management inattention to the statutory procurement requirements could lead 

to failure to use RMCs. 

4.3 Economic Barriers 

Economic barriers to increased RMC utilization represent a key factor affecting the use of 

RMCs. The sections below present a brief discussion of the key economic barriers affecting 

increased RMC use. The following barriers are discussed: 

 

73 RCRA Section 6002, http://epa.gov/epaoswer/non-hw/procure/pdf/rcra-6002.pdf
4-8

• Transportation costs and geographic distribution; 

• Importance of RMCs as a revenue stream; 

• Cost-effectiveness; and, 

• RMC disposal costs. 

4.3.1 Transportation Costs and Geographic Distribution 

RMCs are not necessarily generated in the vicinity of cement kilns or major construction projects 

or, in the case of foundry sands, are generated by a relatively large number of generators 

producing relatively small quantities. The costs of collecting and transporting these materials 

from their points of generation can render them uncompetitive with virgin materials at a specific 

site. For example, the ACAA notes that transportation costs are the primary economic 

impediment to the reuse of CCPs. ACAA estimates that such costs generally limit the shipment 

of CCPs to a 100-mile radius around a power plant. In addition to the problems posed by 

distance, using railcars to transport RMCs also presents issues because railcar availability is 

limited, and rail transportation rates are high in certain markets. This issue also applies to virgin 

materials; however, the geographic distribution and specific transportation costs are likely to 

vary from those for CCPs.74 

Studies have noted the sub-optimal geographic location of RMC supplies, particularly coal fly 

ash and bottom ash. The best example of the lack of local availability is in California, where 

essentially no coal-fired power plants and no blast furnaces exist. However, depending on the 

size and scale of the project, the lack of proximate coal fly ash and related transportation costs 

may be overcome. For example, the large CalTrans Bay Bridge project imported coal fly ash 

from Washington and Wyoming, and the additional cost of transportation was minimal when 

compared to the entire project budget.75 

As discussed in Section 4.1.3, different coals produce different ashes and an electric utility could 

switch among coal sources for various reasons (price, transportation costs, sulfur reduction, etc.) 

without consideration as to what this does to the ash. In an October 29, 2001, letter to EPA, DOE 

commented that “DOE sites have expressed concerns about the proposed concrete additives. An 

operations office in the western part of the country has stated...that cenospheres and silica fume 

additives for concrete may not be as readily available in all locations as EPA suggests” (DOE, 

2001). This overbalance can be an impediment, as only certain areas of the country have access 

to RMCs, and transportation costs are too great to move the materials to areas with a relatively 

low supply of RMCs. 

Likewise, slag granulation facilities are principally in the East, Midwest and South, so for 

adequate slag cement to reach more remote areas, like the West Coast, imports become essential. 

Bulk transportation over water is significantly less costly and energy intensive than 

transportation by highway or rail. Additional slag granulation facilities, if constructed in the 

 

74 ACAA reports: As the value of coal fly ash has risen in the last two years, ash is typically trucked up to 100-150 

miles without difficulty. Rail shipments have increased to more than 1200 miles. 

75 Personal communication with Tom Pyle, California Department of Transportation (CalTrans), August 30, 2007. 
4-9

Midwest or East, would help improve the geographic distribution somewhat, but not to the 

Rocky Mountain or West Coast states (SCA, 2007). 

In addition, seasonal factors can influence both the amount of RMCs produced (e.g., increased 

summer and winter power demands result in seasonal increased CCP production) and the 

demand for building materials (EPA, 2005b). Lack of product availability in certain markets can 

be a significant impediment to greater reuse. The shortage of coal fly ash in the Pacific 

Northwest in 2006 illustrates the impact of product non-availability. Construction specifications 

are prepared years in advance of construction. If an RMC is abundant, and included in the 

specification, but availability declines when construction starts, it may become a frustrating and 

costly problem for the contractor. Such an event could cause an agency to be cautious about 

including the RMC in future specifications. 

The Texas state review (EERC, 2005) echoes the importance of transportation costs to the 

beneficial use of CCPs. In Texas, power plants are located in areas that are not heavily 

populated, so long distance transportation is necessary to get to major CCP markets. Some 

electric utilities also have limited infrastructure, making it difficult to transport their materials by 

anything other than by truck. In many instances, it is simply not economical to use CCPs due to 

these costs. 

Finally, in relation to transportation costs and GGBFS distribution, foreign sources of RMCs can 

influence the reuse rate of domestic supplies. For example, the U.S. currently imports significant 

quantities of GGBFS from overseas because of low rates of slag granulation in the U.S., as well 

as that it is more economical on the West Coast to import GGBFS from the Far East than to ship 

it across the United States. (See further discussion below regarding the Cost of Increasing Slag 

Granulation Capacity.) Furthermore, bulk transportation over water is significantly less costly 

and energy intensive than transportation by highway or rail. Availability of foreign sources may 

enhance the economic disadvantage introduced by overland transportation costs. 

4.3.2 Importance of RMCs as a Revenue Stream 

The way in which utilities, and all RMC generators, account for costs is critical to RMC 

utilization (EERC, 1999). For example, for many utilities, the sale of CCPs is generally seen as 

merely a means of reducing operational costs through avoided disposal costs. When ash 

management is considered “an operational cost avoidance” rather than a revenue stream, the 

incentives for increased CCP utilization are reduced as compared to it being a source of revenue. 

The market value of RMCs is critical to how a supplier views the management of these 

materials. For coal-fired electric utilities, the revenue produced by the sale of CCPs is often 

insignificant in relation to the revenue stream provided by the sale of electricity. The prices 

received for CCPs may be too low to justify a commitment to material marketing. 

4.3.3 Cost-Effectiveness 

The high price of some RMCs can be an impediment to their greater use. In a letter sent from 

DOE to EPA on October 29, 2001, a DOE northwest office advises that “...Unlike fly ash where 
4-10

the cost with or without fly ash is the same, including silica fume increases the cost by about $1 

per pound. A typical [cubic] yard of concrete will use nearly 50 pounds of silica fume, which 

would increase the cost roughly 50%-65% for each [cubic] yard of concrete used” (DOE, 

2005b). 76

It is noteworthy, however, that RMCs with high unit prices (e.g., GGBFS and silica fume) also 

can have high reuse rates. Therefore, high prices may often be a reflection of the high inherent 

value that some of these materials have as portland cement and concrete additives. 

It should also be noted that some individual foundries may choose to engage in a partnership 

with an intermediary as a cost-effective way to market and sell its spent foundry sand. The costs 

to market the sand may be higher than the firm is willing to spend and will look to a middleman 

to conduct the sales transactions. If the costs of selling were lower, or if the selling price were 

higher, the foundries may be more willing to handle the process themselves. 

Finally, slag granulation in the U.S. affects the cost-effectiveness of this material for use as an 

RMC. The slag granulation rate in the U.S. is considerably lower than other industrialized 

nations. In the U.S., only 25% of slag is granulated, while in Europe and Japan, nearly 80% of 

blast furnace slag is granulated. Several reasons for the low U.S. granulation rate exist, 

including uncertainty and consolidation in the steel industry; capital cost of installing 

granulation/grinding facilities; and availability of foreign slag granules (SCA, 2007). 

4.3.4 RMC Disposal Costs 

The relatively low cost of disposal tends to discourage the expanded use of many RMCs in 

cement and concrete. Disposal costs are a function of available disposal sites. For Electric 

Utilities, as part of the permitting process for any new facility or upgrade to an existing facility, 

the permit must describe what is anticipated for any waste or byproduct streams. Existing plants 

typically have sites near the plant for disposal, if needed. They may be owned by the utility 

(most common) or nearby, such as a locally managed landfill (not necessarily a municipal solid 

waste landfill), most likely a monofill. Given the nature of privately-owned and industrial waste 

landfills, total available capacity at these sites is uncertain. However, according to the National 

Solid Wastes Management Association, as of November 2006 there were approximately 1,654 

Subtitle D landfills operating in the 48 contiguous states.77 Furthermore, on a national level, the 

current municipal solid waste landfills have 20 years worth of disposal capacity available. 

For many RMC generators, the market value of the material does not make up for the handling, 

processing, and marketing costs of selling the material for beneficial use. Current beneficial use 

 

76 SFA indicates that “the primary impression of silica fume as a raw material and silica fume concrete in general is 

that ‘silica fume is quite expensive’ and as a concrete ‘more difficult’ and ‘costly’ to finish as compared to concrete 

containing no silica fume. This industry impression as an expensive material has limited the use of silica fume and 

is the primary obstacle to further expanding the use of silica fume in concrete” (Kojundic, 12/13/2006). (Note: 

USGS reports that further use of silica fume is primarily limited by the inelastic supply of silica fume, as a result of 

the relatively inelastic global supply of silicon metal and ferrosilicon and related ferroalloys production. (Personal 

communication with Hendrik van Oss, USGS, July 12, 2007.)) 

77 National Solid Wastes Management Association, November 8, 2006, “MSW (Subtitle D) Landfills.” 

Available at: http://wastec.isproductions.net/webmodules/webarticles/anmviewer.asp?a=1127
4-11

programs from states, Associations, and EPA are helping to expand the beneficial use of these 

materials. However, as long as it is more economical to dispose of the RMCs in land disposal 

units than to use them beneficially or to sell them as a marketable product, use rates will likely 

be limited. 

4.4 Perceived Safety and Health Risk Barriers 

Another barrier to the expanded beneficial use of RMCs concerns the safety and health risks – 

real or perceived – associated with these materials, i.e., the environmental risks associated with 

exposure to these industrial materials if they enter the environment through leaching into soil or 

other pathways. The issue of risk continues to be evaluated by the Agency. However, targeted 

risk analyses conducted to-date indicate that risks associated with the identified RMCs in cement 

and concrete are likely to be insignificant. For example, in the Agency’s May 2000 Regulatory 

Determination for fossil fuel combustion wastes, EPA’s risk evaluation of the beneficial use of 

CCPs in cement and concrete concluded that national regulation under the Resource 

Conservation and Recovery Act (RCRA) is not warranted.78 This final Regulatory 

Determination additionally notes a previous Regulatory Determination in 1993 (see 58 FR 

42466; August 9, 1993), an EPA-proposed risk-based set of standards for CKD (see 64 FR 

45632; August 20, 1999), and an unpublished report as of May 22, 2000 from the National 

Academy of Sciences presenting “a comprehensive review of mercury and recommendations on 

appropriate adverse health effects levels for this constituent.” Additional research concerning 

steel slag includes a study conducted by Deborah M. Proctor, et al.: “Assessment of Human 

Health and Ecological Risks Posed by the Uses of Steel-Industry Slags in the Environment,” 

2002. Human and Ecological Risk Assessment Vol. 8, No. 4, pp. 681-711. 

Findings from these analyses did not identify significant risks to human health and the 

environment associated with the beneficial uses of concern. In addition, we identified no 

documents providing evidence of damage to human health and the environment from these 

beneficial uses. Our overall conclusions from these efforts, therefore, are that encapsulated 

applications, including cement and concrete uses, appear to present minimal risk.

EPA has also supported risk analyses associated with the beneficial use of foundry sand. The 

Agency concluded that the use of foundry sand as a substitute for natural silica sand in making 

clinker, as a substitute for natural sand in cement, or in other uses in concrete manufacture, 

appears to present minimal risk to human health and the environment. 

 

78 http://www.epa.gov/epaoswer/other/fossil/ff2f-fr.pdf
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5.0 MECHANISMS TO INCREASE THE BENEFICIAL USE OF RMCs 

This section addresses Part (C) of the Congressional mandate requiring EPA to identify potential 

mechanisms to achieve greater substitution of RMCs in cement and concrete products. The 

discussion covers a broad suite of existing and potential mechanisms, and contemplates 

mechanisms that are both within and beyond the immediate purview of EPA and its partner 

agencies. To help align these mechanisms with the barriers described in Section 4, we group the 

discussion into three categories followed by a generalized set of mechanisms: 

• Procurement policies and material use standards; 

• Education, technical assistance79, and recognition programs; and 

• Economics 

Several of the mechanisms described within each category are generally applicable to most types 

of RMCs.80 Consistent with the Congressional charge, however, we also focus on certain RMCs 

that have historically only been beneficially used at lower levels than other RMCs. For example, 

the discussion under "Education, technical assistance, and recognition programs," covers 

programs focused on increasing the use of coal fly ash and foundry sand in cement and concrete. 

As presented, many of the mechanisms described in this section apply to non-Federal, as well as 

Federal projects. The amount of RMCs produced annually in the U.S. surpasses the amount that 

can be incorporated into Federal cement and concrete projects alone. Thus, we consider this 

broader application of potential mechanisms due to the fact that increasing reuse rates to higher 

levels will require greater reuse among both Federal and non-Federal cement and concrete 

projects. 

Finally, this section represents the collective input of a variety of different stakeholders, and 

includes a wide range of options that have been proposed in various contexts. 81 Some of these 

options may be outside the scope of the mechanisms and issues that EPA has control over. 

Further, several of the mechanisms outlined in this chapter may require additional resources to 

complete and sustain into the future. However, we include this broad range of ideas for the 

purpose of documenting and briefly discussing the various options contemplated. 

5.1 Procurement Policies and Material Use Standards 

Procurement policies offer the opportunity to stimulate demand for products making beneficial 

use of RMCs. We consider several aspects of procurement policies: 

• We first review implementation of EPA’s CPG and efforts to assess their impact 

on the beneficial use of RMCs; 

 

79 Includes technical research. 

80 Several of the mechanisms discussed in this chapter are similar in nature to those proposed by: Buckley, Tera D., 

and Debra F. Pflughoeft-Hassell, “National Synthesis Report on Regulations, Standards, and Practices Related to the 

Use of Coal Combustion Products,” Energy & Environmental Research Center, University of North Dakota. Draft 

Final Report, July 2007. 

81 The full set of mechanisms identified by industry representatives is summarized in Appendix E to this report. 
5-2

• Next, we consider efforts to revise engineering and procurement standards to 

optimize the substitution of RMCs in concrete and cement; and 

• Finally, we examine how modifying building and construction standards could 

help increase the beneficial use of RMCs. 

5.1.1 Influence of EPA’s CPGs on RMC Beneficial Use 

Since its inception, procuring agencies, including EPA, have developed a multi-faceted approach 

to implement RCRA section 6002 and the CPG program. Components of this approach have 

both broad and specific relevance to the use of RMCs in Federal concrete projects, including: (1) 

expanding the number of RMCs covered by the CPG; (2) strengthening and streamlining policy 

guidance related to green purchasing requirements, implementation, and reporting; and (3) 

developing and delivering information resources, training, and outreach activities. 

With respect to item (1) above, the RMCs currently covered by the CPG include coal fly ash, 

GGBFS, silica fume and cenospheres. Specifically in 1983, EPA’s original procurement 

guideline designated cement and concrete containing coal fly ash. EPA subsequently amended 

the designation in May 1995 (CPG III) to include cement and concrete containing GGBFS, and 

again in April 2004 (CPG IV) to add silica fume and cenospheres.82 

To translate the CPG designation of an item into actual purchases, procuring agencies are subject 

to a number of implementation and reporting statutory requirements. For example, procuring 

agencies that purchase more than $10,000 of a CPG item are required, by RCRA Section 6002, 

to establish (within one year after the item has been listed) an affirmative procurement program 

for that item. An affirmative procurement program is an agency's strategy for maximizing the 

purchase of an EPA-designated item. Affirmative procurement programs should be developed in 

a manner that assures that items composed of recovered/recycled materials are purchased to the 

maximum extent practicable. Over the years, these programs have been bolstered by a number 

of Executive Orders; the most recent, Executive Order 13423, requires that Federal agencies 

promote the purchase of energy efficient, recycled content, biobased, and environmentally 

preferable products through their purchasing requirements.83

With particular relevance to RMC use in Federal cement and concrete projects, the FHWA and 

other DOT grant programs are explicitly included as purchasing agencies under RCRA Section 

6002, as explained by the conference committee report from the Hazardous and Solid Waste 

Amendments of 1984 (Cong. Rec. H 11138 [October 3, 1984]): 

To assure the fullest participation by procuring agencies, the Conferees wish to 

resolve any ambiguity with respect to §6002’s coverage of the Department of 

Transportation, in particular the Federal Highway Administration (FHWA). The 

 

82 U.S. EPA, Comprehensive Procurement Guidelines, About CPG/RMAN, from http://epa.gov/cpg/about.htm. 83 Adapted from: “Fact Sheet: Executive Order 13423 Strengthening Federal Environmental, Energy, and 

Transportation Management,” The Office of the Federal Environmental Executive. OFEE and OMB require 

agencies to have holistic green purchasing plans that include the EPA-designated recycled content products with 

other green products and services, rather than a separate affirmative procurement program just for the EPAdesignated products. 
5-3

FHWA is a “procuring agency” under the Solid Waste Disposal Act and is 

therefore fully responsible for implementing the guidelines and other 

requirements of §6002. It is the intent of Congress that both FHWA’s direct 

procurement and indirect Federal-aid programs (Federal Highway Trust Fund) 

be covered by the requirements of §6002 as amended by this Act. Indirect 

purchases by the Federal Aviation Administration are also covered under Section 

6002 in the same manner as is the FHWA. Coverage of the FHWA’s direct and 

indirect procurement activities under this amendment extend to the review of 

procurement specifications pursuant to Section 6002(d), as amended, in addition 

to the affirmative procurement program required under this section. 

Recent efforts have also focused on improving the quality of procurement data and streamlining 

the reporting process for Federal agencies. For example, in an effort to increase Federal 

purchasing of energy efficient, recycled content, biobased, and environmentally preferable 

products, E.O. 13423 and related guidance require agencies to integrate four existing disparate 

purchasing requirements into an integrated Federal purchasing effort that applies to all types of 

acquisitions of goods and services.84 The Order requires every year that agencies track and 

report on their purchases of EPA-designated recycled-content items.85 

Section 6002 of RCRA requires the Office of Federal Procurement Policy (OFPP) to report to 

Congress every two years on the actions taken by Federal agencies to implement Section 6002. 

When it became clear that it was not possible to gather accurate information on every agency’s 

purchases of individual EPA-designated products, OFPP and OFEE convened a workgroup to 

create a new reporting format. Materials, such as concrete, are supplied or used as part of 

construction contracts. Contractors generally do not report on the volume of materials supplied 

or used, let alone the recycled content of materials. For this reason, agencies now provide other 

evidence of compliance in the annual data reports. 

The reporting questionnaire focuses on compliance, training, and auditing and trends analysis to 

foster increased accountability for program implementation. In the case of construction 

products, it asks agencies to “Demonstrate how your agency complies with the requirements to 

purchase EPA-designated construction products containing recovered materials, to the maximum 

extent practicable. Examples include integrating specific, recycled-content products requirements 

with the use of the U.S Green Building Council’s Leadership in Energy and Environmental 

Design (LEED), incorporating recycled-content product requirements into design specifications, 

and inserting recycled-content product requirements into design/build contracts.” 

To optimize program performance, implementation and reporting procedures are supplemented 

with information resources and training activities. Outreach and inter-agency collaboration 

activities also occur on an ongoing basis.86

 

84 Executive Order 13423, "Strengthening Federal Environmental, Energy, and Transportation Management," Fact 

Sheet. 

85 Strengthening the Federal Environment, Energy, and Transportation Management, January 27, 2007. 

86 For a more detailed discussion of these efforts, see, for example: Office of Management and Budget; Office of 

Federal Procurement Policy, "Resource Conservation and Recovery Act: A Report on Agencies' Implementation for 

Fiscal Years 2002 and 2003," October 2005. 
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This multi-faceted approach to green purchasing has led to many successes, including 

influencing the amount of RMCs procured for use in concrete products. As one example, for 

agencies that gather data for specific designated items, for FY 2003, more than 80% of the 

concrete purchases made by NASA, DOE, and GSA contained coal fly ash or slag. The CPG 

program, therefore, represents a critical mechanism to achieve higher RMC reuse levels. 

To continue and expand upon this progress, however, the procurement guidelines and their 

implementation are the focus of ongoing improvement efforts. These efforts cover the 

facilitation role played by EPA, OFPP, and OFEE under the auspices of RCRA 6002 and the 

Executive Orders, and extend to on-the-ground decision-making of Federal procurement entities 

and their reporting obligations. We discuss these issues in further detail below. 

5.1.2 Discussion of Response to CPGs for RMCs in Concrete and Cement 

A number of governmental reports and reviews have commented on the efficacy of purchasing 

programs for recycled-content products, including, by implication, concrete products containing 

RMCs.87 The conclusions drawn in these commentaries focus on two general limitations: (1) the 

lack of robust reporting data on volumes of purchased products and related inability to link such 

volumes to the influence of procurement requirements; and (2) the need for expansion of 

guidance and tools to facilitate the procurement of products with recycled content. In addition, 

with respect to RMC reuse and procurement requirements, several stakeholders have suggested 

that addressing various issues related to material standards and specifications, along with 

contract bidding procedures, may positively influence reuse rates. 

5.1.2.1 Data Limitations 

The extent to which the major Federal procuring agencies have purchased products containing 

RMCs is difficult to measure because few data systems clearly identify purchases of recycledcontent products. In addition, agencies do not receive complete data from their headquarters and 

field offices or their contractors and grantees. As a result, they generally provide estimates, not 

actual first-hand data, to the OFPP and OFEE.88 

Industry commenters (e.g., Holcim, Ltd.) emphasized the need for a centralized reporting system 

that tallies the amount and type of recycled cement/concrete products used in Federally-funded 

projects. In addition, GAO issued the report “Federal Procurement: Better Guidance and 

Monitoring Needed to Assess Purchases of Environmentally Friendly Products” in 2001 to 

evaluate the status of, and barriers to, Federal agencies’ efforts to implement RCRA 

requirements for procuring products with recycled content. The GAO report contained 

suggestions focusing on improving procurement processes, guidance, and data systems. 

 

87 See, for example, Statement for the Record by David G. Wood, Director, Natural Resource and Environment 

Issues, US General Accounting Office, July 11, 2002 (GAO-02-928T). 

88 June 2001, GAO report, “Federal Procurement- Better Guidance and Monitoring Needed to Assess Purchases of 

Environmentally Friendly Products” 
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Improvements in data collection also were highlighted in “Leading By Example: A Report to the 

President on Federal Energy and Environmental Management (2002-2003).” 89 

One example of how relevant procurement data are difficult to both derive and interpret involves 

the recent analysis of agencies’ Federal Procurement Data Systems (FPDS) data. This review 

indicated that recycled content products were not being supplied or used in more than 95% of the 

contracting actions in FY 2002 and FY 2003. While the agencies have not completed their 

assessment of the FPDS data, EPA believes that the amount of material procured does not 

accurately reflect the range of products that can be supplied or used as part of support services 

contracts. 

Better reporting, resulting from the initiatives noted above, should yield a more comprehensive 

information resource to evaluate the performance of the CPG program and identify further areas 

for targeted improvement.90 Detailed data from each contract on the materials, sources, 

tonnages, haul distances, and mixture proportions would significantly improve the 

documentation and assessment of RMC benefits in Federal concrete projects. It is important to 

note, however, that with respect to RCRA Section 6002; EPA, OFPP, and OFEE provide only a 

facilitation role, and have no oversight or compliance assurance authority. These obligations fall 

to the individual procuring agencies. 

One option for increasing compliance could include OFEE using an awards program to focus on 

Agencies’ efforts to purchase products with RMCs. OFEE and OFPP can provide negative and 

positive recognition during the annual Federal budget process. Agencies implementing the CPG 

guidelines and the EO goals and policies can be rewarded. 

5.1.2.2 Procurement Facilitation 

The ability of agencies to procure recycled content products is subject to a number of 

considerations related to information availability, logistics, and costs, among others. EPA and 

partner agencies continue efforts to provide agencies with the information necessary to 

effectively promote the purchase of products with recycled content. These efforts focus on 

outreach, training, and education, along with making relevant information more readily 

accessible. For instance, one area of concern is that green purchasing mandates may not be 

effectively extended to government contractors or grantees. As one measure to address this 

concern, OFEE has revised its training for contracting personnel to emphasize that recycled 

content and other green products are often supplied or used. Contracting personnel are taught 

that contracts should require a contractor to supply or use green products. 

 

89 “Leading By Example: A Report to the President On Federal Energy and Environmental Management (2002-

2003).” October 2004, from http://ofee.gov/final_report1.pdf. 

90 For example, with more robust reporting data, the RCRA agency data report could be amended to include more 

specific questions for agencies regarding their purchases and usage of RMCs in construction projects. Currently, due 

to data limitations, it only asks for a prepared document generally discussing efforts of the agency and not the 

specific quantities of material used. 
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5.1.3 Specifications and Bidding Procedures 

Another set of suggested mechanisms to increase the use of RMCs focuses on the development 

of engineering and procurement standards to optimize the substitution of RMCs in concrete and 

cement. Industry representatives consulted for this report offered observations on how the CPGs 

could be made more effective. For example, SCA stated that the CPGs should have more 

explicit requirements regarding replacement rates and the use of ternary mixtures. In addition, 

the CPGs could have a greater impact if several actions were taken when the review protocol 

recommends specification changes: (1) reissue the specifications if there is time prior to the 

project bid date; (2) if the project has already been bid, then require re-bidding; and (3) withhold 

Federal funding if the project specifiers do not change the specifications. 

Some efforts are already underway to implement these mechanisms. For instance, the cement 

industry has recently promoted the acceptance of the Standard Performance Specification for 

Hydraulic Cement ASTM C1157 to the DOT’s FHWA, Federal Aviation Administration (FAA), 

Corps of Engineers, and Bureau of Reclamation; however, to date, the effort has met with limited 

success. There also is a separate effort to harmonize the AASHTO and ASTM standards via an 

ASTM/AASHTO Task Group, but successful completion of this effort will also take time. In the 

interim, some companies have modified specifications to their cement to address early strength 

issues. For example, Holcim has decreased the slag content in its IS blended cement to address 

seasonal concerns, and the company is currently evaluating the use of different grinding aids that 

will address the perceived set/strength issue. The cement industry as a whole has taken measures 

to emphasize the need for proper finishing and curing techniques to offset the scaling issue. 

In general, the development of standards for optimized substitution is feasible, provided that the 

effort is based on a process where the stakeholders with concerns about quality, cost, and risk 

can participate and identify solutions that address the priorities of each group. However, this 

process, as noted above, can require significant time to arrive at an acceptable solution, and will 

require participation of enough government and industry leaders to provide momentum for 

moving toward a nationally consistent application of standards in different state and local 

jurisdictions. 

5.1.4 Building Standards 

Standards for building and construction offer another avenue for increasing the beneficial use of 

RMCs. First, integrating environmental building requirements into Federal, state, and local 

public building standards could help promote the use of RMC-based materials. Second, 

specifications outlining the use of RMCs could be integrated into building contracts. In 

conjunction with the economic measures described below, the incorporation of additional RMCs 

into building standards could potentially have a large impact on increased RMC use. We discuss 

these options below. 

5.1.4.1 Building and Construction Industry Practices 

The U.S. Green Building Council’s LEED Green Building Rating System® is a voluntary, 

consensus-based national standard for developing high-performance, sustainable buildings. 
5-7

RMC use constitutes only one LEED credit; however, the reduction in GHG that may result from 

increased RMC could satisfy other credits. 

The potential for building industry standards such as LEED to be written into Federal, state, and 

local public building standards offers a simple method for increasing SCMs in cement and 

concrete (PCA, 2003). By explicitly identifying building standards that include the use of RMCbased cement and concrete, the building and construction industry will likely become more 

familiar with these materials and increase their use. In fact, certain Federal agencies already use 

LEED and have found that familiarity with sustainable design and green materials among 

architects and construction contractors has been increasing. Modification of building standards 

could be further pursued in concert with broader green building efforts. Projects, such as the 

Green Building Initiative, for example, “work with builders and their associations to facilitate 

understanding and acceptance of sensible green building practices.”91

Furthermore, continued CPG implementation by FHWA and additional promotion of the Green 

Highways Partnership are likely to alter current transportation construction practices as RMC use 

is increased as a result of new practices and usage patterns. See Section 5.2.3 for information on 

the Green Highways Partnership. 

5.1.4.2 Specifications within Building Contracts 

 

EPA and other stakeholders have recognized the need for a guide for procuring green building 

products and construction services through Federal contracts. In response, EPA has partnered 

with the Federal Environmental Executive and the Whole Building Design Guide (WBDG) to 

develop the Federal Green Construction Guide for Specifiers.

92 This guide helps Federal 

agencies meet their project-specific environmental goals and mandates, and includes the 

following components: 

• Federal Leadership in High Performance and Sustainable Buildings Memorandum 

of Understanding; 

• EPA's Final Guidance on Environmentally Preferable Purchasing; 

• Greening of Government Executive Orders; 

• EPA's CPGs for recovered content; 

• USDA's Biobased Purchasing Program; 

• ENERGY STAR® & DOE Federal Energy Management Program (FEMP) 

Product Efficiency Recommendations; 

• Energy Policy Act of 2005; 

• ASTM, LEED, Green Globes, and other rating systems and standards; and 

• Other “best practices” as determined via industry and public comment. 

One effort in particular, the Federal Leadership in High Performance and Sustainable Buildings 

MOU, guides 19 Federal agencies in the design, construction, and operation of buildings. 

 

91 The Green Building Initiative, “The GBI – A Better Way to Build.” Accessed July 18, 2007 at 

http://www.thegbi.org/gbi/whatwedo.asp. 

92 See details at: http://www.wbdg.org/design/greenspec.php. 
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Among other recommendations, the MOU guiding principles include reducing the environmental 

impact of materials; concrete with RMCs is consistent with this objective. E.O. 13423, 

“Strengthening Federal Environmental, Energy, and Transportation Management,” January 24, 

2007, expanded the applicability of the sustainable building MOU’s guiding principles from the 

19 MOU signatory agencies to all Federal agencies. 

Another effort, the Unified Facilities Guide Specifications (UFGS) is a joint effort of the U.S. 

Army Corps of Engineers, the Naval Facilities Engineering Command, and NASA. UFGS are 

for use in specifying construction for the military services. They include a guide specification 

for obtaining LEED certification, a general guide specification for referencing the EPAdesignated products, and guide specifications for using RMCs in concrete, including coal fly ash, 

ground iron blast furnace slag, and silica fume.93

5.1.5 Summary of Potential Mechanisms Related to Procurement Policies and Material 

Use Standards

Below, we summarize the potential set of mechanisms contained in the above discussion. As 

indicated, in some instances, a lead role can be played by EPA, OFPP, and OFEE as part of their 

Section 6002 facilitation efforts, while other mechanisms require collaboration across multiple 

agencies, or a lead role by procuring entities. In addition, certain mechanisms may merit 

statutory authorization. The potential mechanisms include: 

• Integrate and improve procurement systems, allowing for identification and 

tracking of cement and concrete purchases using RMCs and the RMC volumes 

utilized. As reporting systems allow, modify the RCRA agency data report to 

include more specific questions for agencies regarding their purchases and usage 

of RMCs in construction projects. 

• Review all available options for oversight with the implementation guidelines of 

the CPG. This may involve working to increase awareness of CPG requirements 

and products and to change the perception that CPG is not mandatory. As a 

related matter, clarify the CPG clauses to RMC use and other technical standards 

associated with RMC use. Other options may include a system of negative or 

positive recognition in the annual Federal budget process, and through relevant 

recognition programs. 

• Continue to work with other Federal agencies to implement policies favoring 

purchases of recycled materials. Several agencies (e.g., FHWA and DoD) already 

have such policies in place. In addition, increase outreach to vendors explaining 

the benefits to CPG material use. 

• Develop effective information resources to promote RMC use, including (1) 

update and maintain the CPG Supplier Database94 on a regular basis; (2) issue 

 

93 For more information, see: http://www.wbdg.org/ccb/browse_org.php?o=70. 

94 EPA's CPG Supplier Database is a searchable database of vendors who sell or distribute CPG-designated products 

with recycled content. This tool allows users to search for vendors of a specific CPG product, product category, or 
5-9

purchasing guidance documents RMANs recommending recovered material 

content ranges for CPG products based on the most recent information about 

commercially available products; and (3) develop other information tools as 

available resources allow. 

• Expand training and outreach with OFPP, OFEE, and various green purchasing 

programs to provide training to Federal agency contracting, purchase card, and 

program personnel,95 including more targeted training related to RMC 

procurement. 

• Identify and develop optimization protocols for improved performance and 

increased benefits while increasing RMC use in cement and concrete. 

• Continue to harmonize the AASHTO and ASTM standards. 

• Promote the use of ternary mixtures in the CPG providing the possibility of using 

both coal fly ash and slag cement 

• Continue to work with the Federal Environmental Executive and the WBDG to 

develop and promote the Federal Green Construction Guide for Specifiers. 

• Aid in multi-agency based efforts to integrate environmental building 

requirements into Federal, state, and local public building standards, including, 

for example, industry standards such as LEED being written into Federal, state, 

and local building standards. 

 

5.2 Education, Technical Assistance, and Recognition Programs 

Education, research, technology development, demonstration, and outreach programs have the 

potential to improve the understanding of RMCs and their benefits, and to promote their 

beneficial use. Numerous government agencies (e.g., FHWA, USDA, EPA) have noted how 

these types of programs can help address perceptions that RMCs and associated products are 

inferior or deleterious to health and safety, and how they can improve the information base on 

which economic and technical decisions are made. Likewise, industry representatives (National 

Ready Mixed Concrete Association (NRMCA), the SFA, Headwaters, Inc.) consulted for this 

study have emphasized the importance of education programs for ensuring that end users (e.g., 

local and state transportation agencies) understand the reliability of RMC-based products. 

Together with a number of industry, Federal, and state partners, EPA is undertaking a variety of 

research, education, and recognition efforts to increase RMC markets and use by improving the 

availability and flow of information about the beneficial use of a range of industrial materials. 

The discussion below examines several ongoing and prospective initiatives: 

 type of material. In addition, users can search directly for a specific vendor by typing all or part of the vendor’s 

name in a search field. 

95 See, for example, the training programs offered by OFEE at http://ofee.gov/gp/training.asp. 
5-10

• The EPA coal combustion products outreach efforts; 

• The EPA foundry sand outreach efforts; and 

• Recent industry and public/private collaborations and research. 

While the impact of these initiatives is still emerging, they illustrate programs EPA is conducting 

with the potential to increase the beneficial use of RMCs. 

5.2.1 EPA Coal Combustion Products Outreach Efforts 

 

The C2

P2 is a collaborative partnership program with EPA, DOE, FHWA, ACAA, USDA, EPRI, 

USWAG and more than 150 partners. This partnership is currently working towards two goals. 

The first goal is to increase the beneficial use of CCPs from 31% in 2001 to 50% in 2011. The 

second goal is to increase the use of coal fly ash in concrete from 14 million U.S. tons in 2002 to 

18.6 million U.S. tons by 2011. 

With other partners, EPA is undertaking a number of research, education, and recognition efforts 

to improve the availability and flow of information about the beneficial use of CCPs. For 

example, a 2005 publication created by EPA, DOE, ACAA, FHWA, and USWAG, “Using Coal 

Ash in Highway Construction: A Guide to Benefits and Impacts,” has helped to explain the 

environmental benefits and risks associated with the use of coal fly ash in construction 

applications. EPA also partnered with FHWA to write and publish, “Fly Ash Facts for Highway 

Engineers.” This technical guide document has been widely distributed. In addition, over the 

last several years, the C2

P2 partners have developed a set of projects to increase the amount of 

CCPs that are beneficially used. These projects include an awards program, which recognizes 

CCP users, as well as mechanisms designed to allow for a better understanding of the obstacles 

to the beneficial use of CCPs, and to identify both governmental and private initiatives to address 

these obstacles.96 Some of these activities include sponsoring workshops, publishing information 

materials, and participating in information exchange forums. 

The ACAA’s annual CCP Production and Use Survey is the primary measurement instrument for 

C2

P2 goals. EPA will report the amounts and types of CCPs reported by applicants to the C2P2

Awards Program. EPA works with ACAA to review the results of this survey, assessing trends 

in generation and beneficial use, with the ultimate goal of tracking the partners’ progress toward 

achieving the 50% CCP usage goal by 2011. Through publication of case studies, EPA 

highlights current practices that result in the successful use of CCPs. 

As previously noted, three state reviews have been conducted that examine CCP utilization 

practices and identify the specific factors that encourage or discourage the beneficial use within 

each state. These reviews bring together key stakeholders to discuss factors that affect increased 

CCP utilization. Upon completion of these reviews, EPA will compile the findings in a broader 

publication.97

 

96 In addition to C2

P2 projects, EPA’s regions have initiated their own projects that will also assist the beneficial use 

of CCPs. 

97 Texas and Florida reviews have been completed and released, and a review of Pennsylvania was completed in 

2007. 
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In collaboration with the C2P2 partners, EPA has also held two C2P2 award presentations to 

recognize those partners who have made exceptional progress in promoting the beneficial use of 

CCPs. The C2

P2 web includes fact sheets on project activities, as well as case studies, increasing 

the availability of information easily accessible online.98 Further research and technical 

assistance is available via the construction initiative, created in partnership with DOE, FHWA, 

states, trade associations, and other parties, to facilitate the beneficial use of RMCs in large 

construction projects. 

These collective efforts to increase the beneficial use of CCPs are likely helping to increase the 

amount of CCPs beneficially used each year. According to ACAA survey data, CCP beneficial 

use has increased from 32% in 2001 to 43% in 2006.99

5.2.2 EPA Foundry Sand Outreach Efforts 

EPA has initiated several efforts to increase the reuse of foundry sand. For example, EPA has 

compiled and published the 2002 Beneficial Use of Foundry Sand: A Review of State Practices 

and Regulations. In addition, EPA partnered with FHWA to write and publish, “Foundry Sand 

Facts for Civil Engineers.” This technical guide has been widely distributed. Moreover, EPA’s 

Sector Strategies Division published, State Toolkit for Developing Beneficial Reuse Programs 

for Foundry Sand, in July 2006 (Toolkit).100 Designed specifically to assist states that wish to 

develop or improve their foundry sand beneficial use programs, the Toolkit provides program 

options to states according to their desired preferences and available resources. Starting with a 

series of questions to help states determine what type of program to design, the Toolkit guides 

users through a three-stage, six-step roadmap for creating a foundry sand beneficial use 

program.101 The Toolkit was developed through multiple Foundry Sand stakeholder meetings in 

2005 and 2006. 

5.2.3 Other Public/Private Collaboration and Research 

A number of additional initiatives are being pursued by a variety of industry, not-for-profit, and 

governmental entities. We describe several such initiatives below. 

The Green Highways Partnership. The Green Highways Partnership (GHP) is a public/private 

effort established to incorporate environmental considerations into the design, construction and 

operation of roads, beginning with the Mid-Atlantic Pilot. Environmental considerations include 

practices, such as using RMCs when constructing roads and buildings. RMCs can be used in all 

aspects of road construction – as a base layer, in the pavement, and in embankments. The Green 

Highway Partnership is now expanding into a national program designed to emphasis the use of 

recycled materials in highway construction. This new effort should also help focus the 

engineering, environmental, and economic reasons to use RMCs102. 

 

98 The C2

P2 web site is at: http://www.epa.gov/epaoswer/osw/conserve/c2p2/. 99 For more facts on C2

P2, refer to http://www.epa.gov/epaoswer/osw/conserve/c2p2/pubs/facts508.pdf. 100 The Toolkit is available at: http://www.epa.gov/sectors/metalcasting/foundry.html, accessed November 14, 2006. 101 EPA has also published a document providing general information on foundry sand recycling which is available 

at: http://www.epa.gov/epaoswer/osw/conserve/foundry/foundry-st.pdf 102 Information on the Green Highways Partnership can be found at: http://www.greenhighways.org. 
5-12

FHWA has been instrumental in assisting EPA in making contacts with state highway officials. 

Starting in the mid-Atlantic region, EPA and FHWA have hosted several workshops for State 

environmental and transportation officials and road builders to exchange information and share 

success stories and concerns about RMCs in road building. 

The Federal Highway Administration (FHWA). The FHWA has been successful in 

promoting RMC use in road construction. Their research, development, and technology transfer 

efforts have been instrumental in advancing the use of RMCs in road projects. In addition, 

FHWA has recently undertaken a refocus of their recycling program with a stronger emphasis on 

environmental stewardship/leadership, which intends to address such items as CO2 gas reduction, 

National Green Highway Partnership, storm water management, and pollution reduction through 

improved pavement design. The Recycled Materials Policy established by the FHWA 

Administrator clearly links recycled materials (e.g., asphalt, concrete) to the preservation and 

improvement of the national highway system. 

FHWA has been conducting outreach to the road-building community (the states, local 

governments, and the construction industry) showing that the engineering feasibility of using 

RMCs has been demonstrated in research, field studies, experimental projects and long-term 

performance testing and analysis. In addition, to help foster the use of RMCs, the Administrator 

of the FHWA issued a national policy memorandum expressing the views of the Agency in this 

regard. 

In addition to the above, EPA and FHWA are working with representatives from several byproduct generators to cooperate on workshops and technical information needs in an effort to 

effectively increase the use of these materials in cement substitution, as well as other civil 

engineering applications. 

The Industrial Resources Council (IRC). IRC is an organization designed to promote the use 

of products, by-products, co-products or other non-hazardous materials in various industrial 

activities, focusing on advancing the management and use of these materials in ways that are 

environmentally responsible, technically sound, commercially competitive and publicly 

accepted. EPA is collaborating with this group, which includes: the Construction Materials 

Recycling Association (CMRA); ACAA; the Foundry Industry Recycling Starts Today (FIRST); 

the National Council for Air & Stream Improvement (NCASI); NSA; SCA; and the Rubber 

Manufacturers Association (RMA). The goals of the IRC are to: 

• Stimulate the transfer of information related to the recovery, use, reuse and 

recycling of industrial resources that can be used by planners, designers, 

specifiers, regulators, purchasers, manufacturers and constructors or other 

stakeholders; 

• Participate in the development of appropriate codes, specifications and guides for 

the use of these industrial resources on par with competing materials and 

products; 
5-13

• Facilitate awareness and understanding of the environmental, economic, 

engineering, manufacturing and societal benefits derived from the recovery, use, 

reuse and recycling of industrial materials; and 

• Share experiences of effective strategies that lead to increased utilization of these 

industrial materials, including changes in codes, guides and specifications. 

The Silica Fume Association (SFA). Industry members are spearheading educational efforts to 

address concerns about the utilization of silica fume. For example, Midwest contractors have 

reported finishing silica fume concrete parking decks at 85% of the cost of conventional concrete 

using the single-pass finishing technique. In addition, FHWA’s publication IF-05-016, “Silica 

Fume User’s Manual,” includes a chapter of “how to” contractor training. SFA supports this 

chapter with educational videos in an effort to train contractors on how to properly and 

economically use silica fume concrete (Kojundic, 12/13/2006). Together, these efforts could 

help address the concerns of contractors resistant to using non-virgin materials. 

The Recycled Materials Resource Center (RMRC). RMRC is a national center that promotes 

the appropriate use of secondary materials, including waste materials and by-product materials, 

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. 

The Center has a unique role in the growing field of recycled materials use in highway 

construction—to serve as a catalyst to reduce barriers to the appropriate use of recycled 

materials. The Center seeks to provide a cohesive approach to the complex engineering and 

environmental issues surrounding the use of recycled materials, and to serve as a principal 

outreach organization and evaluator of information, as well as the principal point of contact for 

information. 

The mission of the Center is to promote activities designed to ensure that: 

• policymakers at the federal, state, and local levels have the education and technical 

information needed to formulate policy permitting recycled materials to be considered on 

equal footing with conventional construction materials; 

• a voice dedicated to informing persons that recycled materials exist is present in each of 

the technical organizations associated with transportation infrastructure; 

• existing information on recycled materials is organized and structured into standards, 

specifications, and typical engineering properties that can be used directly by the design 

and construction community; 

• new and innovative applications of recycled materials are continuously developed; and, 
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• industries and transportation agencies have the logistical tools needed to connect sources 

of recycled materials, applications in the transportation infrastructure, and entities 

involved in supply/delivery. 

The RMRC is committed to increasing the wise use of recycled materials and will be working to 

track various metrics of its impact and resulting changes in recycled materials use in the coming 

years 

5.2.4 Summary of Potential Mechanisms Related to Education, Technical Assistance, and 

Recognition Programs

Below we summarize the potential set of mechanisms related to the above discussion. As 

indicated, in some instances, a lead role can be played by EPA and FHWA as part of their 

facilitation efforts, while other mechanisms require collaboration across multiple public and 

private entities. The potential mechanisms include: 

• Support and expand the C2

P2 program, as well as continue EPA foundry sand 

outreach efforts. 

• Continue and expand collaboration with DOT on the Green Highways 

Partnership, incorporating environmental streamlining and stewardship efforts 

into all aspects of the highway lifecycle. Continue and expand collaborative work 

with DOE on increased CCP use. 

 

• Work with the IRC to promote the use of products, by-products, co-products or 

other non-hazardous materials in various industrial activities. 

• Work with industry members and trade associations to address barriers. 

• Conduct additional state reviews to foster a broader understanding RMC 

utilization practices. 

• Publicize the energy savings and GHG reductions achievable through RMC use. 

• Pursue ways to change the perception that anything that was a by-product or 

waste from an industrial process does not or cannot have the same quality 

attributable to a virgin or manufactured material. 

• Expand current research and data collection efforts. Among other research 

efforts, RMRC and FHWA are conducting ongoing research on the beneficial use 

of RMCs in highway construction projects. These efforts include primary 

research of material specifications and guidance on their use. 

(www.fhwa.dot.gov/pavement/recycling) 

• Pursue a collaborative government-industry research effort to develop concrete air 

entrainment additives that are compatible with coal fly ash generated by mercury-
5-15

compliant power plants. EPA and OFEE are well positioned to convene 

government agencies, the concrete industry, and the electrical power industry to 

jointly sponsor such research. 

• Increasing EPA outreach and assistance to the coal combustion industry to foster 

use of mercury controls such that the recyclability of ash is not jeopardized. From 

developing the mercury standards, EPA’s Office of Air and Radiation is wellpositioned with the technical awareness and industry relationships needed to 

mount a program of assistance. Explore new pollution control technologies for 

mercury emissions that do not render coal fly ash potentially unsuitable for 

beneficial use. 

• Continue to review and analyze life cycle performance and risk assessments of 

RMC use in cement and concrete. 

5.3 Economics 

Chapter 4 (Barriers to Increased RMC Substitution) highlights a variety of economic factors that 

influence RMC substitution levels. As noted in that chapter, the market for RMCs is 

characterized by small price differences. In addition, the perceived cost savings potentially 

enjoyed by producers and consumers of RMCs can be limited by the regional variation in the 

supply of RMCs and transportation costs and constraints. Even where cost savings exist, they 

may not be deemed sufficient to overcome potential externalities and justify changes in practice. 

This may occur as a result of barriers related to misinformation, quality concerns, and standard 

operating procedures that may constrain their use. 

Given these market complexities, it is relevant to consider specifically whether and how 

economic mechanisms implemented by Federal, state, or local governments could potentially 

motivate increased levels of RMC substitution by minimizing any negative externalities 

associated with increased RMC use. Particularly with respect to the substantial GHG benefits 

associated with the use of CCPs, the development of targeted tax credits or accelerated 

depreciation for necessary infrastructure would be beneficial. 

On a basic level, an economic influence in this context would seek to reduce the price of 

concrete manufactured with RMCs relative to concrete manufactured using virgin materials. In 

theory, these incentives could be applied anywhere along the material flow of concrete and 

concrete inputs - at the virgin material or RMC production phase; at the manufacturing phase; or 

at the end-user phase. The discussion below focuses on transportation funding mechanisms and 

various other incentives for RMC users. 

5.3.1 Transportation Funding Mechanisms 

Economic influences aimed at reducing the effective price of RMC substitution could rely on a 

variety of tax credits and other incentive mechanisms. At the project level, the Federal 

government could use matching requirements for federally funded highway construction projects 

to encourage the use of RMCs by reducing any perceived externalities of RMC use by the 
5-16

project’s contractors. For most Federally-funded highway projects, Federal law requires states or 

localities to match a certain percentage of the construction funds provided by the Federal 

government. In an effort to encourage greater RMC use, this percentage could be reduced for 

those projects meeting RMC substitution targets. Improved data collection is critical to the 

success of transportation funding mechanisms. 

5.3.2 Mechanisms for Increased Industry RMC Use 

Another set of economic mechanisms would directly sponsor industry in ways that encourage the 

beneficial use of RMCs. Examples of approaches that would influence the behaviour and 

decisions of cement producers and other RMC users include the following: 

• The introduction of tax credits or accelerated depreciation for installed equipment 

could enable continued and expanded rates of beneficial use of RMCs. For example, 

tax credits for investment in slag granulation capacity could help address lower U.S. 

granulation rates (as noted by SCA). 

• Industry observers (e.g., SFA) recommend that when awarding Federal projects, 

Federal agencies give weighted financial credit to concrete firms practicing the 

beneficial use of RMCs. This could include the exploration of other various incentive 

mechanisms, such as tax deductions or credits for firms that meet RMC substitution 

targets. 

• Further research and development (R&D) on the substitution of RMCs could make 

RMC use more economically viable. Potential incentives for increased R&D on 

RMC use could include tax breaks or credits of varying sizes depending on the 

amount of resources expended by each firm. 

• Promote the increased use of “green bonds” that are tax-exempt when used for 

qualified green building and sustainable design projects, as designated by the 

Secretary of the Treasury and the EPA Administrator.103 Under Section 701 of the 

American Jobs Creation Act of 2004, up to $2 billion of the bonds can be awarded. 

• Within the context of the potential development of a carbon dioxide cap and trade 

program, consider how emissions credits could be applied toward RMC use. 

• Encourage utilities and coal ash marketers to increase utilization rates by investing in 

storage and distribution assets that increase the availability and reliability of coal fly 

ash supplies in construction markets. Investment tax credit and/or the accelerated 

depreciation of capital expenditures for these types of investments would send an 

economic signal favoring utilization over disposal. 

 

103 Provus, Stan. “CDFA Spotlight: Green Bonds,” July 2005, 

http://www.cdfa.net/cdfa/cdfaweb.nsf/pages/july2005tlc.html. 
5-17

5.3.3 Caveats 

Any potential economic mechanisms discussed in this section would be subject to relevant 

statutory, regulatory, and budgetary constraints and considerations. The transportation funding 

and tax related incentives presented in this section are for Congressional consideration only. We 

recognize that the Department of Transportation does not currently have the legal authority to 

use transportation funding mechanisms to help increase RMC use. In addition, many of these 

mechanisms would likely require improved data collection on materials used in Federal 

construction projects, and additional information regarding documentation of inventories and 

annual production of various RMCs. 
6-1 

6.0 CONCLUSIONS 

This study provides information in response to specific provisions in the SAFETEA- LU. 

Consistent with the statutory direction, this report addresses the following issues: 

(A) Quantify (i) the extent to which recovered mineral components are being 

substituted for portland cement, particularly as a result of current procurement 

requirements, and (ii) the energy savings and environmental benefits associated 

with that substitution; 

(B) Identify all barriers in procurement requirements to greater realization of energy 

savings and environmental benefits, including barriers resulting from exceptions 

from current law; and 

(C) (i) Identify potential mechanisms to achieve greater substitution of recovered 

mineral component in types of cement or concrete projects for which recovered 

mineral components historically have not been used or have been used only 

minimally; (ii) evaluate the feasibility of establishing guidelines or standards for 

optimized substitution rates of recovered mineral component in those cement or 

concrete projects; and (iii) identify any potential environmental or economic 

effects that may result from greater substitution of recovered mineral component 

in those cement or concrete projects. 

With respect to the first question – the degree of beneficial use and its impact – we identify 

several conclusions: 

• Volumes of RMCs being substituted for portland cement. For the four 

congressionally-identified RMCs, along with the additional eight RMCs identified 

by EPA for further evaluation, we document current production or sales, and 

generally capture or estimate usage rates, which are generally indicative of the 

extent of substitution. While data quality varies across RMCs, several materials 

show relatively high rates of substitution; these include RMCs, such as blast 

furnace slag and silica fume. Substitution rates for other high-quantity RMCs, 

such as coal fly ash, are lower. 

• Substitution resulting from current procurement requirements. For all of the 

RMCs, complete procurement data are unavailable to estimate the total volume of 

RMCs used in Federal concrete projects. It follows that these information gaps 

preclude the Agency from establishing a causal relationship between the CPG and 

levels of RMC substitution in Federal concrete projects. Despite these data 

limitations, we have identified a number of successful efforts on the part of 

procuring agencies to purchase products with RMCs. The lack of a 

comprehensive information resource related to RMC procurement primarily 

results from disparate and incomplete procurement data systems, reporting 

burdens, and lack of reporting compliance. Improvements in procurement data 
6-2 

systems and reporting would allow a better understanding of the incremental 

effects of procurement requirements for cement and concrete projects.

• Energy savings and environmental benefits associated with substitution. 

RMC use yields positive environmental benefits through lower resource 

consumption. To overcome the procurement data limitations noted above, for 

GGBFS, coal fly ash, and silica fume, we derive estimates of their use in Federal 

projects by roughly apportioning total volumes to Federal and non-Federal 

projects (based upon the estimated proportion of total cement demand related to 

federally-funded projects). For the years 2004 and 2005, our life cycle analysis 

indicates that the use of GGBFS and coal fly ash in Federal concrete projects 

alone resulted in significant reductions of GHG emissions, criteria air pollutants, 

and energy and water use. For these two years combined, the analysis suggests 

reduced energy use of 31.5 billion megajoules, avoided CO2 equivalent air 

emissions of 3.8 million metric tons, and water savings of 2.1 billion liters. We 

further illustrate how these benefits may accrue over a longer time period 

(through 2015) given alternative use scenarios. This aspect of the analysis also 

links to issue C (iii) noted above.

With respect to the issues identified under parts (B) and (C), the report identified a number of 

barriers which impede the beneficial use of RMCs through procurement requirements. A variety 

of potential mechanisms exist for addressing these barriers. Specifically: 

• Procurement policies and material standards initiatives, including an ongoing 

assessment and refinement of EPA’s CPGs, refinement of engineering standards 

governing the substitution of RMCs, and development and application of green 

building standards. 

• Education, technical assistance, and recognition programs, such as the Green 

Highways Partnership, EPA’s foundry sand outreach efforts, and public/private 

partnerships, such as C2

P2 encourage the beneficial use of CCPs; in addition, 

ongoing research and pilot projects are critical to advancing the use of RMCs. 

• Economic influences, such as using transportation funding mechanisms to 

increase RMC use and providing tax credits, accelerated depreciation, tax-exempt 

bonds and other influences related to various components of the RMC generation 

and use chain. 

Table 6-1 summarizes the barriers itemized in Chapter 4 and characterizes the linkages with the 

possible mechanisms for increasing the use of RMCs and these barriers. These linkages are 

complex, covering a spectrum of stronger and weaker barriers coupled with a suite of potential 

mechanisms of varying effectiveness given a particular context. For example, in instances where 

the use of an RMC is cost prohibitive (for example, where it is in short supply or requires 

extensive transport), it is unlikely that adjustments to the procurement guidelines or technical 

assistance programs would substantially affect the RMC's utilization. In contrast, these 

mechanisms may be more effective in instances where barriers related to perceptions of material 
6-3 

performance or standard operating procedures are present. As another example, EPA’s efforts in 

C2P2 are primarily focused on outreach and technical assistance. However, C2P2 also includes 

research to advance coal fly ash uses; therefore, technical or economic barriers could be partly 

addressed by a program that is largely an education initiative. Similarly, EPA’s foundry sand 

program includes guidance for states on creating foundry sand beneficial use programs, directly 

influencing procurement/contractual barriers. 

With respect to barriers in procurement requirements, we have noted several concerning data 

reporting, material specifications and standards, contract and bidding procedures, and general 

program awareness. Anecdotal information indicates that these barriers may contribute, in some 

instances, in not using RMCs in making procurement decisions. As noted in Chapter 5, a wide 

range of mechanisms are applicable to these issues. Furthermore, to implement these 

mechanisms fully will require broad participation and effort on the part of federal, state, and 

private entities. 
6-4 

Table 6-1: Summary of Barriers and Mechanisms for Increasing Beneficial Use of RMCs 

Barrier Category Barrier 

Applicable Types of 

Mechanisms Example Applications of Specifi

Transportation costs and geographic distribution RMC as minor component of producers overall revenue Poor cost-effectiveness of RMC utilization 

Economic Barriers 

Low cost of RMC disposal 

 Economic incentives  Procurement policies and 

building standards 

 Education, technical 

assistance, and recognition 

Economic: Fees to increase cost of RMC dbeneficial use incentives. Procurement: In general, CPGs help promRMCs and increase beneficial use. Howevcollection would allow assessment of CPG refinement of CPG. Education: C2P2 research helps identify ar

shortages, helping address geographic dist

Federal air pollution regulations State and Federal solid waste regulations 

Legal, Regulatory, and Contractual Barriers 

Bidding procedures and contractual constraints 

 Procurement policies and 

building standards 

 Education, technical 

assistance, and recognition 

Procurement: Integrate green building stastate, and local procurement policies to beRMC-based products. Education: EPA’s foundry sand program development of beneficial use programs. 

Performance of products containing RMCs Acceptance of materials specifications 

Technical Barriers 

Variation in the quality of RMC supplies 

 Education, technical 

assistance, and recognition 

 Economic incentives 

Education: Establish baseline data and gouse rates (e.g., coal ash under EPA’s C2P2)

Economic: Sponsor and/or conduct researminimize variation in RMC quality. Research: Ongoing 

Safety and Health Risk Perception Barriers 

Perceived risk associated with products containing RMCs 

 Education, technical 

assistance, and recognition 

Education: As a means of increasing acceusers regarding risks associated with RMC
 R-1 

REFERENCES 

American Coal Ash Association (ACAA), 2006. “Coal Combustion Product (CCP) Production 

and Use Survey”. 

American Coal Ash Association (ACAA), 2005. “Coal Combustion Product (CCP) Production 

and Use Survey”. 

American Coal Ash Association (ACAA), 2004. “Coal Combustion Product (CCP) Production 

and Use Survey”. 

American Coal Ash Association (ACAA), 2003. “Coal Combustion Product (CCP) Production 

and Use Survey”. 

American Coal Ash Association (ACAA), 2002. “Coal Combustion Product (CCP) Production 

and Use Survey”. 

American Coal Ash Association (ACAA), 2001. “Coal Combustion Product (CCP) Production 

and Use Survey”. 

American Concrete Institute (ACI), 2006. “Guide for the Use of Silica Fume in Concrete, ACI 

234R-06” 

American Foundry Society, Undated. http://www.afsinc.org/

Arnold, Dana, 2006. Office of the Federal Environmental Executive. Personal Communication. 

Chizmadia, Tom, 2006. Holcim Cement. Personal Communication. 

Corathers, L.A., 2004. “USGS 2004 Minerals Yearbook: Volume I--Metals and Minerals: 

Silicon”. 

Electric Power Research Institute (EPRI), December 1992. “Institutional Constraints to Coal Fly 

Ash Use in Construction.” Palo Alto, CA. 

Energy & Environmental Research Center (EERC), July 1999. “Barriers to the Increased 

Utilization of Coal Combustion/Desulfurization By-Products by Government and Commercial 

Sectors - Update 1998.” EERC Topical Report DE-FC21-93MC-30097--70. Grand Forks, ND. 

Energy and Environment Research Center (EERC), January 2005. Review of Texas Regulations, 

Standards, and Practices Related to the Use of Coal Combustion Products. 2005-EERC-01-01. 

University of North Dakota, Grand Forks, ND. 

Energy and Environment Research Center (EERC), April 2006. Review of Florida Regulations, 

Standards, and Practices Related to the Use of Coal Combustion Products. 2006-EERC-04-03. 

University of North Dakota, Grand Forks, ND. 
 R-2 

Founie, Alan, 2004. “USGS 2004 Minerals Yearbook: Volume I--Metals and Minerals: 

Gypsum.” 

Foundry Industry Recycling Starts Today (FIRST), 2006. On-line information accessed October 

2, 2006 at http://www.foundryrecycling.org/org/whatis.html

Goss, Dave, 2006. American Coal Ash Association. Personal Communication. 

Hg-CCP dialogue mtg. sum Final Draft. 1-14-08. RPA Meeting with the Utility Industry and 

ACAA to Discuss Repercussions of CAMR on the beneficial use of CCPs/EEI’s HQs, 

Washington DC, 8/30/07. 

 

IEA Clean Coal Centre, January 2005. “Cement and Concrete – Benefits and Barriers in Coal 

Ash Utilization.” 

Kalyoncu, R.S., 2001. “USGS 2001 Minerals Yearbook: Volume I--Metals and Minerals: SlagIron and Steel” 

Kiggins, Karen, December 20, 2007. Email Communication from Karen Kiggins (National Slag 

Association) to Anthony Carrell (US EPA) 

Kojundic, T, 2006. Email Communication from Tony Kojundic, Silica Fume Association on 

8/30/2006. 

Kojundic, T, 2006. Email Communication from Tony Kojundic, Silica Fume Association on 

12/13/2006. 

Kosmatka, S., Kerkhoff, B. and Panarese, W., 2002.”Design and Control of Concrete Mixtures, 

Fourteenth Edition. Portland Cement Association, Skokie, IL. 

Lehman, Richard, October 3, 2007. Email Communication from Rich Lehman (Edw. C Levy 

Co.) and Karen Kiggins (National Slag Association) to Anthony Carrell (US EPA) presenting 

comments on the September 20, 2007 draft of the Report to Congress. 

Lipiatt, Barbara C., 2002. "BEES 3.0 Technical Manual and User Guide." National Institute for 

Standards and Technology, Gaithersburg, MD. 

Lobo, Colin, 2006. National Ready Mixed Concrete Association. Personal Communication. 

Moulton, L.K., 2003. “Bottom Ash and Boiler Slag,” Proceedings of the Third International Ash 

Utilization Symposium. U.S. Bureau of Mines, Information Circular No. 8640, Washington, DC. 

Mullarky, John, 2006. U.S. Department of Transportation, Federal Highways Administration. 

Personal Communication. 
 R-3 

Portland Cement Association (PCA), 2003. “Concrete Builds the Sustainable Movement”. 

Cooperative publication involving PCA, Concrete Reinforcing Steel Institute, and Precast 

Concrete Institute. First published in Building Design& Constructions’ September 2003 Issue. 

Portland Cement Association, 2004. "2004 Apparent Use of Portland Cement by Market." 

Skokie, IL. 

Portland Cement Association (PCA), July 2005. “Iron and Steel Byproducts: Portland Cement 

Association Sustainable Manufacturing Fact Sheet.” Accessed October 18, 2006 at 

http://www.cement.org/pdf_files/is326.pdf 

Portland Cement Association (PCA), July 2005b. “Power Plant Byproducts: Portland Cement 

Association Sustainable Manufacturing Fact Sheet.” Accessed October 18, 2006 at 

http://www.cement.org/pdf_files/is331.pdf 

Portland Cement Association (PCA), 2006. “Report on Sustainable Manufacturing.” Accessed 

October 16, 2006 at http://www.cement.org/smreport06/index.htm

Portland Cement Association (PCA), 2006a. “Long-Term Cement Consumption Outlook” 

Portland Cement Association (PCA), 2006b. “Summary of 2006 Cement Kiln Dust and Clinker 

Production” State Summaries 2006. 

Proctor, D.M. et. al. 2000. “Physical and Chemical Characteristics of Blast Furnace, Basic 

Oxygen Furnace, and Electric Arc Furnace Steel Industry Slags,” Environmental Science & 

Technology. Vol. 34, No. 8, 2000. pp. 1576-1582. 

Proctor, Deborah M., et. al. 2002. “Assessment of Human health and Ecological Risks Posed by 

the Uses of Steel-Industry Slags in the Environment,” Human and Ecological Risk Assessment. 

Vol. 8, No. 4, 2002. pp. 681-711. 

Prusinski, Jan R. 2006. Slag Cement Information for EPA Mineral Recycling Report to 

Congress. Slag Cement Association, May 2006. 

Pulipaka, Aswani S., J.M. Parker, and S.D. Kohn. (undated). “Blast Furnace Slag Aggregate in 

Concrete Construction.” Soils and Materials Engineers, Inc., Plymouth, MI. 

U.S. Department of Energy (DOE), July 1994. “Barriers to the Increased Utilization of Coal 

Combustion/Desulfurization Byproducts by Governmental and Commercial Sectors.” Office of 

Fossil Energy, Morgantown, WV. 

U.S. Department of Energy (DOE), 2001. Letter from Department of Energy, Washington, D.C., 

October 29, 2001 to U.S. EPA. 
 R-4 

U.S. Department of Energy (DOE), 2004. EIA-860 data file “Existing Generating Units in the 

United States by State, Company and Plant, 2004”, newunits2004-1.xls available at 

http://www.eia.doe.gov/cneaf/electricity/page/eia860.html 

U.S. Department of Energy (DOE), 2004b. “Annual Steam-Electric Plant Operation and Design 

Data”. EIA-767 data files available at http://www.eia.doe.gov/cneaf/electricity/page/eia767.html

U.S. Department of Transportation, Federal Highway Administration (FHWA), April 1998. 

“User Guidelines for Waste and By-Product Materials in Pavement Construction.” FHWA-RD97-148. Turner-Fairbank Highway Research Center, McLean, VA. 

U.S. Department of Transportation, Federal Highway Administration (FHWA), May, 2004. 

“Foundry Sand Facts for Civil Engineers”. 

U.S. Department of Transportation, Federal Highway Administration (FHWA), April 2005. 

“Silica Fume Users Manual” 

U.S. Environmental Protection Agency (U.S. EPA), December 1993. “Report to Congress on 

Cement Kiln Dust: Method and Findings.” EPA530-R-94-001. 

U.S. Environmental Protection Agency (U.S. EPA), February 7, 1995. “Regulatory 

Determination on Cement Kiln Dust; Final Rule.” 60 Federal Register 7366. 

U.S. Environmental Protection Agency (U.S. EPA), 1998. “Metal Casting Industry Sector 

Notebook.” U.S. EPA, Office of Compliance. 

U.S. Environmental Protection Agency (U.S. EPA), 2002. Beneficial Reuse of Foundry Sand: A 

Review of State Practices and Regulations. U.S. EPA Office of Policy, Economic, and 

Innovation. 

U.S. Environmental Protection Agency (U.S. EPA), 2003. CPG4: Construction Products – 

Cement and Concrete Containing Cenospheres. 

U.S. Environmental Protection Agency (U.S. EPA), 2005. “Using Coal Ash in Highway 

Construction: A Guide to Benefits and Impacts”, EPA 530-K-05-002. 

U.S. Environmental Protection Agency (U.S. EPA), 2005b. Summary of Notes from EPA/PCA 

Alternative Fuels and Raw Materials Workshop, July 20, 2005. 

U.S. Environmental Protection Agency (U.S. EPA), 2005c. Regulatory Impact Analysis for the 

Final Clean Air Interstate Rule. EPA-425/R-05-002, March 2005. 

U.S. Environmental Protection Agency (U.S. EPA), 2005d. “Control of Mercury Emissions from 

Coal Fired Utility Boilers: An Update.” U.S. EPA, Air Pollution and Control Division, National 

Risk Management Research Laboratory, Office of Research and Development. 
 R-5 

U.S. Environmental Protection Agency (U.S. EPA), January 2006. “Characterization of 

Mercury-Enriched Coal Combustion Residues from Electric Utilities Using Enhanced Sorbents 

for Mercury Control.” EPA/600/R-06/008. F. Sanchez, R. Keeney, D. Kosson, R. Delapp, and S. 

Thorneloe. 

U.S. Environmental Protection Agency (U.S. EPA), August 14, 2007. Office of Solid Waste. 

Waste and Materials-Flow Benchmark Sector Report: Beneficial Use of Secondary Materials – 

Foundry Sand. 

U.S. Geological Survey, 2001. “Mineral Commodity Summaries 2001”, U.S. Government 

Printing Office, Washington, D.C. 

U.S. Geological Survey, 2002. “Mineral Commodity Summaries 2002”, U.S. Government 

Printing Office, Washington, D.C. 

U.S. Geological Survey, 2003. “Mineral Commodity Summaries 2003”, U.S. Government 

Printing Office, Washington, D.C. 

U.S. Geological Survey, 2004. “Mineral Commodity Summaries 2004”, U.S. Government 

Printing Office, Washington, D.C. 

U.S. Geological Survey, 2005. “Mineral Commodity Summaries 2005”, U.S. Government 

Printing Office, Washington, D.C. 

U.S. Geological Survey, 2006. “Mineral Commodity Summaries 2006”, U.S. Government 

Printing Office, Washington, D.C. 

van Oss, H.G., 2001. “USGS 2001 Minerals Yearbook: Volume I--Metals and Minerals: 

Cement” 

van Oss, H.G., 2002. “USGS 2002 Minerals Yearbook: Volume I--Metals and Minerals: SlagIron and Steel” 

van Oss, H.G., 2002b. “USGS 2002 Minerals Yearbook: Volume I--Metals and Minerals: 

Cement” 

van Oss, H.G., 2003. “USGS 2003 Minerals Yearbook: Volume I--Metals and Minerals: SlagIron and Steel” 

van Oss, H.G., 2003b. “USGS 2003 Minerals Yearbook: Volume I--Metals and Minerals: 

Cement” 

van Oss, H.G., 2004. “USGS 2004 Minerals Yearbook: Volume I--Metals and Minerals: 

Cement”, accessed October 2, 2006, via 

http://minerals.usgs.gov/minerals/pubs/commodity/cement/cemenmyb04.pdf
 R-6 

van Oss, H.G., 2004b. “USGS 2004 Minerals Yearbook: Volume II--Metals and Minerals: SlagIron and Steel”, accessed October 2, 2006, via 

http://minerals.usgs.gov/minerals/pubs/commodity/cement/cemenmyb04.pdf

van Oss, H.G., 2005. “Background Facts and Issues Concerning Cement and Concrete Data, U.S. 

Geological Survey Open-File Report 2005-1152: Version 1.2”, accessed October 2, 2006, via 

http://pubs.usgs.gov/of/2005/1152/2005-1152.pdf

van Oss, H.G., July 2006. Personal communication. 

van Oss, H.G., September 27, 2007. Personal communication 

Wagaman, T., 2006. National Slag Association. Personal contact 

Winkler, E.S. and Bolshakov, A.A., 2000. “Characterization of Foundry Sand Waste.” Chelsea 

Center for Recycling and Economic Development, University of Massachusetts at Lowell. 

World Business Council for Sustainable Development (WBCSD), June, 2005. “The Cement 

Sustainability Initiative Progress Report.” Geneva, Switzerland. 
G-1 

GLOSSARY 

The following terminology is used throughout this report. 

Aggregate

A rock material such as sand, gravel, or crushed rock with which cement or bitumen is mixed to 

form a mortar or concrete. 

Air-Cooled Blast Furnace Slag 

(see Blast Furnace Slag Aggregate) 

Alkali-Silica Reaction 

A concrete pathology due to chemical reactionsinvolving reactive silica from reactive aggregates 

and the inner solution of concrete. Main effects are swelling, cracking, and reduction in the 

mechanical properties of affected concretes. 

Ash Reburn 

Either fly ash or bottom ash or a mixture of both is added in a fine particle condition to the 

furnace of a pulverized coal boiler in a small proportion to the pulverized coal fed to the furnace. 

The fuel value that remains in the high carbon coal ash is utilized for heat and steam generation, 

and the ash is transformed from a material that must be landfilled to one that can be sold and 

utilized. 

Beneficiation 

The second step in hard rock mining (extraction being the first); it is the initial attempt at 

liberating and concentrating the valuable mineral from the extracted ore. Includes the following 

activities: crushing, grinding, washing, dissolution, crystallization, filtration, sorting, sizing, 

drying, sintering, pelletizing, briquetting, calcining to remove water and/or carbon dioxide, 

roasting in preparation for leaching, gravity concentration, magnetic separation, electrostatic 

separation, flotation, ion exchange, solvent extraction, electrowinning, precipitation, 

amalgamation, and heap, dump, vat, tank, and in situ leaching. 

Blast Furnace Slag 

Produced during the production of iron from iron ore when slagging agents (primarily limestone 

or dolomite) or fluxing materials are added to iron ores in blast furnaces to remove impurities 

from iron ore. In this process of reducing iron ore to iron, the molten slag forms as a non-metallic 

liquid that floats on top of the molten iron. The molten slag is then separated from the liquid 

metal and cooled. 

Blast Furnace Slag Aggregate 

Blast furnace slag aggregate (BFSA), also referred to as air-cooled blast furnace slag (ACBFS), 

is produced by allowing the molten slag from iron production to cool and solidify slowly under 

atmospheric conditions. Once cooled, it is crushed, screened and used as aggregate in 

applications such as base, concrete, asphalt, rail ballast, roofing, shingle coating, and glass 

making. 
G-2 

Boiler Slag 

Boiler slag is a byproduct from the combustion of coal in power plants. It is melted and fused 

particles of ash that collect on the bottom of the boiler. Slag forms when operating temperatures 

exceed ash fusion temperature. 

Bottom Ash 

Bottom ash (also called power plant bottom ash) is the coarse, solid mineral residue that results 

from the burning of coal in utility boilers. Bottom ash does not melt and therefore remains in the 

form of unconsolidated ash that settles on the bottom of a boiler. 

Carbon Burnout 

A process that combusts fly ash with high carbon, using that carbon as fuel, and produces a 

premium quality fly ash that can be readily sold to concrete ‘ready-mix’ facilities.

Cement Kiln Dust 

The fine-grained, solid, highly alkaline material removed from cement kiln exhaust gas by air 

pollution control devices. Much of the material comprising CKD is actually unreacted raw 

material, including raw mix at various stages of burning and particles of clinker. 

Cementitious

Having the property of or acting like cement. 

 

Cenospheres 

Very small (10 to 350 microns in diameter), inert, lightweight, hollow, “glass” spheres composed 

of silica and alumina and filled with air or other gases. They occur naturally in coal fly ash and 

are recovered from the ash for use as aggregate (filler) in concrete production. 

CERCLA 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980, also known 

as Superfund. 

Char 

To reduce to carbon or charcoal by incomplete combustion.

Clinker 

Clinker is an intermediate product of hydraulic cement manufacture. Clinker is produced in a 

kiln and consists of semifused nodules that contain a controlled and intimate mix of clinker (or 

cement) minerals. Portland cement clinker consists, chiefly, of the four minerals tricalcium 

silicate (C3S), dicalcium silicate (C2S), tricalcium aluminate (C3A), and tetracalcium 

aluminoferrites (C4AF). Clinker is finely ground to make finished cement; in the case of cement, 

the clinker is interground with a small amount of gypsum and/or anhydrite. 

Coal Combustion Products (CCPs) 

The materials produced primarily from the combustion of coal as a part of the coal fired power 

plants operating processes. CCPs include fly ash, bottom ash, boiler slag, flue gas 

desulfurization materials, and other types of material such as fluidized bed combustion ash, 
G-3 

cenospheres, and scrubber residues. The characteristics and physical properties of CCPs vary. 

In general, the size, shape, and chemical composition of these materials determines their 

beneficial reuse as a component of building materials or as a replacement to other virgin 

materials such as sand, gravel, or gypsum.

Comprehensive Procurement Guidelines 

Program authorized by Congress under Section 6002 of RCRA and Executive Order 13101 that 

requires EPA to designate products that are or can be made with recovered materials, and to 

recommend practices for buying these products. Once a product is designated, procuring 

agencies are required to purchase it with the highest recovered material content level practicable. 

Concrete 

Concrete is a building material made by mixing a cementing material (such as portland cement) 

along with aggregate (such as sand and gravel) with sufficient water and additives to cause the 

cement to set and bind the entire mass. 

Cyclone Boiler 

A coal combustion technology that creates a cyclone-like air circulation pattern causing smaller 

particles to burn in suspension, while larger particles adhere to a molten layer of slag that forms 

on the barrel walls. 

Flotation 

A process in which the minerals floated gather in and on the surface of bubbles of air or gas 

driven into or generated in the liquid in some convenient manner. 

Flue Gas Desulfurization

Process and technologies by which sulfur oxides are removed from flue gas (the gaseous 

products of combustion that exit a boiler through a flue or stack) after combustion. 

Fluidized-Bed Combustion (FBC) 

A coal combustion process in which fuel is burned on a bed of incombustible material (e.g., sand 

and limestone) while combustion air is forced upward at high velocities, making the particles 

flow as a fluid. 

Fluxing Materials

A material used to remove undesirable substances as a molten mixture. It may also be used to 

prevent the formation of, or to dissolve and facilitate the removal of, oxides and other 

undesirable substances. 

Coal Fly Ash 

Coal fly ash is the finely divided mineral residue that results from the combustion of ground or 

powdered coal in coal-fired power plants. It consists primarily of glassy, spherical particles 

comprised of silicon, aluminum, iron, calcium, and magnesium. The majority of the fly ash 

generated by combustion is removed from stack emissions using electrostatic precipitators or 

fabric-filter bag houses. Some varieties of fly ash are useful as pozzolans or SCM and others can 

be used as raw material for clinker manufacture and as fine-grained construction aggregates. 
G-4 

Foundry Sand 

High quality silica sand that is a byproduct from the production of both ferrous and nonferrous 

metal castings. The physical and chemical characteristics of foundry sand depend on the type of 

casting process and industry sector from which it originates. 

Granulated Blast Furnace Slag 

A sand-sized glassy, granular product produced during the production of iron from iron ore. It is 

formed by quickly quenching (chilling) molten slag. Can be ground very finely into ground 

granulated blast furnace slag (GGBFS) giving it moderate hydraulic cementitious properties. 

High-Performance Concrete 

A concrete: made with appropriate materials combined according to a selected mix design; 

properly mixed, transported, placed, consolidated and cured so that the resulting concrete will 

give excellent performance in the structure in which it is placed, in the environment to which it is 

exposed and with the loads to which it will be subject for its design life. 

Low-NOx Burners 

A type of gas burner that significantly reduces the formation of oxides of nitrogen. 

Micrometer 

A widely used device in mechanical engineering for precisely measuring thickness of blocks, 

outer and inner diameters of shafts and depths of slots. 

Particulate Matter 

Fine liquid or solid particles such as dust, smoke, mist, fumes, or smog, found in the air or 

emissions. 

Portland Cement

Portland cement is a type of hydraulic cement composed primarily of hydraulic calcium silicates. 

Hydraulic cements are the binding agents in concretes and most mortars. Portland cement is a 

generic term for the type of cement used in most concrete. Portland cement is produced by 

pulverizing clinker that consists primarily of hydraulic calcium silicates. Clinker also contains 

some calcium aluminates and calcium aluminoferrites and one or more forms of calcium sulfate 

(gypsum) are interground with the clinker to make the finished product. 

Strictly, the term portland cement in the United States is limited to the Types I through V 

varieties (and their air-entrained variants) as defined in ASTM C- 150; these types are also 

collectively called straight portland cement. Apart from the straight varieties, “portland cement” 

when used loosely (a common industry practice) can also include a number of similar hydraulic 

cements, including blended cements that are based on portland cement clinker plus gypsum. 

Powdered Activated Carbons 

Made up of crushed or ground carbon particles, 95%–100% of which will pass through a 

designated mesh sieve or sieve. It is generally added directly to other process units, such as raw 

water intakes, rapid mix basins, clarifiers, and gravity filters. 
G-5 

Pozzolan 

A pozzolan is a siliceous or siliceous and aluminous material, which in itself possesses little or 

no cementitious value but which will, in finely divided form and in the presence of moisture, 

chemically react with calcium hydroxide at ordinary temperatures to form compounds possessing 

cementing properties (ASTM C-618). 

Pozzolana 

A pozzolanic volcanic ash or tuff. 

Pulverized Coal Boiler 

A coal combustion technology that burns finely ground (powdered) coal in suspension. 

RCRA Subtitle D 

The portion of the Resource Conservation and Recovery Act regulations that primarily address 

non hazardous solid wastes.

Selective Non-Catalytic Reduction 

A method for reducing nitrogen oxide emissions in conventional power plants that burn biomass 

and coal. The process involves injecting either ammonia or urea into the firebox of the boiler at a 

location where the flue gas is between 1600 o

F and 2100 oF to react with the nitrogen oxides 

formed in the combustion process. The resulting product of the chemical reaction is elemental 

nitrogen (N2), carbon dioxide (CO2), and water (H2O). 

Selective Catalytic Reduction 

a process where a gaseous or liquid reductant is added to the flue or exhaust gas stream and is 

absorbed onto a catalyst. The reductant reacts with NOx in the exhaust gas to form water vapor 

and nitrogen gas. 

Silica Fume 

Also referred to as microsilica or condensed silica fume, ultrafine particles of disordered silica 

formed as a byproduct of the manufacture of silicon metal, silicon carbide, and silicon alloys 

(e.g., ferrosilicon). It is used as a pozzolan or SCM. 

Slag

Slags are valuable co-products of iron and steel production. Ferrous slags are produced by 

adding slagging agents (chiefly limestone or dolomite) and/or fluxing materials to blast furnaces 

and steel furnaces to strip the impurities from iron ore, steel scrap, and other iron or steel feeds. 

The molten slag forms as a liquid silicate melt that floats on top of the molten crude iron or steel 

and is tapped from the furnace separately from the liquid metal 

Slag Cement 

Slag cement is the manufactured product from granulated blast-furnace slag governed by ASTM 

C 989. Increasingly on the U.S. market, the term slag cement is used for a 100% GGBFS product 

that is sold as an SCM.
G-6 

Slagging Agents

A material, such as limestone, dolomite, lime, and silica sand, which serves, through the 

formation of a slag, to strip impurities from ores, during the smelting of metallic ores. Slagging 

agents commonly perform a dual function as a flux. 

Sorbent Injection 

Involves the addition of an alkaline material (usually hydrated lime or soda ash) into the gas 

stream to react with the acid gases. The sorbent can be injected directly into several different 

locations: the combustion process, the flue gas duct (ahead of the particulate control device), or 

an open reaction chamber (if one exists). The acid gases react with the alkaline sorbents to form 

solid salts that are removed in the particulate control device. 

Steel Furnace Slag 

A molten or fused solid byproduct from the processing of iron or scrap steel in a basic oxygen 

furnace or electric arc furnace produced as limestone or dolomite is used as a flux to remove 

impurities. Steel furnace slag is cooled similarly to air-cooled blast furnace slag, has similar 

properties to it, and is used for many of the same purposes. Steel slags containing large amounts 

of dicalcium silicate are prone to expansion and commonly are cured in piles for some months to 

allow for this and for leaching out of lime. 

Supplementary Cementitious Material(s) (SCM) 

SCMs are materials that can be incorporated within blended cements or in concrete mixes as 

partial substitutes for portland cement. Common examples are GGBFS, fly ash, silica fume, and 

pozzolana.
AA-1 

ABBREVIATIONS AND ACRONYMS 

AASHTO American Association of State Highway and Transportation 

 Officials 

ACAA American Coal Ash Association 

ACBFS air-cooled blast furnace slag 

ACI American Concrete Institute 

AFS American Foundry Society 

ASTM American Society for Testing and Materials 

BEES Building for Environmental and Economic Sustainability 

BFSA blast furnace slag aggregate 

C2P2 Coal Combustion Products Partnership 

Ca(OH)2 Slaked lime, when solide, the mineral portlandite 

CaSO3 calcium sulfite 

CaSO4 calcium sulfate 

CaSO4·2H2O calcium sulfate dehydrate; the mineral gypsum 

CBO carbon burnout 

CCP coal combustion product 

CERCLA Comprehensive Environmental Response, Compensation, and 

 Liability Act 

CFR Code of Federal Regulations 

CKD cement kiln dust 

CPG Comprehensive Procurement Guidelines 

DOE Department of Energy 

DOT Department of Transportation 

EERC Energy & Environment Research Center 

EIA Energy Information Administration 

EO Executive Order 

EPA U.S. Environmental Protection Agency 

EPACT Energy Policy Act of 2005 

EPRI Electric Power Research Institute 
AA-2 

FAA Federal Aviation Administration 

FBC fluidized-bed combustion 

FDEP Florida Department of Environmental Protection 

FEMP Federal Energy Management Program 

FGD flue gas desulfurization 

FHWA Federal Highway Administration 

FIRST Foundry Industry Recycling Starts Today 

FPDS Federal Procurement Data System 

FY Fiscal Year 

GAO Government Accountability Office 

GBFS granulated blast furnace slag 

GGBFS ground granulated blast furnace slag 

GHP Green Highways Partnership 

HPC high-performance concrete 

IEA International Energy Agency 

IRC Industrial Resources Council 

LCA Life cycle analysis 

LEED Leadership in Energy and Environmental Design 

MOU Memorandum of Understanding 

MPa megapascal 

NOx nitrogen oxides 

NRMCA National Ready Mixed Concrete Association 

NSR New Source Review 

OFEE Office of the Federal Environmental Executive 

OFPP Office of Federal Procurement Policy 

OMB Office of Management and Budget 

OSW Office of Solid Waste 

PAC powdered activated carbon 

PC pulverized coal 

PCA Portland Cement Association 

PM particulate matter 
AA-3 

QA/QC quality assurance/quality control 

RCRA Resource Conservation and Recovery Act 

RMANs Recovered Materials Advisory Notices 

RMC recovered mineral component 

RMRC Recycled Materials Resource Center 

SAFETEA- LU The Safe Accountable Flexible Efficient Transportation Equity 

 Act: A Legacy for Users 

SCM supplementary cementitious materials 

SFA Silica Fume Association 

SO2 sulfur dioxide 

SOx sulfur oxides 

TCAUG Texas Coal Ash Utilization Group 

TCEQ Texas Commission on Environmental Quality 

TxDOT Texas Department of Transportation 

USGBC United States Green Building Council 

USGS U.S. Geological Survey 

USWAG Utility Solid Waste Activities Group 

WBDG Whole Building Design Guide 

μm micrometer 
APPENDIX A: 

OVERVIEW OF PORTLAND CEMENT AND CONCRETE 
A-1 

Overview of Portland Cement and Concrete 

Although the terms “cement” and “concrete” are often used interchangeably, cement is actually 

an ingredient of concrete. Cements are binding agents in concretes and mortars. Concrete is an 

artificial rock-like material, basically a mixture of coarse aggregate (gravel or crushed stone), 

fine aggregate (sand), cement, air, and water. The term portland cement is a general term used to 

describe a variety of cements used today. Portland cements are hydraulic cements, which means 

they will set and harden by reacting chemically with water through hydration. 

Current (2004) world total annual production of hydraulic cement is about 2 billion metric tons 

(Gt), with production spread unevenly among more than 150 countries. This quantity of cement 

is sufficient for about 14 to 18 Gt/yr of concrete (including mortars), and makes concrete the 

most abundant of all manufactured solid materials. The current yearly output of hydraulic cement 

is sufficient to make about 2.5 metric tons per year (t/yr) of concrete for every person worldwide 

(van Oss, 2005). 

Cement and Cement Manufacturing 

Hydraulic cements are the binding agents in concretes and most mortars and are thus common 

and critically important construction materials. Hydraulic cements are of two broad types: those 

that are inherently hydraulic (i.e., require only the addition of water to activate), and those that 

are pozzolanic. The term pozzolan (or pozzolanic) refers to any siliceous material that develops 

hydraulic cementitious properties in the presence of lime [Ca(OH)2]. This includes true 

pozzolans and latent cements. The difference between these materials is that true pozzolans have 

no cementitious properties in the absence of lime, whereas latent cements already have some 

cementitious properties, but these properties are enhanced in the presence of lime. Pozzolanic 

additives or extenders can be collectively termed supplementary cementitious materials (SCM). 

(van Oss, 2005) 

Portland cement is the most commonly manufactured and used hydraulic cement in the United 

States (and the world). It is manufactured through the blending of mineral raw materials at high 

temperatures in cement rotary kilns. Rotary kilns produce an intermediate product called 

“clinker.” Clinker is ground to produce cement. By modifying the raw material mix and, to 

some degree, the temperature of manufacture, slight compositional variations in the clinker can 

be achieved to produce portland cements with varying properties 

Similar varieties of portland cement are made in many parts of the world but go by different 

names. In the United States, the different varieties of straight portland cement are denoted per the 

American Society for Testing and Materials (ASTM) standard C-150 as: 

• Type I: general use portland cement. In some countries, this type is known as ordinary 

portland cement. 

• Type II: general use portland cement exhibiting moderate sulfate resistance and moderate 

heat of hydration. 

• Type III: high early strength portland cement. 
A-2 

• Type IV: portland cement having a low heat of hydration. 

• Type V: portland cement having high sulfate resistance. 

For Types I, II, and III, the addition of the suffix A (e.g., Type IA) indicates the inclusion of an 

air entraining agent. Air entraining agents impart a myriad of tiny bubbles into the concrete 

containing the hydrated cement, which can offer certain advantages to the concrete, especially 

improved resistance to freeze-thaw cracking. In practice, many companies market hybrid 

portland cements; Type I/II is a common hybrid and meets the specifications of both Types I and 

II. Another common hybrid is Type II/V. 

Blended Cements 

Blended cements (called composite cements in some countries) are intimate mixes of a portland 

cement base (generally Type I) with one or more SCM extenders. The SCM commonly makes up 

about 5% to 30% by weight of the total blend, but can be higher. 

In blended cements, the SCM (or pozzolans) are activated by the high pH resulting from the 

hydroxide ions released during the hydration of portland cement. The most commonly used SCM 

are volcanic ashes called pozzolana, certain types of fly ash (from coal-fired power plants), 

ground granulated blast furnace slag (GGBFS)—now increasingly being referred to as slag 

cement—burned clays, silica fume, and cement kiln dust (CKD). In general, incorporation of 

SCM with portland cement improves the resistance of the concrete to chemical attack, reduces 

the concrete’s porosity, reduces the heat of hydration of the cement (not always an advantage), 

potentially improves the flowability of concrete, and produces a concrete having about the same 

long-term strength as straight portland cement-based concretes. However, SCM generally reduce 

the early strength of the concrete, which may be detrimental to certain applications (van Oss, 

2005). 

Blended cements either can be prepared at a cement plant for sale as a finished blended cement 

product, or by doing the blending within a concrete mix. In fact, most of the SCM consumption 

by U.S. concrete producers is material purchased directly for blending into the concrete mix. 

Concrete producers in the United States buy relatively little finished blended cement. 

The designations for blended cements vary worldwide, but those currently in use in the United 

States meet either ASTM Standard C-595, C 989 or C-1157. ASTM Standard C-595 defines 

several types of blended cements. The main designations include (van Oss, 2005): 

• Portland blast furnace slag cement (IS). Contains 25% to 70% GGBFS. 

• Portland-pozzolan cement (IP and P). Contains a base of portland and/or IS cement and 

15% to 40% pozzolans. 

• Pozzolan-modified portland cement (I(PM)). The base is portland and/or Type IS cement 

with a pozzolan addition of less than 15%. 

• Slag-modified portland cement (I(SM)). Contains less than 25% GGBFS. 
A-3 

• Slag cement (S).1 GGBFS content of 70% or more. Type S can be blended with portland 

cement to make concrete or with lime for mortars; the latter combination would make the 

final cement a pozzolan-lime cement. 

Chemical Composition of Portland Cement 

Modern straight portland cement is a very finely ground mix of portland cement clinker and a 

small amount (typically 3% to 7%) of gypsum (calcium sulfate dihydrate) and/or anhydrite 

(calcium sulfate). Cement chemistry is generally denoted in simple stoichiometric shorthand 

terms for the major constituent oxides. Table A-1 provides the shorthand notation for the major 

oxides in the cement literature. Table A-1 also shows the typical chemical composition of 

modern portland cement and its clinker. For clinker, the oxide compositions would generally not 

vary from the rough averages shown by more than 2% to 4%. The oxide composition of portland 

cement would vary slightly depending on its actual gypsum fraction or whether any other 

additives are present. 

Table A-1: Chemical Shorthand and Composition of Clinker and Portland Cement 

Oxide Formula 

Shorthand 

Notation 

Percentage by Mass 

in Clinker 

Percentage by Mass 

in Cement* 

CaO C 65 65.0 

SiO2 S 22 22.0 

Al2O3 A 6 6.0 

Fe2O3 F 3 3.0 

MgO M 2 2.0 

K2O + Na2O K + N 0.6 0.6 

Other (including SO3

-

) ...(...S ) 1.4 3.6 

H2O H “nil” 1.0 

* Based on clinker shown plus 5% addition of gypsum (CaSO4·2H2O). 

Source: van Oss, 2005 

Mineralogy of Portland Cement and Its Clinker 

The major oxides in clinker are combined essentially into just four cement or clinker minerals, 

denoted in shorthand: tricalcium silicate or ‘alite’ (C3S); dicalcium silicate or ‘belite’ (C2S); 

tricalcium aluminate (C3A); and tetracalcium aluminoferrite (C4AF). These formulas represent 

averages, ignoring impurities commonly found in actual clinker. It is the ratios of these four 

minerals (and gypsum) that determine the varying properties of different types of portland 

cements. Table A-2 provides the chemical formulas and nomenclature for the major cement 

oxides as well as the function of each in cement mixtures. 

 

1 True Type S cements are no longer commonly made in the United States. Instead, the name slag cement (but with 

no abbreviation) is now increasingly given to the unblended 100 % GGBFS product (van Oss, 2005). ASTM C989 

now governs slag cement (GGBFS).
A-4 

Table A-2: Typical Mineralogical Composition of Modern Portland Cement 

Chemical 

Formula Oxide Formula 

Shorthand 

Notation Description 

Typical 

Percentage Mineral Function 

Ca3SiO5 (CaO)3SiO2 C3S 

Tricalcium 

silicate 

(‘alite’) 

50-70 

Hydrates quickly and 

imparts early 

strength and set 

Ca2SiO4 (CaO)2SiO2 C2S 

Dicalcium 

silicate 

(‘belite’) 

10-30 

Hydrates slowly and 

imparts long 

term (ages beyond 1 

week) strength. 

Ca3Al2O6 (CaO)3Al2O3 C3A Tricalcium 

aluminate 3-13 

Hydrates almost 

instantaneously and 

very exothermically. 

Contributes to early 

strength and set. 

Ca4Al2Fe2O10 (CaO)4Al2O3Fe2O3 C4AF Tetracalcium 

aluminoferrite 5-15 

Hydrates quickly. Acts 

as a flux in 

clinker manufacture. 

Imparts gray color. 

CaSO4·2H2O (CaO)(SO3) · 

(H2O)2 CS H2

Calcium 

sulfate 

dihydrate 

(gypsum) 

3-7 

Interground with 

clinker to make 

portland cement. Can 

substitute anhydrite 

(CS ). Controls early 

set. 

CaSO4 (CaO)(SO3) CS Anhydrous 

calcium sulfate 0.2-2 

Source: van Oss, 2005. 

As indicated in Table A-2, some of the minerals in clinker serve different functions in the 

manufacturing process while others impart varying final properties to the cement. The proportion 

of C3S, for example, determines the degree of early strength development of the cement. The 

“ferrite” mineral’s (C4AF) primary purpose, on the other hand, is to lower the temperature 

required in the kiln to form the C3S mineral, and really does not impart a specific property to the 

cement. Table A-3 presents the common mineralogical compositions of Types I through IV 

cements and the unique properties of each type. 
A-5 

Table A-3: Typical Range in Mineral Composition in Portland Cements 

ASTM C-150 Clinker Mineral Percent* 

Cement Type C3S C2S C3A C4AF Properties of Cement 

I 50-65 10-30 6-14 7-10 General purpose 

II 45-65 7-30 2-8 10-12 Moderate heat of hydration, 

moderate sulfate resistance 

III 55-65 5-25 5-12 5-12 High early strength** 

IV 35-45 28-35 3-4 11-18 Low heat of hydration 

V 40-65 15-30 1-5 10-17 High sulfate resistance 

* Range of minerals is empirical and approximate rather than definitional. 

** High early strength is typically achieved by finer grinding of Type I cement. 

Source: van Oss, 2005. 

Physical Properties of Portland Cement 

Portland cement consists of individual angular particles with a range of sizes, the result of 

pulverizing clinker in the grinding mill. Approximately 95% of cement particles are smaller than 

45 micrometers, with the average particle around 15 micrometers. The fineness of cement affects 

the amount of heat released during hydration. Greater cement fineness (smaller particle size) 

increases the rate at which cement hydrates and thus accelerates strength development. Except 

for AASHTO M 85, most cement standards do not have a maximum limit on fineness, only a 

minimum. The fineness of Types I through V portland cement are shown in Table A-4 

(Kosmatka, 2002). Values are expressed according to the Blaine air-permeability test (ASTM C 

204 or AASHTO T 153), which indirectly measures the surface area of particles per unit mass. 

Table A-4: Fineness of Portland Cement 

ASTM C - 150 

Cement Type Fineness (cm2

/g, Blaine) 

 Range Mean 

I 3,000-4,210 3,690 

II 3,180-4,800 3,770 

III 3,900-6,440 5,480 

IV 3,190-3,620 3,400 

V 2,750-4,300 3,730 

The specific gravity of portland cement typically ranges from 3.10 to 3.25, with an average of 

3.15. Bulk densities can vary significantly depending on how the cement is handled and stored. 

Reported bulk densities range from 830 to 1,650 kg/m3

 (Kosmatka, 2002). 
A-6 

The Clinker Manufacturing Process 

Portland cement manufacturing is a two-step process beginning with the manufacture of clinker 

followed by the fine grinding of the clinker with gypsum and other additives to make the finished 

cement product. Grinding can occur on site or at offsite grinding plants. 

The first step in clinker manufacture is the quarrying, crushing, and proportioning of raw 

materials. Due to the low unit value of these raw materials, they typically are mined within a few 

miles of the cement plant. The cost of transport renders long-distance transport of these low-cost 

raw materials uneconomical. 

Once the raw mix, or raw meal, is prepared, it is fed into a cement kiln and converted into the 

clinker minerals through a thermochemical conversion, referred to as pyroprocessing because it 

involves direct flame interaction. Figure A-1 provides a generalized flow diagram of the cement 

manufacturing process (van Oss, 2005). 

Figure A-1: Cement Manufacturing Flow Diagram 

The raw materials for clinker manufacture consist primarily of materials that supply four primary 

oxides: Calcium oxide (CaO), silicon dioxide (SiO2), aluminum oxide (Al2O3), and ferric oxide 

(Fe2O3). The composition of the raw mix typically includes about 80% calcium carbonate, about 

10% to 15% silica, and small amounts of alumina and iron. Depending on the quality and 

quantity of these oxides available to the facility, other raw materials, referred to as accessory or 

sweetener materials, are added to correct for any deficiencies in the primary raw materials. 

Certain types of fuel burned in the cement kiln can also contribute oxides (e.g., ash from coal 

combustion contributes silica oxides, steel belts in waste tires contribute iron oxide). 
A-7 

Calcium oxide (CaO or simply C in shorthand) is the primary ingredient in clinker, comprising 

about 65% of clinker by mass. A cement plant typically examines its source of C (typically 

limestone, marl, or chalk) and determines what other oxides need to be added to achieve the 

desired clinker composition. Clay, shale, slate, or sand provide the silica and alumina 

component, while iron, mill scale, or other ferrous materials provide the iron content. Preparing 

the raw mix for clinker production requires constant sampling, chemical testing, and adjusting of 

the inputs to maintain the desired clinker composition. 

On average, it takes about 1.7 tons of nonfuel raw materials to produce 1 ton of clinker. Of the 

1.7 tons of raw materials, approximately 1.5 tons is limestone or calcium oxide rich rock (van 

Oss, 2005). The lost mass takes the form of carbon dioxide (CO2) driven off by the calcination of 

limestone and the generation of CKD. Nearly one ton of CO2 is produced for every ton of clinker 

manufactured (van Oss, 2005). The CKD that is produced during clinker manufacture is carried 

“up the stack” and captured by emission control devices. A large portion of the CKD, though not 

all of it, is returned to the kiln as part of the feed stream. 

Manufacture of Finished Cement from Clinker 

After clinker has been cooled to about 100°C, it is ready to be ground into finished cement in a 

grinding mill, more commonly referred to as a finish mill. Generally, separate grinding and/or 

blending finish mill lines will be maintained at a plant for each of its major product classes 

(finished portland cements, blended cements, masonry cements, ground slag). Additives that 

commonly require grinding at the mill include gypsum, limestone, granulated blast furnace slag, 

and natural pozzolans. Additives that generally do not require significant grinding include coal 

fly ash, GGBFS, and silica fume, but the finish mill does provide intimate mixing of these with 

the portland cement base. 

Production 

The U.S. Geological Survey (USGS) estimated that in 2005 approximately 97.5 million metric 

tons (Mt) of portland plus masonry cement was produced at 113 plants in 37 states in the United 

States. The reported final production of masonry plus portland cement was 99.3 Mt, with 

portland cement alone accounting for 93.9 Mt of this total (van Oss, 2007). Figure A-2 shows 

the locations of U.S. cement plants in 2005 based on information provided by the Portland 

Cement Association (PCA, 2006). Appendix C contains a listing of cement plants operating in 

the United States in 2005. The estimated value of cement production for 2005 was about $8 

billion. The final reported actual value for portland plus masonry cement production in 2005 was 

$11.6 billion. Of this total, $10.9 billion was for portland cement alone (van Oss, 2007). Most 

of the cement was used to make ready mixed concrete (75%), while 14% went to concrete 

manufacturers, 6% to contractors, 3% to building materials dealers, and 2% to other users. 

Clinker production occurred at 107 plants, with a combined annual capacity of about 103 million 

tons. Actual U.S. cement imports in 2005 were reported at 30.4 Mt (excluding Puerto Rico), and 

clinker imports were 2.86 Mt (van Oss, 2007). Average mill prices for cement in 2005 were 

about $84 per ton. More than 172 million tons of raw materials were used to produce cement and 
A-8 

clinker in the United States in 2004. Table A-5 summarizes U.S. cement statistics for the years 

2000 through 2005 (USGS, 2001; 2002; 2003; 2004; 2005; 2006). Table A-6 summarizes raw 

materials used in the United States in 2003 and 2004 to produce cement and clinker (van Oss, 

2004). 

Figure A-2: U.S. Cement Plants 
A-9 

Table A-5: U.S. Cement Statistics 

Year 2000 2001 2002 2003 2004 2005

---------------------------million metric tons-----------------------------

Estimated Cement 

Production 

87.8 88.9 89.7 92.8 97.4 97.5*

Clinker Production 78.1 78.8 81.5 81.9 86.7 87.4

Imports of Cement 24.6 23.7 22.2 21.0 25.4 29.0

Imports of Clinker 3.7 1.8 1.6 1.8 1.6 2.8

Exports of Cement and 

Clinker 

0.74 0.75 0.83 0.84 0.82 0.80

Average Price, Mill Value, 

$/ton 

78.56 76.50 76.00 75.00 79.50 84.00

* Actual total masonry plus portland cement final production for 2005 is reported at 99.3 Mt, of which 93.9 Mt was for 

portland cement alone. 

 

Table A-6: Raw Materials Used in Producing Clinker and Cement in the United States 

2003 2004 

Raw Materials Clinker Cement Clinker Cement

------------------------thousand metric tons-------------------

Limestone 109,000 1,530 125,000 1,810

Cement rock 12,700 44 12,700 2

Cement kiln dust 289 149 333 165

Lime 22 27 24 29

Other calcareous 235 32 23 19

Clay 3,950 --* 4,740 --

Shale 2,630 8 3,700 29

Other aluminous 618 -- 661 --

Ferrous, iron ore, pyrites, 

millscale, other 

1,340 -- 1,340 --

Sand and calcium silicate 2,860 2 3,150 --

Sandtone, quartzite soils, other 587 2 878 6

Coal Fly ash 2,250 39 2,890 77

Other ash, including bottom ash 1,100 -- 1,050 --

Granulated blast furnace slag 17 333 104 345

Other blast furnace slag 214 -- 189 --

Steel slag 448 -- 401 --

Other slags 113 -- 53 --

Natural rock pozzolans -- 25 -- 6

Other pozzolans 129 49 114 19

Gypsum and anhydrite -- 5,000 -- 5,300

Other, not elsewhere classified 70 68 106 98

Clinker, imported -- 4,240 -- 7,530

Total 139,000 11,500 157,000 15,400

*-- Indicates none reported.
A-10

Concrete

Concrete is basically a mixture of two components: aggregate and cement paste. The cement 

paste, comprised of a binder (usually portland cement) and water, binds the aggregates (usually 

sand and gravel or crushed stone) into a rocklike mass as the paste hardens. The paste hardens 

because of a chemical reaction, called hydration, between the cement and water. 

The National Ready Mixed Concrete Association (NRMCA) estimates that ready mixed concrete 

production in the United States was approximately 349 million cubic meters in 2005. NRMCA 

estimates that there are approximately 6,000 ready mixed concrete plants in the United States, 

and that annual ready mixed concrete production is valued at more than $30 billion. Table A-7 

shows ready mixed concrete production by state in 2005 as reported by NRMCA. USGS 

estimates that total concrete production in the United States in 2005 was valued at more than $48 

billion (USGS, 2006). Although there are no data available on the amount of concrete placed 

annually in the United States, based on U.S. cement sales it can be estimated to be nearly one 

billion metric tons per year. 
A-11

Table A-7: Ready Mixed Concrete Production by State (2005) 

State 

Production 

(million cubic 

meters)

Percent of 

National 

Production State 

Production 

(million cubic 

meters)

Percent of 

National 

Production 

Alabama 4.9 1.4% Nebraska 3.8 1.1%

Alaska 0.5 0.1% Nevada 7.3 2.1%

Arizona 13.1 3.8% New 

Hampshire 

0.6 0.2%

Arkansas 3.4 1.0% New Jersey 5.5 1.6%

California 43.4 12.4% New Mexico 2.5 0.7%

Colorado 7.3 2.1% New York 8.9 2.6%

Connecticut 2.2 0.6% North 

Carolina 

8.2 2.4%

Delaware 0.6 0.2% North Dakota 1.0 0.3%

District of 

Columbia 

0.6 0.2% Ohio 10.9 3.1%

Florida 31.6 9.1% Oklahoma 4.5 1.3%

Georgia 12.4 3.6% Oregon 3.5 1.0%

Hawaii 1.2 0.3% Pennsylvania 9.3 2.7%

Idaho 2.0 0.6% Puerto Rico 5.2 1.5%

Illinois 11.6 3.3% Rhode Island 0.5 0.1%

Indiana 6.1 1.8% South 

Carolina 

5.0 1.4%

Iowa 5.4 1.6% South Dakota 1.4 0.4%

Kansas 4.3 1.2% Tennessee 6.0 1.7%

Kentucky 4.2 1.2% Texas 40.8 11.7%

Louisiana 5.5 1.6% Utah 4.3 1.2%

Maine 0.7 0.2% Vermont 0.4 0.1%

Maryland 4.4 1.3% Virginia 7.5 2.1%

Massachusetts 3.5 1.0% Washington 6.3 1.8%

Michigan 8.2 2.4% West Virginia 1.4 0.4%

Minnesota 5.7 1.6% Wisconsin 6.6 1.9%

Mississippi 3.0 0.9% Wyoming 1.3 0.4%

Missouri 8.0 2.3% Other 1.2 0.3%

Montana 1.1 0.3% Total 348.8 100.0%

The character of concrete is determined by the quality of the cement paste (i.e., the cement and 

water mixture). The water to cement ratio—the weight of the mixing water divided by the weight 

of the cement—plus the quality and type of cement determines the strength of the paste, and 

hence the strength of the concrete. High-quality concrete is produced by lowering the watercement ratio as much as possible without sacrificing the workability of fresh concrete. Generally, 

using less water produces a higher quality concrete provided the concrete is properly placed, 

consolidated, and cured. 
A-12

For a typical concrete mix, 1 metric ton of cement (powder) will yield about 3.4 to 3.8 cubic 

meters of concrete weighing about 7 to 9 metric tons (i.e., the density is typically in the range of 

about 2.2 to 2.4 metric tons per cubic meter). Although aggregates make up the bulk of the mix, 

it is the hardened cement paste that binds the aggregates together and contributes virtually all of 

the strength of the concrete, with the aggregates serving largely as low cost fillers. The strengths 

of the cement paste is determined by both the quality and type of the cement and the water-tocement ratio (van Oss, 2005). 
APPENDIX B: 

 BACKGROUND OF RECOVERED MINERAL COMPONENTS
B-1 

Background of Recovered Mineral Components 

B.1 Iron and Steel Slags 

Ferrous slags are by-products from iron and steel manufacturing. There are two main types of 

ferrous slags produced in the United State—blast furnace slags and steel slags. Blast furnace 

slags are produced during smelting of iron ore or iron pellets with coke and a flux, such as 

limestone or dolomite. The calcium in the stone combines with the aluminates and silicates in the 

ore and ash from the coke to produce this non-metallic material. The slag is removed from the 

furnace for further processing. Blast furnace slag has many uses, including the production of 

clinker and blended cements, and as an aggregate in portland cement concrete. 

Steel slag is a byproduct from the processing of iron in a basic oxygen furnace (BOF) or scrap 

steel in an electric arc furnace (EAF). Steel slags also can be used in the manufacture of clinker. 

More information on steel slag is provided in section B.9. There is still some minor open hearth 

(OH) furnace material resident in slag piles that is occasionally sold. However, no OH slag is 

being produced anymore in this country. 

In 2005, PCA estimates that 39 cement plants were using slag as a raw material the manufacture 

of clinker, and 11 plants were blending it into one or more cement products (see Figure B-1) 

(PCA, 2005). 
B-2 

Figure B-1: Portland Cement Plants Utilizing Slag 
B-3 

B.2 Blast Furnace Slag 

Figure B-2: U.S. Blast Furnace Slag Producers 

The chemical composition of blast furnace slag varies, but Table B-1 presents a typical range of 

values (FHWA, 1998). 

Table B-1: Typical Chemical Composition of Blast Furnace Slag 

Constituent Mean Range 

--------------------------percent by weight---------------------------

Calcium Oxide (CaO) 39.0 34 - 43 

Silicon Dioxide (SiO2) 36.0 27 - 38 

Aluminum Oxide (Al2O3) 10.0 7 - 12 

Magnesium Oxide (MgO) 12.0 7 - 15 

Iron (FeO or Fe2O3) 0.5 0.2 - 1.6 

Manganese Oxide (MnO) 0.4 0.15 - 0.76 

Sulfur (S) 1.4 1.0 - 1.9 
B-4 

The National Slag Association provided data on slag usage in concrete as aggregate and as a 

SCM for the years 1996 through 2005, which is summarized in Table B-2. These data were not 

broken out by slag type (i.e., granulated vs. air-cooled). 

Table B-2: Blast Furnace Slag Production and Usage (National Slag Association Data) 

Estimated Slag 

Production 

Slag Used as 

Concrete Aggregate 

Slag Used as 

Supplementary 

Cementitious Material 

Year ---------------------------------------million metric tons---------------------------------------

1996 NA* NA 1.0 

1997 NA 1.27 1.2 

1998 NA 1.27 1.4 

1999 NA 1.36 1.6 

2000 10.9 1.27 1.8 

2001 9.5 1.36 2.2 

2002 9.2 1.36 2.6 

2003 9.3 1.36 2.7 

2004 9.3 1.45 3.2 

2005 10.3 NA 3.3 

*NA = data not available 

GBFS is a glassy granular material, consisting mainly of silicates and aluminosilicates of 

calcium. The particle distribution, shape, and grain size of GBFS vary, depending on the 

chemical composition and method of production, from coarse, popcornlike friable particles to 

dense, sand-size grains. Whereas portland cement typically is ground to around 3,000-3,500 

cm

2

/g (Blaine) in the United States, granulated slag is typically ground even finer (to about 4,000 

– 5,000 cm2

/g (Blaine) to achieve satisfactory reactivity. 

ASTM C 989 (AASHTO M302) classifies slag by its increasing level of reactivity as follows: 

• Grade 80 - slags with low activity index 

• Grade 100 - slags with a moderate activity index 

• Grade 120 - slags with high activity index

GGBFS is a hydraulic material with inherent cementious character, that is, it will set up and gain 

strength on its own when mixed with water. In the presence of alkalis such as may be present in 

a concrete mix with portland cement, these alkalis will accelerate the hydration of the slag 

cement to levels similar to that of portland cement. Because of its cementitious nature, it should 

be noted that 70% slag cement concrete mixtures are usually used to control heat of hydration in 

mass concrete placement. GGBFS has been used for many years as a SCM in portland cement 

concrete, either as a mineral admixture or as a component of blended cement. GGBFS slag, when 

used in general purpose concrete in North America, typically constitutes between 30% and 45% 

of the cementitious material in the mix. Some slag concretes have a slag component of 70% or 

more of the cementitious material (Kosmatka, 2002). GGBFS is used in making blended 

Portland blast furnace slag cement (IS). The use of GGBFS in blended cement is governed by 

ASTM C-595. The specific gravity of GGBFS is in the range of 2.85 to 2.95, and the bulk 

density varies from 1,050 to 1,375 kg/m3 (Kosmatka, 2002). 
B-5 

Performance Record 

Florida, Maryland, New Hampshire, and Oregon state agencies are reported to be investigating 

the use of GGBFS as a SCM. At least 11 states (Delaware, Florida, Indiana, Maryland, 

Massachusetts, Michigan, New Hampshire, North Carolina (limited use on experimental basis), 

Pennsylvania, South Carolina and Virginia) currently have specifications covering the use of 

GGBFS as a partial replacement for portland cement. Some state agencies have reported 

durability problems (decreased salt scaling resistance) with exposed concrete containing blast 

furnace slag where the amount of GGBFS exceeds about 25% of the total cement. 

B.3 Silica Fume 

According to the Silica Fume Association, there are five companies producing silica fume in the 

United States. USGS data indicate that in 2004, silicon alloys and/or silicon metals were 

produced at six plants, and that a seventh plant was idle in 2004 (Corathers, 2004). Demand for 

silica fume is high, and the United States is currently importing silica fume from Venezuela, 

Spain, Argentina, Norway and Iceland. U.S. companies also export silica fume to Canada, 

Central America, and South America. Figure B-3 illustrates the location of silica fume producers 

in the United States. Appendix C contains a listing of U.S. silica fume producers. 
B-6 

Figure B-3: U.S Silica Fume Producers 

Silica fume has been known to be a beneficial admixture to concrete since the late 1940’s. 

However, silica fume did not become widely used until the development of high-range waterreducing admixtures or superplasticizers. These admixtures are necessary because the high 

surface area of silica fume increases water demand in concrete, which can have a detrimental 

effect on concrete properties. The use of water-reducing admixtures or superplasticizers can 

improve workability and placement of concrete at lower water contents, offsetting the need for 

additional water in mixes containing silica fume. 

The addition of silica fume to concrete mixes improves finished concrete properties through both 

physical and chemical mechanisms. Physically, the extremely small size of silica fume particles 

allows them to occupy spaces between cement grains, an arrangement typically referred to as 

particle packing or micro-filling. Chemically, silica fume particles are highly pozzolanic (i.e., 

they react with calcium hydroxide (hydrated lime) to produce highly cementitious compounds) 

due to their high amorphous silicon dioxide content. Therefore, when portland cement releases 

calcium hydroxide as it hydrates, silica fume reacts with the calcium hydroxide to form 

additional binder material (DOT, 2005). 

The addition of silica fume has two main effects on fresh concrete. First, it makes the concrete 

more cohesive, which reduces segregation and improves the efficiency of shotcreting. Second, 
B-7 

silica fume reduces the bleeding in concrete by reducing porosity and reacting with lime. 

Bleeding leads to the formation of capillary channels, which can increase chloride intrusion in 

finished concrete. In addition, eliminating bleeding allows concrete to be finished earlier, which 

is advantageous in projects where durability is important, such as in bridge decks or parking 

structures. 

The percentage of silica fume used in high performance concrete (HPC) varies depending on the 

application and desired performance characteristics of the concrete, but typically ranges from 5% 

to 20% on a dry weight basis. HPC containing silica fume also often contains coal fly ash. Silica 

fume also can be used in concrete with other recovered materials such as GGBFS and 

cenospheres. Because silica fume costs more than portland cement and there are relatively low 

volumes available, its use is limited primarily to HPC. 

The increased strength of finished concrete with silica fume can mean that less cement is 

required in concrete mixes, though silica fume is usually used in addition to the standard 

amounts of portland cement. 

Further, silica fume concrete only requires “single-pass” or “one-pass” finishing whereby the 

finishing is condensed into a single operation. In single-pass finishing, placement, consolidation, 

surface-closing, and texturing operations follow one another in succession. The concrete is then 

cured immediately. The total time from placement to final curing is recommended by the Federal 

Highway Administration (FHWA) to be less than 20 minutes. This rapid finishing technique is 

cost efficient, but quite different than normal construction practices used over the past 50 years. 

Specifications regarding the use of silica fume in concrete can be found in ASTM C1240 

(AASHTO M307). ACI 234R-06 describes the physical and chemical properties of silica fume, 

how silica fume interacts with portland cement, the effects of silica fume on the properties of 

fresh and hardened concrete, typical applications of silica fume concrete, and recommendations 

on proportions, specifications, and handling of silica fume in the field. 

The Figure B-4 below shows typical concrete made with cement and 15% coal fly ash as 

substitution for cement. To this reference mix, 8% and 15% silica fume, based on cement 

weight, was added. 
B-8 

Figure B-4: Cement Mix Continuum 

The figure above shows that the efficiency of a pound of cement to concrete strength increases 

significantly when 8% silica fume, by weight of cement, was added to the mix. The ability to 

generate increased strength from each pound of cement used means that less cement can be used 

to achieve a required compressive strength. Also, as the rate or ‘slope’ is reduced from 1400 to 

250psi / cwt, the quality control necessary to achieve that strength becomes more difficult to 

implement. 

B.4 Coal Fly Ash 

The U.S. Department of Energy (DOE) conducts several annual surveys to collect data on 

electric power plants. One such survey (EIA-860: Annual Electric Generator Report) (U.S. DOE, 

2004) includes data about generators in electric power plants owned and operated by electric 

utilities and nonutilities. These data indicate that in 2004 there were 1,526 generating units at 

facilities that used coal2

 as a primary fuel source. Of these units, 1,220 were classified as NACIS 

22 (electric, gas and sanitary services). It is likely that this represents the universe of U.S. 

generators that would produce coal combustion products, including coal fly ash. 

 

2

 This includes facilities that burn anthracite, bituminous and subbituminous coal, lignite, waste coal and synthetic 

coal. 
B-9 

Another annual DOE survey (U.S. DOE, 2004b) collects data from organic-fueled or 

combustible renewable steam-electric power plants with a rating of 10 or more megawatts. This 

survey (EIA-767: Annual Steam-Electric Plant Operation and Design Data) gathers information 

on, among other things, coal combustion product production. In 2004, 426 facilities reported data 

on coal fly ash production. These data indicate that approximately 69.8 million metric tons of 

coal fly ash was produced in 2004 at these facilities. 

The American Coal Ash Association (ACAA) also conducts an annual survey of coal 

combustion product production. ACAA estimates that in 2004 approximately 64.2 million metric 

tons of coal fly ash were produced in the United States. (ACAA, 2004) 

Coal fly ash is produced in abundant quantities and in all areas of the United States. Figure B-5 

illustrates the geographic distribution of facilities that produce coal fly ash by state, based on the 

2004 EIA-767 data files. Table B-3 shows the number of facilities producing coal fly ash, and 

coal fly ash production and disposition by state. Additional details on these facilities are included 

in Appendix .C 
B-10

Figure B-5: U.S. Coal Fly Ash Producers by State 
B-11

Table B-3: Coal Fly Ash Production and Disposition, by State (2004)* 

Total Fly 

Ash 

Production 

Fly Ash 

Landfilled 

Fly Ash 

Ponded 

Fly Ash Used 

or Stored OnSite Fly Ash 

Sold 

Fly Ash 

Disposed 

Off-site 

State 

Number of 

Plants 

--------------------------------------thousand metric tons----------------------------------

AL 10 2,150 672 982 -- 396 99 

AR 3 455 189 -- -- 266 -- 

AZ 6 1,800 550 178 -- 1,050 23 

CA 1 46 46 -- -- -- -- 

CO 11 1,090 484 3 41 141 421 

CT 4 75 -- -- -- -- 75 

DE 2 3,269 114 -- 3,075 -- 81 

FL 17 2,658 732 62 42 1,230 593 

GA 11 2,369 540 1,054 -- 721 54 

HI 1 7 -- -- -- -- 7 

IA 12 838 125 34 59 447 173 

IL 23 2,060 18 365 163 683 831 

IN 20 4,410 704 2,531 663 382 130 

KS 7 642 250 83 -- 279 31 

KY 19 3,490 1,718 1,172 153 181 266 

LA 4 997 383 160 10 445 -- 

MA 6 248 -- -- 4 76 168 

MD 9 1,403 381 20 -- 379 624 

ME 3 578 557 -- -- -- 20 

MI 15 1,590 656 535 67 289 44 

MN 10 860 314 389 -- 146 11 

MO 15 1,252 206 409 6 560 70 

MS 6 1,396 742 79 90 431 54 

MT 2 613 -- 572 16 24 -- 

NC 17 2,796 389 900 830 524 153 

ND 7 1,299 843 -- 48 354 54 

NE 6 321 91 -- 7 216 8 

NH 3 78 13 -- -- 3 62 

NJ 6 400 -- -- -- -- 400 

NM 3 2,449 -- 397 92 442 1,518 

NV 3 553 269 -- -- 284 -- 

NY 12 739 293 -- 1 157 287 

OH 22 4,124 1,249 1,504 -- 555 814 

OK 7 926 149 18 19 461 278 

OR 1 64 -- -- -- 64 -- 

PA 25 4,262 1,928 578 416 855 484 

SC 13 1,177 135 253 -- 751 38 

SD 1 33 25 -- -- 8 -- 

TN 8 1,758 662 493 35 373 195 

TX 20 5,837 2,209 76 9 3,042 501 

UT 6 1,355 771 11 333 240 -- 

VA 15 1,573 730 263 34 17 528 

WA 1 463 143 -- -- 320 -- 

WI 14 961 74 -- 95 780 14 

WV 14 3,201 1,871 721 213 346 51 

WY 5 1,125 478 81 -- 461 105 

Total 426 69,791 21,702 13,921 6,519 18,383 9,266 

Source: U.S. Department of Energy (DOE), 2004b. “Annual Steam-Electric Plant Operation and Design Data”. EIA-767 

data files available at http://www.eia.doe.gov/cneaf/electricity/page/eia767.html

* No coal fly ash production was reported in Alaska, Idaho, Rhode Island, or Vermont 
B-12

Coal fly ash is a finely divided powder resembling portland cement. Most of the coal fly ash 

particles are solid spheres and some are hollow cenospheres. Plerospheres are also present, 

which are spheres containing smaller spheres. The particle sizes in coal fly ash vary from less 

than 1 μm (micrometer) to more than 100 μm with the typical particle measuring under 20 μm. 

Only 10% to 30% of the particles by mass are larger than 45 μm. The surface area of coal fly ash 

is typically 3,000 to 5,000 cm2/gm, although some fly ashes can have surface areas as low as 

2,000 cm2/gm and as high as 7,000 cm2/gm. For coal fly ash without close compaction, the bulk 

density can vary from 540 to 860 kg/m3

, but with close packed storage or vibration, the range 

can be 1,120 to 1,500 kg/m3

. The specific gravity of coal fly ash generally ranges between 1.9 

and 2.8 (Kosmatka, 2002). 

Coal fly ash consists primarily of silicate glass containing silica, alumina, iron and calcium. 

Minor constituents are magnesium, sulfur, sodium, potassium and carbon. This makeup gives 

coal fly ash its pozzolanic properties, meaning that it reacts with water and free lime (calcium 

oxide) to produce a cement-like compound. ASTM C 618 (AASHTO M295) classifies coal fly 

ash as Class C and Class F based on their pozzolanic and cementitious properties. Some coal fly 

ash meets both Class C and F classifications. 

• Class C Coal Fly Ash is high-calcium, containing typically 10% to 30% calcium oxide 

with carbon contents less than 2%. Many Class C ash exhibits both cementitious and 

pozzolanic properties. 

• Class F Coal Fly Ash is generally low-calcium, with less than 10% calcium oxide, with 

carbon contents usually less than 5%, but may have carbon contents as high as 10%. 

Many Class F ashes have pozzolanic properties—they require addition of lime to form 

cementitious compounds. 

Table B-4 presents typical chemical compositions for coal fly ash produced from different coal 

types (FHWA, 1998) 

Table B-4: Chemical Composition of Various Coal Fly Ash Types

Coal Type 

Component Bituminous Subbituminous Lignite 

-----------------------------------percent by weight----------------------------

SiO2 20 - 60 40 - 60 15 - 45 

Al2O3 5 - 35 20 - 30 10 - 25 

Fe2O3 10 - 40 4 - 10 4 - 15 

CaO 1 - 12 5 - 30 15 - 40 

MgO 0 - 5 1 - 6 3 - 10 

SO3 0 - 4 0 - 2 0 - 10 

Na2O 0 - 4 0 - 2 0 - 6 

K2O 0 - 3 0 - 4 0 - 4 

Loss on Ignition 0 - 15 0 - 3 0 - 5 
B-13

Figure B-6 shows the locations of the 39 portland cement plants using coal fly ash as a raw feed 

in the manufacture of clinker and the 3 plants blending coal fly ash into finished cement 

products. 

Figure B-6: U.S. Portland Cement Plants Utilizing Coal Fly Ash (PCA, 2005b) 
B-14

B.5 Foundry Sand 

Foundry sand is produced by five different foundry classes. The ferrous foundries (gray iron, 

ductile iron, and steel) produce the most sand in the United States, while aluminum, copper, 

brass, and bronze produce the rest. Foundries purchase high-quality, size-specific sand for use in 

their molding and casting operations. Foundry sand is used to form the outer shape of the mold 

cavity and relies upon a small amount of bentonite clay to act as the binder material. Depending 

on the geometry of the casting, sand cores are inserted into the mold cavity to form internal 

passages for the molten metal. Once the metal has solidified, the casting is separated from the 

molding and the core sand in the shakeout process. At that point, the old sand is displaced from 

the cycle as byproduct, new sand is introduced, and the cycle begins again (see Figure B-7) 

(FHWA, 2004). 

Figure B-7: How sand is reused and becomes foundry sand

Two general types of binder systems are used in metalcasting: clay-bonded systems (green sand) 

and chemically-bonded systems. Both types of sand are suitable for beneficial use but they have 

different physical and environmental characteristics (FIRST, Undated): 

 

• Green Sand molds are used to produce about 90% of casting volume in the United States. 

Green sand is composed of naturally occurring materials which are blended together: 

high quality silica sand (85% to 95%); bentonite clay (4% to10%) as a binder; a 

carbonaceous additive (2% to 10%) to improve the casting surface finish; and water (2% 

to 5%). Green sand is the most commonly used RFS for beneficial reuse. 

• Chemically bonded sand are used both in coremaking, where high strengths are necessary 

to withstand the heat of the molten metal, and in mold making. Chemically bonded sand 

is generally light in color and coarser in texture than clay bonded sand. 
B-15

Availability 

Foundries are located throughout the United States in all 50 states. The top ten foundry 

production states are Alabama, California, Illinois, Indiana, Michigan, Ohio, Pennsylvania, 

Tennessee, Texas, and Wisconsin. There are approximately 12 cement kilns that are using 

foundry sand as a raw material, and there is an industry survey under way to obtain more 

complete data (FIRST, Undated). Cement kilns in New York, Texas, Wisconsin, Ohio, Missouri, 

Maryland, Illinois, and Iowa have used foundry sand as a source of silica. 

B.6 Flue Gas Desulfurization Materials 

Figure B-8 shows the locations of portland cement facilities grinding and blending flue gas 

desulfurization materials with clinker to produce finished cement products. 

Figure B-8: U.S. Portland Cement Plants Utilizing FGD Materials (PCA, 2005b) 
B-16

Table B-5 shows the FGD gypsum production and disposition in the United States by state in 

2004. 

Table B-5: FGD Gypsum Production and Disposition, by State (2004) 

Total FGD 

Gypsum 

Production 

FGD 

Gypsum 

Landfilled 

FGD 

Gypsum 

Ponded 

FGD 

Gypsum 

Used or 

Stored 

On-Site 

FGD 

Gypsum 

Sold 

FGD 

Gypsum 

Disposed 

Off-Site 

State 

Number of 

Plants 

-------------------------------------thousand metric tons-----------------------------------------

AL 2 452 -- 405 -- 47 -- 

FL 3 1,359 -- -- 160 1,199 -- 

GA 1 29 -- -- -- 29 -- 

IA 1 20 -- -- -- 20 -- 

IL 1 160 6 -- -- 154 -- 

IN 3 879 - 4 -- 875 -- 

KY 5 1,738 -- 466 -- 1,272 -- 

NJ 1 39 -- -- -- 39 -- 

NY 1 91 6 -- -- 86 -- 

OH 2 576 -- -- -- 576 -- 

PA 4 1,539 148 -- -- 959 432 

SC 1 242 -- -- 101 141 -- 

TN 1 1,238 -- -- -- 1,238 -- 

TX 4 329 59 197 -- 73 -- 

WA 1 481 103 -- -- 378 -- 

WV 1 222 -- -- -- 222 -- 

Total 32 9,394 322 1,072 261 7,307 432 

B.7 Bottom Ash 

Physically, bottom ash is typically grey to black in color. Bottom ashes have angular particles 

with a very porous surface texture. The ash is usually a well-graded material, although variations 

in particle size distribution may be encountered in ash samples taken from the same power plant 

at different times. Bottom ash is predominantly sand-sized, usually with 50% to 90% passing a 

4.75 mm (No. 4) sieve, 10% to 60% passing a 0.42 mm (No. 40) sieve, 0% to 10% passing a 

0.075 mm (No. 200) sieve. The top size usually ranges from 19 mm (3/4 in) to 38.1 mm (1-1/2 

in) (FHWA, 1998). 

The specific gravity of dry bottom ash is a function of chemical composition, with higher carbon 

content resulting in lower specific gravity, typically in the range of 2.1 to 2.7. The dry unit 

weight of bottom ash is typically in the range of 720 to 1,600 kg/m3

 (FHWA, 1998). 

Bottom ash is composed primarily of silica, alumina and iron, with smaller percentages of 

calcium, magnesium, sulfates and other compounds. The composition is controlled primarily by 

the source of the coal and not by the type of furnace. Bottom ash derived from lignite or subbituminous coals has a higher percentage of calcium than the bottom ash from anthracite or 

bituminous coals. Sulfite content of bottom ash is typically very low (less than 1.0%). Table B-6 

presents the chemical composition of several bottom ashes from different coal sources (FHWA, 

1998). 
B-17

Table B-6: Chemical Composition of Select Bottom Ash 

Coal Type: Bituminous 

Subbituminous Lignite 

West Virginia Ohio Texas 

Location: --------------------------------percent by weight-----------------------------------------

SiO2 53.6 45.9 47.1 45.4 70.0 

Al2O3 28.3 25.1 28.3 19.3 15.9 

Fe2O3 5.8 14.3 10.7 9.7 2.0 

CaO 0.4 1.4 0.4 15.3 6.0 

MgO 4.2 5.2 5.2 3.1 1.9 

Na2O 1.0 0.7 0.8 1.0 0.6 

K2O 0.3 0.2 0.2 -- 0.1 

Table B-7 indicates production and disposition of bottom ash by state for 2004. 

Table B-7: Bottom Ash Production and Disposition, by State (2004)* 

Bottom 

Ash Total 

Bottom Ash 

Landfilled 

Bottom 

Ash 

Ponded 

Bottom 

Ash Used 

or Stored 

On-site 

Bottom 

Ash Sold 

Bottom 

Ash 

Disposed 

Offsite 

State 

Number 

of Plants 

-----------------------------------thousand metric tons------------------------------------------

AL 9 548 136 252 106 53 1 

AR 3 166 126 13 1 25 2 

AZ 6 496 373 115 - 3 6 

CO 11 237 85 3 28 18 103 

CT 3 26 - - - - 26 

DE 2 53 - - 43 8 2 

FL 17 466 201 15 33 149 68 

GA 10 451 69 205 11 166 - 

HI 1 0 - - - - 0 

IA 12 245 16 73 6 110 39 

IL 23 1,183 - 158 130 656 239 

IN 20 1,379 33 564 302 428 51 

KS 7 369 46 72 32 209 10 

KY 18 760 124 379 70 42 145 

LA 5 164 10 76 - 78 - 

MA 4 49 - - 3 36 10 

MD 8 360 32 5 50 157 116 

ME 3 149 149 - - - 0 

MI 15 356 140 2 152 49 13 

MN 10 256 17 58 131 48 1 

MO 16 766 6 355 12 391 2 

MS 5 228 131 0 44 53 - 

MT 2 251 - 245 2 4 - 

NC 16 395 31 165 37 98 64 

ND 7 762 201 247 215 46 53 

NE 6 104 51 - 2 47 5 

NH 3 51 - - (10) 58 2 

NJ 6 105 - - - 62 43 

NM 3 598 - - 247 - 351 

NV 4 184 184 - - - 0 
B-18

Bottom 

Ash Total 

Bottom Ash 

Landfilled 

Bottom 

Ash 

Ponded 

Bottom 

Ash Used 

or Stored 

On-site 

Bottom 

Ash Sold 

Bottom 

Ash 

Disposed 

Offsite 

State 

Number 

of Plants 

-----------------------------------thousand metric tons------------------------------------------

NY 11 208 39 - 92 40 37 

OH 22 1,213 18 399 266 360 169 

OK 6 232 20 13 2 85 113 

OR 1 22 13 - - 9 - 

PA 22 906 375 17 103 318 93 

SC 14 277 41 138 - 65 33 

SD 1 62 44 - - 18 - 

TN 7 350 - 110 198 39 3 

TX 19 2,665 1,724 132 83 557 168 

UT 6 403 292 111 - - - 

VA 13 596 204 79 60 73 180 

WA 1 1,129 301 - 332 496 - 

WI 13 241 52 - 43 147 1 

WV 14 566 126 98 128 201 13 

WY 5 415 275 140 - - - 

Total 410 20,442 5,685 4,238 2,952 5,405 2,162 

* No bottom ash production was reported for Alaska, California, Idaho, Rhode Island and Vermont. 

Figure B-9 presents the locations of portland cement facilities that use bottom ash and/or boiler 

slag as a raw feed in clinker production. 
B-19

Figure B-9: U.S. Portland Cement Plants Utilizing Bottom Ash/Boiler Slag (PCA, 2005b) 
B-20

B.8 Boiler Slag 

Boiler slags are predominantly single-sized and within a range of 5.0 to 0.5 mm (No. 4 to No. 40 

sieve). Ordinarily, boiler slags have a smooth surface texture, but if gases are trapped in the slag 

as it is tapped from the furnace, the quenched slag will become somewhat vesicular or porous. 

Boiler slag from the burning of lignite or subbituminous coal tends to be more porous than that 

of the eastern bituminous coals. Boiler slag is essentially the size of coarse to medium sand with 

90% to 100% passing a 4.75 mm (No. 4) sieve, 40% to 60% passing a 2.0 mm (No. 10) sieve, 

10% or less passing a 0.42 mm (No. 40) sieve, and 5% or less passing a 0.075 mm (No. 200) 

sieve (FHWA, 1998). The specific gravity of boiler slag is typically in the range of 2.3 to 2.9, 

and the dry unit weight is typically in the range of 960 to 1,440 kg/m3

 (FHWA, 1998). 

Boiler slag is composed principally of silica, alumina, and iron, with smaller percentages of 

calcium, magnesium, sulfates, and other compounds. Like bottom ash, the composition of the 

boiler slag particles is controlled primarily by the source of the coal and not by the type of 

furnace. Boiler slag derived from lignite or sub-bituminous coals has a higher percentage of 

calcium than the boiler slag from anthracite or bituminous coals. Sulfate content is usually very 

low (less than 1.0%), unless pyrites have not been removed from the boiler slag. Table B-8 

presents the chemical composition of select boiler slags (FHWA, 1998). 

Table B-8: Chemical Composition of Select Boiler Slags 

Coal Type: Bituminous Lignite 

Location: West Virginia North Dakota 

-------------------------------------percent by weight-------------------------------------------

SiO2 48.9 53.6 40.5 

Al2O3 21.9 22.7 13.8 

Fe2O3 14.3 10.3 14.2 

CaO 1.4 1.4 22.4 

MgO 5.2 5.2 5.6 

Na2O 0.7 1.2 1.7 

K2O 0.1 0.1 1.1 

Figure B-9 above presents portland cement facilities using boiler slag and/or bottom ash as a raw 

feed in clinker production. 
B-21

B.9 Steel Slag 

Steel slag aggregates are highly angular in shape and have a rough surface texture. The cooling 

rate of steel slag is sufficiently low so that crystalline compounds are generally formed. The 

predominant compounds are dicalcium silicate, tricalcium silicate, dicalcium ferrite, merwinite, 

calcium aluminate, calcium-magnesium iron oxide, and some free lime and free magnesia. The 

relative proportions of these compounds depend on the steel-making practice and the steel slag 

cooling rate. Table B-9 presents the typical chemical composition of steel furnace slag. Steel slag 

typically has a high specific gravity ranging between 3.2 and 3.6, and a unit weight of 1,600 to 

1,920 kg/m3 (FHWA, 1998). 

Table B-9: Typical Chemical Composition of Steel Furnace Slag 

Constituent Range 

(percent by weight)

CaO 40 - 52 

SiO2 10 - 19 

Al2O3 1 - 3 

MgO 5 - 10 

FeO and Fe2O3 10 - 40 

MnO 5 - 8 

S < 0.1 

P2O5 0.5 - 1 

Metallic Fe 0.5 - 10 

B.10 Cement Kiln Dust (CKD) 

CKD is a fine, dry, alkaline dust that readily absorbs water. It is composed of particles of 

unburned or partially burned feedstock materials, dehydrated clay, decarbonated (calcined) 

limestone, ash from combusted fuels, and various minerals formed during the different stages of 

the clinkering process. While composition varies from plant to plant, the primary constituents of 

CKD are calcium oxides, silicates, carbonates, potassium oxide, sulfates, chlorides, various 

metal oxides, and sodium oxide. CaO typically comprises the largest component of CKD, 

approaching as much as 50% by weight in some cases (U.S. EPA, 1993). 

CKD is very fine grained with particle diameters ranging from near zero μm to greater than 50 

μm. At least 55% of CKD measures less than 30 μm and nearly 82% is less than 50 μm (U.S. 

EPA, 1993). Because of its fine grained nature, CKD is readily entrained and transported in the 

continuous, rapidly flowing, and highly turbulent gas flow of cement kilns. To remove these 

entrained fine particles from kiln exhaust gas requires the use of complex air-pollution control 

devices such as electrostatic precipitators or fabric filters (i.e., bag houses). Wet scrubbers, 

common in other mineral processing industries, can not be used due to the chemically 

dehydrated nature and cementitious properties of CKD. Cement kiln dust collection systems are 

especially effective at removing CKD from exhaust gas, typically exhibiting 98% to nearly 100% 

removal efficiencies (U.S. EPA, 1993). 
B-22

CKD’s alkaline nature derives from its high concentrations of CaO and other alkaline 

compounds including K2O, NaOH, Na2CO3, and NaSO4. Even though CKD is a highly alkaline 

material, because it is a solid, it does not exhibit the RCRA Subtitle C hazardous waste 

characteristic of corrosivity. (This is because the RCRA hazardous identification regulations do 

not include a definition for corrosive solids.) When mixed with water, however, the resulting 

CKD and water mixtures often have pH levels greater than 12.5 and therefore do exhibit the 

corrosivity characteristic. Studies using the standard EPA leaching procedure (i.e., the Toxicity 

Characteristic Leaching Procedure or TCLP) show leachate pH levels falling in the 11 to 13 

range (U.S. EPA, 1993). 

 

Trace constituents commonly found in CKD include organic chemicals, metals, and 

radionuclides. Concentrations of heavy metals are of particular concern in the reuse of CKD 

either directly in the kiln or for other beneficial applications. Studies performed by EPA in 

preparation for its 1993 Report to Congress consistently found eight Toxicity Characteristic (TC) 

metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) and nine 

other metals (antimony, beryllium, copper, manganese, nickel, strontium, thallium, vanadium, 

and zinc) present in CKD samples. The predominant metals were antimony, barium, lead, 

manganese, strontium, thallium, and zinc. The others were found in lesser concentrations. While 

these metals were consistently present in the CKD samples, in general, their concentrations were 

well below the regulatory TCLP/Toxicity Characteristic levels (U.S. EPA, 1993). A few of the 

samples, however, did yield results above the regulatory limits for lead (4 of 244 samples), 

selenium (2 of 129 samples), barium (1 of 88 samples), and cadmium (1 of 88 samples) (U.S. 

EPA, 1993). 

Table B-10 illustrates the typical chemical composition of CKD (FHWA, 1998). 

Table B-10: Typical Chemical Composition of CKD

Fresh Stockpiled 

Parameter Sample 1 Sample 2 

-------------------------------------percent by weight-------------------------------------------

CaO 40.5 31.4 44.2 

Free Lime 4.4 0.0 0.0 

SiO2 14.5 11.7 11.9 

Al2O3 4.1 3.18 3.24 

MgO 1.55 0.97 1.73 

Na2O3 0.44 0.13 0.27 

K2O 4.66 1.65 2.92 

Fe2O3 2.00 2.16 1.45 

SO3 6.50 8.24 2.40 

Loss on Ignition, 

105°C 

22.9 40.4 30.2 

Figure B-10 below shows the amount of CKD disposed in landfills from 1990 through 2004 and 

compares the amount of CKD disposed in landfills to clinker production during this same time 

period. The graph below represents CKD recovered from CKD scrubbers and does not reflect 

any CKD automatically re-ducted back into the kiln. 
B-23

Figure B-10 CKD Landfilled; CKD Landfilled versus Clinker Produced 
APPENDIX C: 

CEMENT AND RMC PRODUCERS 
C-1 

Table C-1: U.S. Cement Plants (PCA, 2006)

Company City State 

CEMEX Demopolis AL 

Holcim (US) Inc. Theodore AL 

Lafarge North America, Inc. Calera AL 

Lehigh SE Cement Company Roberta AL 

National Cement Company Of Alabama Ragland AL 

California Portland Cement Company Rillito AZ 

Phoenix Cement Company (a.k.a., Salt River 

Materials) 

Clarkdale AZ 

Ash Grove Cement Company Foreman AR 

California Portland Cement Company Colton CA 

California Portland Cement Company Mojave CA 

CEMEX Victorville CA 

Texas Industries, Inc. Riverside CA 

Hanson Permanente Cement (recently purchased by 

Lehigh) 

Cupertino CA 

Lehigh Southwest Cement Company Tehachapi CA 

Lehigh Southwest Cement Company Redding CA 

Mitsubishi Cement Corporation Lucerne Valley CA 

National Cement Company Of California Lebec CA 

RMC Pacific Materials, Inc. (now part of CEMEX) Davenport CA 

Texas Industries, Inc. (TXI Riverside Cement) Oro Grande and Crestmore CA 

CEMEX Lyons CO 

Holcim (US) Inc. (facility is closed) LaPorte CO 

Holcim (US) Inc. Florence CO 

CEMEX Brooksville FL 

Florida Rock Industries, Inc. Newberry FL 

Lafarge North America, Inc. (owned by Florida 

Rock Industries) 

Palmetto FL 

Lafarge North America, Inc. (owned by Florida 

Rock Industries) 

Tampa FL 

Rinker Materials (owned by CEMEX) Brooksville FL 

Rinker Materials (owned by CEMEX) Miami FL 

Tarmac America, Inc. Medley FL 

CEMEX Clinchfield GA 

Lafarge North America, Inc. Atlanta GA 

Ash Grove Cement Company Inkom ID 

Centex Construction Products, Inc. (Eagle 

Materials) 

La Salle IL 

Dixon-Marquette Cement Company (St Mary’s 

Cement) 

Dixon IL 

Lafarge North America, Inc. Grand Chain IL 

Lone Star Industries, Inc. (Buzzi Unicem) Oglesby IL 

Essroc Cement Corp. Speed IN 

Essroc Cement Corp. Logansport IN 

Lehigh Cement Company Mitchell IN 

Lone Star Industries, Inc. (Buzzi Unicem) Greencastle IN 
C-2 

Company City State 

Holcim (US) Inc. Mason City IA 

Lafarge North America, Inc. Buffalo IA 

Lehigh Cement Company Mason City IA 

Ash Grove Cement Company Chanute KS 

Lafarge North America, Inc. Fredonia KS 

Monarch Cement Company Humboldt KS 

RC Cement Company, Inc. Independence KS 

Kosmos Cement Company (operated by CEMEX) Louisville KY 

Lone Star Industries, Inc. (Buzzi Unicem) New Orleans LA 

Dragon Products Company Thomaston ME 

Essroc Cement Corp. Frederick MD 

Lehigh Cement Company Union Bridge MD 

St. Lawrence Cement Company Hagerstown MD 

CEMEX Charlevoix MI 

Essroc Cement Corp. Essexville MI 

Holcim (US) Inc. Dundee MI 

Lafarge North America, Inc. Alpena MI 

St. Marys Cement, Inc. (U.S.) Detroit MI 

Holcim (US) Inc. Artesia MS 

Continental Cement Company, Inc. Hannibal MO 

Holcim (US) Inc. Clarksville MO 

Lafarge North America, Inc. Sugar Creek MO 

Lone Star Industries, Inc. (Buzzi Unicem) Cape Girardeau MO 

RC Cement Company, Inc. (Buzzi Unicem) Fustus MO 

Ash Grove Cement Company Montana City MT 

Holcim (US) Inc. Three Forks MT 

Ash Grove Cement Company Louisville NE 

Centex Construction Products, Inc. Fernley NV 

Royal Cement Company, Inc. (facility closed) Logandale NV 

GCC Rio Grande Tijeras NM 

Lehigh Cement Company Glens Falls NY 

Lehigh Cement Company Cementon NY 

Lafarge North America, Inc. Ravena NY 

St. Lawrence Cement Company Catskill NY 

CEMEX Fairborn OH 

Lafarge North America, Inc. Paulding OH 

Holcim (US) Inc. Ada OK 

Lafarge North America, Inc. Tulsa OK 

Lone Star Industries, Inc. (Buzzi Unicem) Pryor OK 

Ash Grove Cement Company Durkee OR 

Armstrong Cement & Sup. Corp. Cabot PA 

CEMEX Wampum PA 

Essroc Cement Corp. Nazareth PA 

Essroc Cement Corp. Bessemer PA 

Giant Cement Holding, Inc. Bath PA 

Lafarge North America, Inc. Whitehall PA 

Lehigh Cement Company Evansville PA 
C-3 

Company City State 

Lehigh Cement Company York PA 

RC Cement Company, Inc. (Buzzi Unicem) Stockertown PA 

Giant Cement Holding, Inc. Harleyville SC 

Holcim (US) Inc. Holly Hill SC 

Lafarge North America, Inc. Harleyville SC 

GCC Dacotah Rapid City SD 

CEMEX Knoxville TN 

RC Cement Company, Inc. (Buzzi Unicem) Chattanooga TN 

Alamo Cement Company San Antonio TX 

Capitol Aggregates, Ltd. San Antonio TX 

CEMEX Odessa TX 

CEMEX New Braunfels TX 

Texas Industries Inc. New Braunfels TX 

Texas Industries Inc. Midlothian TX 

Texas-Lehigh Cement Company Buda TX 

Holcim (US) Inc. Midlothian TX 

Lehigh Cement Company Waco TX 

Lone Star Industries, Inc. (Buzzi Unicem) Maryneal TX 

North Texas Cement Company, L.P. (Ash Grove 

Texas LP) 

Midlothian TX 

Ash Grove Cement Company Leamington UT 

Holcim (US) Inc. Morgan UT 

Roanoke Cement Company Cloverdale VA 

Ash Grove Cement Company Seattle WA 

Lafarge North America, Inc. Seattle WA 

Lehigh Northwest Cement Company Bellingham WA 

Essroc Cement Corp. Martinsburg WV 

Centex Construction Products, Inc. Laramie WY 
C-4 

Table C-2: U.S. Blast Furnace Slag Processors (van Oss, 2004b) 

Company City State 

Fritz Enterprises, Inc. Fairfield AL 

Holcim (US) Inc. Birmingham (Fairfield) AL 

Civil & Marine, Inc. (Hanson Slag 

Cement) 

Cape Canaveral FL 

Florida Rock Industries, Inc. Tampa FL 

Rinker Materials Corp. Miami FL 

Titan Florida, Inc. Medley FL 

Lafarge North America, Inc. Chicago IL 

Lafarge North America, Inc. Joppa IL 

Holcim (US) Inc. Gary IN 

Lafarge North America, Inc. East Chicago IN 

Levy Co., Inc., The Burns Harbor IN 

Levy Co., Inc., The East Chicago IN 

Levy Co., Inc., The Gary IN 

Mountain Enterprises, Inc. Ashland KY 

Stein, Inc. Ashland KY 

Buzzi Unicem USA, Inc. New Orleans LA 

Lafarge North America, Inc. Sparrows Point MD 

MultiServ Sparrows Point MD 

Edward C. Levy Co. Detroit MI 

Edward C. Levy Co. Detroit MI 

St. Marys Cement, Inc. Detroit MI 

St. Lawrence Cement, Inc. Camden NJ 

Buffalo Crushed Stone, Inc. Woodlawn NY 

Glens Falls-Lehigh Cement Co. Cementon NY 

Essroc Corp. Middlebranch OH 

Lafarge North America, Inc. Cleveland (Cuyahoga Co.) OH 

Lafarge North America, Inc. Lordstown OH 

Lafarge North America, Inc. McDonald OH 

Lafarge North America, Inc. Salt Springs (Youngstown) OH 

Lafarge North America, Inc. Warren OH 

Stein, Inc. Cleveland OH 

Stein, Inc. Lorain OH 

Tube City IMS Corporation Middletown OH 

Tube City IMS Corporation Mingo Junction OH 

Beaver Valley Slag Aliquippa PA 

Lafarge North America, Inc. West Mifflin PA 

Lafarge North America, Inc. West Mifflin (Brown Reserve) PA 

Lafarge North America, Inc. Whitehall PA 

Lehigh Cement Evansville PA 

Tube City-IMS, IMS Division Bethlehem PA 

MultiServ Geneva (Provo) UT 

Lafarge North America, Inc. Seattle WA 

Holcim (US) Inc. Weirton WV 

Lafarge North America, Inc. Weirton WV 
C-5 

Table C-3: U.S. Steel Slag Processors (van Oss, 2004b) 

Company City State 

AMSI Holsopple PA 

Barfield Enterprises, Inc. La Place LA 

Barfield Enterprises, Inc. Lone Star TX 

Beaver Valley Slag Aliquippa PA 

Beaver Valley Slag (Thor Mill Services) Roanoke VA 

Blackheart Slag Company Muscatine (Montpelier) IA 

Border Steel, Inc. El Paso TX 

Edward C. Levy Company Decatur (Trinity) AL 

Edward C. Levy Company Butler IN 

Edward C. Levy Company Columbia City IN 

Edward C. Levy Company Crawfordsville IN 

Edward C. Levy Company Detroit MI 

Edward C. Levy Company Detroit MI 

Edward C. Levy Company Canton OH 

Edward C. Levy Company Delta OH 

Edward C. Levy Company Huger SC 

Fritz Enterprises, Inc. Fairfield AL 

Gerdau Ameristeel Corporation Jacksonville FL 

Gerdau Ameristeel Corporation Charlotte NC 

Levy Company, Inc., The Burns Harbor IN 

MultiServ Birmingham AL 

MultiServ Tuscaloosa AL 

MultiServ Blytheville AR 

MultiServ Blytheville (Armorel) AR 

MultiServ Pueblo CO 

MultiServ Wilton (Muscatine) IA 

MultiServ East Chicago IN 

MultiServ Indiana Harbor IN 

MultiServ Ghent KY 

MultiServ Sparrows Point MD 

MultiServ Ahoskie (Cofield) NC 

MultiServ Canton OH 

MultiServ Mansfield OH 

MultiServ Warren OH 

MultiServ Braddock (Mon Valley) PA 

MultiServ Butler PA 

MultiServ Coatesville PA 

MultiServ Koppel PA 

MultiServ Steelton PA 

MultiServ Midlothian TX 

MultiServ Geneva (Provo) UT 

MultiServ Seattle WA 

Stein, Inc. Sterling IL 

Stein, Inc. Ashland KY 

Stein, Inc. Cleveland OH 
C-6 

Company City State 

Stein, Inc. Loraine OH 

Tube City IMS Corporation Birmingham AL 

Tube City IMS Corporation Newport AR 

Tube City IMS Corporation Rancho Cucamonga CA 

Tube City IMS Corporation Portage IN 

Tube City IMS Corporation Norfolk NE 

Tube City IMS Corporation Perth Amboy NJ 

Tube City IMS Corporation Sayreville NJ 

Tube City IMS Corporation Middletown OH 

Tube City IMS Corporation Mingo Junction OH 

Tube City IMS Corporation Youngstown OH 

Tube City IMS Corporation Sand Springs OK 

Tube City IMS Corporation Cayce SC 

Tube City IMS Corporation Knoxville TN 

Tube City IMS Corporation Seguin TX 

Tube City IMS Corporation Petersburg VA 

Tube City-IMS, IMS Division Axis AL 

Tube City-IMS, IMS Division Fort Smith AR 

Tube City-IMS, IMS Division Newport AR 

Tube City-IMS, IMS Division Kingman AZ 

Tube City-IMS, IMS Division Claymont DE 

Tube City-IMS, IMS Division Cartersville GA 

Tube City-IMS, IMS Division Wilton (Muscatine) IA 

Tube City-IMS, IMS Division Kankakee IL 

Tube City-IMS, IMS Division Peoria IL 

Tube City-IMS, IMS Division Laplace LA 

Tube City-IMS, IMS Division Jackson MI 

Tube City-IMS, IMS Division Monroe MI 

Tube City-IMS, IMS Division St. Paul MN 

Tube City-IMS, IMS Division Jackson MS 

Tube City-IMS, IMS Division Charlotte NC 

Tube City-IMS, IMS Division Perth Amboy NJ 

Tube City-IMS, IMS Division Sayreville NJ 

Tube City-IMS, IMS Division Auburn NY 

Tube City-IMS, IMS Division Marion OH 

Tube City-IMS, IMS Division McMinnville OR 

Tube City-IMS, IMS Division Portland OR 

Tube City-IMS, IMS Division Bethlehem PA 

Tube City-IMS, IMS Division Bridgeville PA 

Tube City-IMS, IMS Division Midland PA 

Tube City-IMS, IMS Division Monroeville PA 

Tube City-IMS, IMS Division New Castle PA 

Tube City-IMS, IMS Division Park Hill (Johnstown) PA 

Tube City-IMS, IMS Division Pricedale PA 

Tube City-IMS, IMS Division Reading PA 

Tube City-IMS, IMS Division Darlington SC 

Tube City-IMS, IMS Division Georgetown SC 
C-7 

Company City State 

Tube City-IMS, IMS Division Jackson TN 

Tube City-IMS, IMS Division Beaumont TX 

Tube City-IMS, IMS Division Jewett TX 

Tube City-IMS, IMS Division Longview TX 

Tube City-IMS, IMS Division Plymouth UT 

Tube City-IMS, IMS Division Saukville WI 

Tube City-IMS, IMS Division Weirton WV 
C-8 

Table C-4: U.S. Facilities Producing Coal Fly Ash (U.S. DOE, 2004b) 

Utility Name Plant Name City State 

Alabama Electric Coop, Inc. Charles R Lowman Leroy AL 

Alabama Power Co. Barry Bucks AL 

Alabama Power Co. Gadsden East Gadsden AL 

Alabama Power Co. Gorgas Parrish AL 

Alabama Power Co. Greene County Demopolis AL 

Alabama Power Co. E C Gaston Wilsonville AL 

Alabama Power Co. James H Miller Jr Quinton AL 

International Paper Co.-Courtland International Paper Courtland Mill Courtland AL 

Tennessee Valley Authority Colbert Tuscumbia AL 

Tennessee Valley Authority Widows Creek Stevenson AL 

Entergy Arkansas, Inc. White Bluff Redfield AR 

Entergy Arkansas, Inc. Independence Newark AR 

Southwestern Electric Power Co. Flint Creek Gentry AR 

Arizona Electric Pwr Coop, Inc. Apache Station Cochise AZ 

Arizona Public Service Co. Cholla Joseph City AZ 

Salt River Proj Ag I & P Dist Navajo Page AZ 

Salt River Proj Ag I & P Dist Coronado St Johns AZ 

UNS Electric, Inc. H Wilson Sundt Generating Station Cherry Bell Station AZ 

UNS Electric, Inc. Springerville Springerville AZ 

ACE Cogeneration Co. ACE Cogeneration Facility Trona CA 

Colorado Springs, City of Martin Drake Colorado Springs CO 

Colorado Springs, City of Ray D Nixon Fountain CO 

Platte River Power Authority Rawhide Wellington CO 

Public Service Co. of Colorado Arapahoe Denver CO 

Public Service Co. of Colorado Cherokee Denver CO 

Public Service Co. of Colorado Comanche Pueblo CO 

Public Service Co. of Colorado Valmont Boulder CO 

Public Service Co. of Colorado Hayden Hayden CO 

Public Service Co. of Colorado Pawnee Brush CO 

Tri-State G & T Assn, Inc. Nucla Nucla CO 

Tri-State G & T Assn, Inc. Craig Craig CO 

AES Thames LLC AES Thames Uncasville CT 

NRG Devon Operations, Inc. Devon Station Devon CT 

NRG Norwalk Harbor Operations NRG Norwalk Harbor South Norwalk CT 

PSEG Power Connecticut LLC Bridgeport Station Bridgeport CT 

Conectiv Energy Supply, Inc. Edge Moor Edgemoor DE 

Indian River Operations, Inc. Indian River Operations Millsboro DE 

Central Power & Lime, Inc. Central Power & Lime Brooksville FL 

Florida Power & Light Co. Cape Canaveral Cocoa FL 

Florida Power & Light Co. Riviera Riviera Beach FL 

Florida Power & Light Co. Sanford Lake Monroe FL 

Florida Power & Light Co. Manatee Parrish FL 

Gainesville Regional Utilities Deerhaven Generating Station Alachua FL 

Gulf Power Co. Crist Pensacola FL 

Gulf Power Co. Lansing Smith Southport FL FL 
C-9 

Utility Name Plant Name City State 

Indiantown Cogeneration LP Indiantown Cogen Facility Indiantown FL 

JEA St Johns River Power Park Oceanway FL 

JEA Northside Generating Station Oceanway FL 

Orlando Utilities Comm Stanton Energy Center Alafaya Branch FL 

PG&E Operating Service Co. Cedar Bay Generating LP Jacksonville FL 

Progress Energy Florida, Inc. Crystal River Crystal River FL 

Progress Energy Florida, Inc. P L Bartow St Petersburg FL 

Seminole Electric Coop Inc. Seminole Bostwick FL 

Tampa Electric Co. Big Bend Ruskin FL 

Georgia Power Co. Bowen Taylorsville GA 

Georgia Power Co. Hammond Coosa GA 

Georgia Power Co. Harllee Branch Milledgeville GA 

Georgia Power Co. Jack McDonough Smyrna GA 

Georgia Power Co. Mitchell Putney GA 

Georgia Power Co. Yates Sargent GA 

Georgia Power Co. Wansley Roopville GA 

Georgia Power Co. Scherer Juliette GA 

International Paper Co. International Paper Savanna Mill Savannah GA 

Savannah Electric & Power Co. Kraft Port Wentworth GA 

Savannah Electric & Power Co. McIntosh Rincon GA 

AES Corp AES Hawaii Kapolei HI 

Archer Daniels Midland Co. 

Archer Daniels Midland Cedar 

Rapids Cedar Rapids IA 

Interstate Power & Light Co. Milton L Kapp Clinton IA 

Interstate Power & Light Co. Prairie Creek Cedar Rapids IA 

Interstate Power & Light Co. Sutherland Marshalltown IA 

Interstate Power & Light Co. Burlington Burlington IA 

Interstate Power and Light Ottumwa Ottumwa IA 

MidAmerican Energy Co. Riverside Bettendorf IA 

MidAmerican Energy Co. Council Bluffs Council Bluffs IA 

MidAmerican Energy Co. George Neal North Salix IA 

MidAmerican Energy Co. Louisa Muscatine IA 

MidAmerican Energy Co. George Neal South Salix IA 

Muscatine, City of Muscatine Plant #1 Muscatine IA 

Ameren Energy Generating Co. Coffeen Coffeen IL 

Ameren Energy Generating Co. Hutsonville Hutsonville IL 

Ameren Energy Generating Co. Meredosia Meredosia IL 

Ameren Energy Generating Co. Newton Newton IL 

Ameren Energy Resources 

Generating E D Edwards Bartonville IL 

Ameren Energy Resources 

Generating Duck Creek Canton IL 

Archer Daniels Midland Co. Archer Daniels Midland Decatur Decatur IL 

Dominion Energy Services Co. Kincaid Generation LLC Kincaid IL 

Dynegy Midwest Generation, Inc. Baldwin Energy Complex Baldwin IL 

Dynegy Midwest Generation, Inc. Havana Havana IL 

Dynegy Midwest Generation, Inc. Hennepin Power Station Hennepin IL 

Dynegy Midwest Generation, Inc. Vermilion Oakwood IL 
C-10

Utility Name Plant Name City State 

Dynegy Midwest Generation, Inc. Wood River East Alton IL 

Electric Energy, Inc. Joppa Steam Joppa IL 

Midwest Generations EME LLC Joliet 29 Joliet IL 

Midwest Generations EME LLC Crawford Chicago IL 

Midwest Generations EME LLC Joliet 9 Joliet IL 

Midwest Generations EME LLC Powerton Pekin IL 

Midwest Generations EME LLC Waukegan Waukegan IL 

Midwest Generations EME LLC Will County Romeoville IL 

Midwest Generations EME LLC Fisk Street Chicago IL 

Southern Illinois Power Coop Marion Marion IL 

Springfield, City of Dallman Springfield IL 

Alcoa Power Generating, Inc. Warrick Newburgh IN 

Hoosier Energy R E C, Inc. Frank E Ratts Petersburg IN 

Hoosier Energy R E C, Inc. Merom Sullivan IN 

Indiana Michigan Power Co. Tanners Creek Lawrenceburg IN 

Indiana Michigan Power Co. Rockport Rockport IN 

Indiana-Kentucky Electric Corp Clifty Creek Madison IN 

Indianapolis Power & Light Co. Harding Street Indianapolis IN 

Indianapolis Power & Light Co. Eagle Valley Martinsville IN 

Indianapolis Power & Light Co. AES Petersburg Petersburg IN 

Northern Indiana Pub Serv Co. Bailly Chesterton IN 

Northern Indiana Pub Serv Co. Michigan City Michigan City IN 

Northern Indiana Pub Serv Co. R M Schahfer Wheatfield IN 

PSI Energy, Inc. Cayuga Cayuga IN 

PSI Energy, Inc. Edwardsport Edwardsport IN 

PSI Energy, Inc. R Gallagher New Albany IN 

PSI Energy, Inc. Wabash River Terre Haute IN 

PSI Energy, Inc. Gibson Mt Carmel IN 

Southern Indiana Gas & Elec Co. F B Culley Newburgh IN 

Southern Indiana Gas & Elec Co. A B Brown Mount Vernon IN 

State Line Energy LLC State Line Energy Hammond IN 

Kansas City, City of Quindaro Fairfax Station KS 

Kansas City, City of Nearman Creek Robert L Roberts STA KS 

Kansas City Power & Light Co. La Cygne La Cygne KS 

Sunflower Electric Power Corp Holcomb Holcomb KS 

Westar Energy Lawrence Energy Center Lawrence, Kansas KS 

Westar Energy Tecumseh Energy Center Tecumseh KS 

Westar Energy Jeffrey Energy Center Belvue KS 

Cincinnati Gas & Electric Co. East Bend Rabbit Hash KY 

East Kentucky Power Coop, Inc. Cooper Burnside KY 

East Kentucky Power Coop, Inc. Dale Winchester KY 

East Kentucky Power Coop, Inc. H L Spurlock Maysville KY 

Kentucky Power Co. Big Sandy Louisa KY 

Kentucky Utilities Co. E W Brown Burgin KY 

Kentucky Utilities Co. Ghent Ghent KY 

Kentucky Utilities Co. Green River Central City KY 

Kentucky Utilities Co. Tyrone Versailles KY 
C-11

Utility Name Plant Name City State 

Louisville Gas & Electric Co. Cane Run Louisville KY 

Louisville Gas & Electric Co. Mill Creek Louisville KY 

Louisville Gas & Electric Co. Trimble County Bedford KY 

Owensboro, City of Elmer Smith Daviess KY 

Tennessee Valley Authority Paradise Drakesboro KY 

Tennessee Valley Authority Shawnee West Paducah KY 

Western Kentucky Energy Corp Kenneth C Coleman Hawesville KY 

Western Kentucky Energy Corp HMP&L Station Two Henderson Sebree KY 

Western Kentucky Energy Corp R D Green Sebree KY 

Western Kentucky Energy Corp D B Wilson Centertown KY 

Cleco Power LLC Dolet Hills Mansfield LA 

Cleco Power LLC Rodemacher Lena LA 

Entergy Gulf States, Inc. R S Nelson Lake Charles LA 

Louisiana Generating LLC Big Cajun 2 New Roads LA 

Consolidated Edison E MA, Inc. West Springfield West Springfield MA 

Dominion Energy New England Brayton Point Somerset MA 

Mirant Canal LLC Canal Sandwich MA 

Northeast Generation Services Co. Mount Tom Holyoke MA 

Somerset Power LLC Somerset Station Somerset MA 

U S Gen New England, Inc. Salem Harbor Salem MA 

AES WR Ltd Partnership 

AES Warrior Run Cogeneration 

Facility Cumberland MD 

Allegheny Energy Supply Co. LLC R Paul Smith Power Station Williamsport MD 

Constellation Power Source Gen Brandon Shores Baltimore MD 

Constellation Power Source Gen C P Crane Baltimore MD 

Constellation Power Source Gen Herbert A Wagner Baltimore MD 

Mirant Mid-Atlantic LLC Chalk Point LLC Aquasco MD 

Mirant Mid-Atlantic LLC Dickerson Dickerson MD 

Mirant Mid-Atlantic LLC Morgantown Generating Plant Newburg MD MD 

Vienna Operations, Inc. Vienna Operations Vienna MD 

FPL Energy Wyman LLC William F Wyman Yarmouth ME 

MeadWestvaco Corp Rumford Cogeneration Rumford ME 

S D Warren Co. Somerset Plant Skowhegan ME 

Consumers Energy Co. B C Cobb Muskegon MI 

Consumers Energy Co. Dan E Karn Essexville MI 

Consumers Energy Co. J H Campbell West Olive MI 

Consumers Energy Co. J C Weadock Essexville MI 

Consumers Energy Co. J R Whiting Erie MI 

Detroit Edison Co. Harbor Beach Harbor Beach MI 

Detroit Edison Co. Monroe Monroe MI 

Detroit Edison Co. River Rouge River Rouge MI 

Detroit Edison Co. St Clair East China MI 

Detroit Edison Co. Trenton Channel Trenton MI 

Detroit Edison Co. Belle River Belle River MI 

Lansing, City of Eckert Station Lansing MI 

Lansing, City of Erickson Station Lansing MI 

MeadWestvaco Corp Escanaba Paper Company Escanaba MI 

Wisconsin Electric Power Co. Presque Isle Marquette MI 
C-12

Utility Name Plant Name City State 

Allete, Inc. Syl Laskin Aurora MN 

Allete, Inc. Clay Boswell Cohasset MN 

Allete, Inc. Taconite Harbor Energy Center Schroeder MN 

Cleveland Cliffs, Inc. Silver Bay Power Silver Bay MN 

Northern States Power Co. Black Dog Burnsville MN 

Northern States Power Co. High Bridge St. Paul MN 

Northern States Power Co. Allen S King Bayport MN 

Northern States Power Co. Riverside Minneapolis MN 

Northern States Power Co. Sherburne County Becker MN 

Otter Tail Power Co. Hoot Lake Fergus Falls MN 

Ameren UE Labadie Labadie MO 

Ameren UE Meramec St Louis MO 

Ameren UE Sioux West Alton MO 

Ameren UE Rush Island Festus MO 

Aquila, Inc. Sibley Sibley MO 

Aquila, Inc. Lake Road St Joseph MO 

Associated Electric Coop, Inc. New Madrid Marston MO 

Associated Electric Coop, Inc. Thomas Hill Moberly MO 

Empire District Electric Co. Asbury Asbury MO 

Independence, City of Blue Valley Independence MO 

Kansas City Power & Light Co. Montrose Clinton MO 

Kansas City Power & Light Co. Iatan Weston MO 

Sikeston, City of Sikeston Power Station Sikeston MO 

Springfield, City of James River Power Station Springfield MO 

Springfield, City of Southwest Power Station Springfield MO 

Entergy Mississippi, Inc. Gerald Andrus Greenville MS 

Mississippi Power Co. Jack Watson Gulfport MS 

Mississippi Power Co. Victor J Daniel Jr Escatawpa MS 

South Mississippi El Pwr Assn R D Morrow Purvis MS 

Tractebel Power, Inc. Red Hills Generating Facility Ackerman MS 

Weyerhaeuser Co. Weyerhaeuser Columbus MS Columbus MS 

PPL Montana LLC J E Corette Plant Billings MT 

PPL Montana LLC Colstrip Colstrip MT 

Carolina Power & Light Co. Asheville Arden NC 

Carolina Power & Light Co. Cape Fear Moncure NC 

Carolina Power & Light Co. Lee Goldsboro NC 

Carolina Power & Light Co. Roxboro Semora NC 

Carolina Power & Light Co. L V Sutton Wilmington NC 

Carolina Power & Light Co. W H Weatherspoon Lumberton NC 

Carolina Power & Light Co. Mayo Roxboro NC 

Cogentrix of N Carolina, Inc. Cogentrix Southport Southport NC 

Cogentrix of Rocky Mount, Inc. 

Cogentrix Dwayne Collier Battle 

Cogen Battleboro NC 

Duke Energy Corp G G Allen Belmont NC 

Duke Energy Corp Buck Spencer NC 

Duke Energy Corp Cliffside Cliffside NC 

Duke Energy Corp Dan River Eden NC 

Duke Energy Corp Marshall Terrell NC 
C-13

Utility Name Plant Name City State 

Duke Energy Corp Riverbend Mount Holly NC 

Duke Energy Corp Belews Creek Walnut Cove NC 

Westmoreland-LG&E Partners 

Westmoreland-LG&E Roanoke 

Valley I Weldon NC 

Basin Electric Power Coop Leland Olds Stanton ND 

Basin Electric Power Coop Antelope Valley Beulah ND 

Great River Energy Stanton Stanton ND 

Great River Energy Coal Creek Underwood ND 

MDU Resources Group, Inc. R M Heskett Mandan ND 

Minnkota Power Coop, Inc. Milton R Young Center ND 

Otter Tail Power Co. Coyote Beulah ND 

Fremont, City of Lon Wright Fremont NE 

Grand Island, City of Platte Grand Island NE 

Nebraska Public Power District Sheldon Hallam NE 

Nebraska Public Power District Gerald Gentleman Sutherland NE 

Omaha Public Power District North Omaha Florence NE 

Omaha Public Power District Nebraska City Nebraska City NE 

Public Service Co. of NH Merrimack Concord NH 

Public Service Co. of NH Schiller Portsmouth NH 

Public Service Co. of NH Newington Portsmouth NH 

Atlantic City Electric Co. B L England Marmora NJ 

Atlantic City Electric Co. Deepwater Penns Grove NJ 

Chambers Cogeneration LP Chambers Cogeneration LP Carneys Point NJ 

Logan Generating Co. LP Logan Generating Plant Swedesboro NJ 

PSEG Fossil LLC PSEG Hudson Generating Station Jersey City NJ 

PSEG Fossil LLC PSEG Mercer Generating Station Trenton NJ 

Arizona Public Service Co. Four Corners Fruitland NM 

Public Service Co. of NM San Juan Waterflow NM 

Tri-State G & T Assn, Inc. Escalante Prewitt NM 

Nevada Power Co. Reid Gardner Moapa NV 

Sierra Pacific Power Co. North Valmy Valmy NV 

Southern California Edison Co. Mohave Laughlin NV 

AES Cayuga LLC AES Cayuga Lansing NY 

AES Greenidge LLC AES Greenidge LLC Dresden NY 

AES Somerset LLC AES Somerset LLC Barker NY 

AES Westover LLC AES Westover Johnson City NY 

Astoria Generating Co. LP Astoria Generating Station Woolsey NY 

Dunkirk Power LLC Dunkirk Generating Station Central Avenue NY 

Dynegy Northeast Gen, Inc. Danskammer Generating Station Newburgh NY 

Dynegy Northeast Gen, Inc. Roseton Generating Station Newburgh NY 

Eastman Kodak Co. Kodak Park Site Rochester NY 

Mirant New York, Inc. Lovett Tomkins Cove NY 

NRG Huntley Operations, Inc. C R Huntley Generating Station Tonawanda NY 

Rochester Gas & Electric Corp Rochester 7 Rochester NY 

American Mun Power-Ohio, Inc. Richard Gorsuch Marietta OH 

Cardinal Operating Co. Cardinal Brilliant OH 

Cincinnati Gas & Electric Co. Walter C Beckjord New Richmond OH 

Cincinnati Gas & Electric Co. Miami Fort North Bend OH 
C-14

Utility Name Plant Name City State 

Cincinnati Gas & Electric Co. W H Zimmer Cincinnati OH 

Cleveland Electric Illum Co. Ashtabula Ashtabula OH 

Cleveland Electric Illum Co. Eastlake Eastlake OH 

Cleveland Electric Illum Co. Lake Shore Cleveland OH 

Columbus Southern Power Co. Conesville Conesville OH 

Columbus Southern Power Co. Picway Lockbourne OH 

Dayton Power & Light Co. O H Hutchings Miamisburg OH 

Dayton Power & Light Co. J M Stuart Aberdeen OH 

Dayton Power & Light Co. Killen Station Manchester OH 

Hamilton, City of Hamilton Hamilton OH 

Ohio Edison Co. R E Burger Shadyside OH 

Ohio Edison Co. W H Sammis Stratton OH 

Ohio Power Co. Muskingum River Beverly OH 

Ohio Power Co. General James M Gavin Cheshire OH 

Ohio Valley Electric Corp Kyger Creek Cheshire OH 

Orion Power Midwest LP Avon Lake Avon Lake OH 

Orion Power Midwest LP Niles Niles OH 

Toledo Edison Co. Bay Shore Oregon OH 

AES Shady Point, LLC AES Shady Point Panama OK 

Fort James Operating Co. Muskogee Mill Muskogee OK 

Grand River Dam Authority GRDA Chouteau OK 

Oklahoma Gas & Electric Co. Muskogee Ft Gibson OK 

Oklahoma Gas & Electric Co. Sooner Morrison OK 

Public Service Co. of Oklahoma Northeastern Oologah OK 

Western Farmers Elec Coop, Inc. Hugo Fort Towson OK 

Portland General Electric Co. Boardman Boardman OR 

AES Beaver Valley 

AES Beaver Valley Partners Beaver 

Valley Monaca PA 

Allegheny Energy Supply Co. LLC Armstrong Power Station Kittaning PA 

Allegheny Energy Supply Co. LLC Hatfields Ferry Power Station Masontown PA 

Allegheny Energy Supply Co. LLC Mitchell Power Station Courtney PA 

Exelon Generation Co. LLC Cromby Generating Station Phoenixville PA 

Exelon Generation Co. LLC Delaware Generating Station Philadelphia PA 

Exelon Generation Co. LLC Eddystone Generating Station Chester PA 

Exelon Generation Co. LLC Schuylkill Generating Station Philadelphia PA 

Midwest Generation Homer City Station Homer City PA 

Orion Power Midwest LP New Castle Plant West Pittsburg PA 

Orion Power Midwest LP Cheswick Power Plant Cheswick PA 

P H Glatfelter Co. P H Glatfelter Spring Grove PA 

Pennsylvania Power Co. Bruce Mansfield Shippingport PA 

PG&E National Energy Group Northhampton Generating LP Northampton PA 

PPL Corp PPL Brunner Island York Haven PA 

PPL Corp PPL Martins Creek Martins Creek PA 

PPL Corp PPL Montour Washingtonville PA 

Reliant Energy Mid-Atlantic PH Portland Portland PA 

Reliant Energy Mid-Atlantic PH Titus Birdboro PA 

Reliant Energy Mid-Atlantic PH Shawville Clearfield PA 

Reliant Energy NE Mgt Co. Conemaugh New Florence PA 
C-15

Utility Name Plant Name City State 

Reliant Energy NE Mgt Co. Keystone Shelocta PA 

Sunbury Generation LLC WPS Energy Servs Sunbury Gen Shamokin Dam PA 

TIFD VIII-W, Inc. Colver Power Project Colver PA 

Zinc Corp of America G F Weaton Power Station Monaca PA 

Carolina Power & Light Co. H B Robinson Hartsville SC 

Duke Energy Corp W S Lee Pelzer SC 

International Paper Co.-Eastovr International Paper Eastover Facility Eastover SC 

South Carolina Electric&Gas Co. Canadys Steam Canadys SC 

South Carolina Electric&Gas Co. McMeekin Irmo SC 

South Carolina Electric&Gas Co. Urquhart Urquhart SC 

South Carolina Electric&Gas Co. Wateree Eastover SC 

South Carolina Genertg Co., Inc. Williams Goose Creek SC 

South Carolina Pub Serv Auth Cross Cross SC 

South Carolina Pub Serv Auth Dolphus M Grainger Conway SC 

South Carolina Pub Serv Auth Jefferies Moncks Corner SC 

South Carolina Pub Serv Auth Winyah Georgetown SC 

Stone Container Corp Stone Container Florence Mill Florence SC 

Otter Tail Power Co. Big Stone Big Stone City SD 

Eastman Chemical Co.-TN Ops Tennessee Eastman Operations Kingsport TN 

Tennessee Valley Authority Allen Steam Plant Memphis TN 

Tennessee Valley Authority Bull Run Clinton TN 

Tennessee Valley Authority Cumberland Cumberland City TN 

Tennessee Valley Authority Gallatin Gallatin TN 

Tennessee Valley Authority John Sevier Rogersville TN 

Tennessee Valley Authority Johnsonville New Johnsonville TN 

Tennessee Valley Authority Kingston Kingston TN 

AEP Texas North Co. Oklaunion Vernon TX 

AES Corp AES Deepwater Pasadena TX 

Alcoa, Inc. Sandow Station Rockdale TX 

Lower Colorado River Authority Fayette Power Project La Grange TX 

San Antonio Public Service Bd J T Deely Downtown Station TX 

San Antonio Public Service Bd J K Spruce Downtown Station TX 

San Miguel Electric Coop, Inc. San Miguel Christine TX 

Sempra Energy Resources Twin Oaks Power One Bremond TX 

Southwestern Electric Power Co. Welsh Pittsburg TX 

Southwestern Electric Power Co. Pirkey Hallsville TX 

Southwestern Public Service Co. Harrington Amarillo TX 

Southwestern Public Service Co. Tolk Muleshoe TX 

Texas Genco Limestone Jewett TX 

Texas Genco W A Parish Thompsons TX 

Texas Municipal Power Agency Gibbons Creek Anderson TX 

Topaz Power Group LLC Coleto Creek Fannin TX 

TXU Electric Co. Big Brown Fairfield TX 

TXU Electric Co. Martin Lake Tatum TX 

TXU Electric Co. Monticello Mt. Pleasant TX 

TXU Electric Co. Sandow No 4 Rockdale TX 

Deseret Generation & Tran Coop Bonanza Vernal UT 
C-16

Utility Name Plant Name City State 

Kennecott Utah Copper 

Corporation KUCC Magna Post Office UT 

Los Angeles, City of Intermountain Power Project Delta UT 

PacifiCorp Carbon Helper UT 

PacifiCorp Hunter Castledale UT 

PacifiCorp Huntington Huntington UT 

Appalachian Power Co. Clinch River Cleveland VA 

Appalachian Power Co. Glen Lyn Glen Lyn VA 

Birchwood Power Partners LP Birchwood Power King George VA 

Cogentrix of Richmond, Inc. Cogentrix of Richmond Richmond VA 

Cogentrix-Virginia Leas'g Corp Cogentrix Portsmouth Portsmouth VA 

Covanta Fairfax, Inc. Covanta Fairfax Energy Lorton VA 

DPS Mecklenburg LLC Mecklenburg Power Station Clarksville VA 

James River Cogeneration Co. Cogentrix Hopewell Hopewell VA 

Mirant Mid-Atlantic LLC Potomac River George Washington VA 

St Laurent Paper Products Co. West Point Mill West Point VA 

Virginia Electric & Power Co. Bremo Bluff Bremo Bluff VA 

Virginia Electric & Power Co. Chesterfield Chester VA 

Virginia Electric & Power Co. Chesapeake Chesapeake VA 

Virginia Electric & Power Co. Yorktown Yorktown VA 

Virginia Electric & Power Co. Clover Clover VA 

TransAlta Centralia Gen LLC Transalta Centralia Generation Centralia WA 

Dairyland Power Coop Alma Alma WI 

Dairyland Power Coop Genoa Genoa WI 

Dairyland Power Coop John P Madgett Alma WI 

Fort James Operating Co. Green Bay West Mill Green Bay WI 

Madison Gas & Electric Co. Blount Street Madison WI 

Wisconsin Electric Power Co. Port Washington Generating Station Port Washington WI 

Wisconsin Electric Power Co. South Oak Creek Oak Creek WI 

Wisconsin Electric Power Co. Valley Milwaukee WI 

Wisconsin Electric Power Co. Pleasant Prairie Kenosha WI 

Wisconsin Power & Light Co. Edgewater Sheboygan WI 

Wisconsin Power & Light Co. Nelson Dewey Cassville WI 

Wisconsin Power & Light Co. Columbia Pardeeville WI 

Wisconsin Public Service Corp Pulliam Green Bay WI 

Wisconsin Public Service Corp Weston Rothschild WI 

Appalachian Power Co. John E Amos St Albans WV 

Appalachian Power Co. Kanawha River Glasgow WV 

Appalachian Power Co. Mountaineer New Haven WV 

Central Operating Co. Philip Sporn New Haven WV 

Monongahela Power Co. Albright Albright WV 

Monongahela Power Co. Fort Martin Power Station Maidsville WV 

Monongahela Power Co. Harrison Power Station Haywood WV 

Monongahela Power Co. Rivesville Rivesville WV 

Monongahela Power Co. Willow Island Williow Island WV 

Monongahela Power Co. Pleasants Power Station Willow Island WV 

Ohio Power Co. Kammer Moundsville WV 

Ohio Power Co. Mitchell Moundsville WV 
C-17

Utility Name Plant Name City State 

PPG Industries, Inc. PPG Natrium Plant New Martinsville WV 

Virginia Electric & Power Co. Mt Storm Mt Storm WV 

Basin Electric Power Coop Laramie River Station Wheatland WY 

PacifiCorp Dave Johnston Casper WY 

PacifiCorp Naughton Kemmerer WY 

PacifiCorp Wyodak Gillette WY 

PacifiCorp Jim Bridger Rock Springs WY 
C-18

Table C-5: U.S. Silica Fume Producers (Corathers, 2004) 

Company City State 

Elkem Materials, Inc. Alloy WV 

Norchem, Inc. Waterford OH 

Norchem, Inc. Selma AL 

Norchem, Inc. Niagara Falls* NY 

Oxbow Carbon and Minerals LLC Bridgeport AL 

Simcala, Inc. Mount Meigs AL 

CC Metals and Alloys, Inc. Calvert City KY 

*Note - Globe’s plant in Niagara Falls was idle in 2004 
C-19

Table C-6: U.S. Facilities Producing Flue Gas Desulfurization (FGD) Gypsum 

(U.S. DOE, 2004b) 

Utility Name Plant Name City State 

Alabama Electric Coop, Inc. Charles R Lowman Leroy AL 

Tennessee Valley Authority Widows Creek Stevenson AL 

JEA St Johns River Power Park Oceanway FL 

Tampa Electric Company Big Bend Ruskin FL 

Seminole Electric Coop, Inc. Seminole Bostwick FL 

Georgia Power Co. Yates Sargent GA 

Muscatine, City of Muscatine Plant #1 Muscatine IA 

Springfield, City of Dallman Springfield IL 

Indianapolis Power & Light Co. AES Petersburg Petersburg IN 

Northern Indiana Pub. Service 

Co. 

R M Schahfer Wheatfield IN 

Southern Indiana Gas & Electric 

Co. 

F B Culley Newburgh IN 

Kentucky Utilities Co. Ghent Ghent KY 

Louisville Gas & Electric Co. Mill Creek Louisville KY 

Louisville Gas & Electric Co. Trimble County Bedford KY 

Owensboro, City of Elmer Smith Daviess KY 

Tennessee Valley Authority Paradise Drakesboro KY 

Atlantic City Electric Co. B L England Marmora NJ 

AES Cayuga LLC AES Cayuga Lansing NY 

Cincinnati Gas & Electric Co. W H Zimmer Cincinnati OH 

Orion Power Midwest LP Niles Niles OH 

AES Beaver Valley AES Beaver Valley Partners 

Beaver Valley 

Monaca PA 

Midwest Generation Homer City Station Homer City PA 

Pennsylvania Power Co. Bruce Mansfield Shippingport PA 

Reliant Energy NE Mgt Co. Conemaugh New Florence PA 

South Carolina Pub Service 

Authority 

Cross Cross SC 

Tennessee Valley Authority Cumberland Cumberland City TN 

AES Corp. AES Deepwater Pasadena TX 

San Antonio Public Service Bd. J K Spruce Downtown Station TX 

TXU Electric Co. Monticello Mt. Pleasant TX 

TXU Electric Co. Sandow No 4 Rockdale TX 

TransAlta Centralia Gen LLC Transalta Centralia Generation Centralia WA 

Monongahela Power Co. Pleasants Power Station Willow Island WV 
C-20

Table C-7: U.S. Facilities Producing Bottom Ash (U.S. DOE, 2004b) 

Utility Name Plant Name City State 

Alabama Electric Coop, Inc. Charles R Lowman Leroy AL 

Alabama Power Co. Barry Bucks AL 

Alabama Power Co. Gadsden East Gadsden AL 

Alabama Power Co. Gorgas Parrish AL 

Alabama Power Co. Greene County Demopolis AL 

Alabama Power Co. E C Gaston Wilsonville AL 

Alabama Power Co. James H Miller Jr Quinton AL 

Tennessee Valley Authority Colbert Tuscumbia AL 

Tennessee Valley Authority Widows Creek Stevenson AL 

Entergy Arkansas, Inc. White Bluff Redfield AR 

Entergy Arkansas, Inc. Independence Newark AR 

Southwestern Electric Power Co. Flint Creek Gentry AR 

Arizona Electric Pwr Coop, Inc. Apache Station Cochise AZ 

Arizona Public Service Co. Cholla Joseph City AZ 

Salt River Proj Ag I & P Dist Navajo Page AZ 

Salt River Proj Ag I & P Dist Coronado St Johns AZ 

UNS Electric, Inc. H Wilson Sundt Generating Station Cherry Bell Station AZ 

UNS Electric, Inc. Springerville Springerville AZ 

Colorado Springs, City of Martin Drake Colorado Springs CO 

Colorado Springs, City of Ray D Nixon Fountain CO 

Platte River Power Authority Rawhide Wellington CO 

Public Service Co. of Colorado Arapahoe Denver CO 

Public Service Co. of Colorado Cherokee Denver CO 

Public Service Co. of Colorado Comanche Pueblo CO 

Public Service Co. of Colorado Valmont Boulder CO 

Public Service Co. of Colorado Hayden Hayden CO 

Public Service Co. of Colorado Pawnee Brush CO 

Tri-State G & T Assn, Inc. Nucla Nucla CO 

Tri-State G & T Assn, Inc. Craig Craig CO 

AES Thames LLC AES Thames Uncasville CT 

NRG Norwalk Harbor Operations NRG Norwalk Harbor South Norwalk CT 

PSEG Power Connecticut LLC Bridgeport Station Bridgeport CT 

Conectiv Energy Supply, Inc. Edge Moor Edgemoor DE 

Indian River Operations, Inc. Indian River Operations Millsboro DE 

Central Power & Lime, Inc. Central Power & Lime Brooksville FL 

Florida Power & Light Co. Cape Canaveral Cocoa FL 

Florida Power & Light Co. Turkey Point Homestead FL 

Progress Energy Florida, Inc. Crystal River Crystal River FL 

Progress Energy Florida, Inc. P L Bartow St Petersburg FL 

Progress Energy Florida, Inc. Suwannee River Live Oak FL 

Progress Energy Florida, Inc. Anclote Tarpon Springs FL 

Gainesville Regional Utilities Deerhaven Generating Station Alachua FL 

Gulf Power Co. Crist Pensacola FL 

Gulf Power Co. Lansing Smith Southport FL FL 

Indiantown Cogeneration LP Indiantown Cogen Facility Indiantown FL 
C-21

Utility Name Plant Name City State 

JEA St Johns River Power Park Oceanway FL 

JEA Northside Generating Station Oceanway FL 

Orlando Utilities Comm Stanton Energy Center Alafaya Branch FL 

PG&E Operating Service Co. Cedar Bay Generating LP Jacksonville FL 

Tampa Electric Co. Big Bend Ruskin FL 

Seminole Electric Coop, Inc. Seminole Bostwick FL 

Georgia Power Co. Bowen Taylorsville GA 

Georgia Power Co. Hammond Coosa GA 

Georgia Power Co. Harllee Branch Milledgeville GA 

Georgia Power Co. Jack McDonough Smyrna GA 

Georgia Power Co. Mitchell Putney GA 

Georgia Power Co. Yates Sargent GA 

Georgia Power Co. Wansley Roopville GA 

Georgia Power Co. Scherer Juliette GA 

Savannah Electric & Power Co. Kraft Port Wentworth GA 

Savannah Electric & Power Co. McIntosh Rincon GA 

AES Corp AES Hawaii Kapolei HI 

Archer Daniels Midland Co. 

Archer Daniels Midland Cedar 

Rapids Cedar Rapids IA 

Interstate Power and Light Ottumwa Ottumwa IA 

Interstate Power & Light Co. Milton L Kapp Clinton IA 

Interstate Power & Light Co. Prairie Creek Cedar Rapids IA 

Interstate Power & Light Co. Sutherland Marshalltown IA 

Interstate Power & Light Co. Burlington Burlington IA 

MidAmerican Energy Co. Riverside Bettendorf IA 

MidAmerican Energy Co. Council Bluffs Council Bluffs IA 

MidAmerican Energy Co. George Neal North Salix IA 

MidAmerican Energy Co. Louisa Muscatine IA 

MidAmerican Energy Co. George Neal South Salix IA 

Muscatine, City of Muscatine Plant #1 Muscatine IA 

Ameren Energy Generating Co. Coffeen Coffeen IL 

Ameren Energy Generating Co. Hutsonville Hutsonville IL 

Ameren Energy Generating Co. Meredosia Meredosia IL 

Ameren Energy Generating Co. Newton Newton IL 

Archer Daniels Midland Co. Archer Daniels Midland Decatur Decatur IL 

Dominion Energy Services Co. Kincaid Generation LLC Kincaid IL 

Dynegy Midwest Generation, Inc. Baldwin Energy Complex Baldwin IL 

Dynegy Midwest Generation, Inc. Havana Havana IL 

Dynegy Midwest Generation, Inc. Hennepin Power Station Hennepin IL 

Dynegy Midwest Generation, Inc. Vermilion Oakwood IL 

Dynegy Midwest Generation, Inc. Wood River East Alton IL 

Electric Energy, Inc. Joppa Steam Joppa IL 

Midwest Generations EME LLC Joliet 29 Joliet IL 

Midwest Generations EME LLC Crawford Chicago IL 

Midwest Generations EME LLC Joliet 9 Joliet IL 

Midwest Generations EME LLC Powerton Pekin IL 

Midwest Generations EME LLC Waukegan Waukegan IL 

Midwest Generations EME LLC Will County Romeoville IL 
C-22

Utility Name Plant Name City State 

Midwest Generations EME LLC Fisk Street Chicago IL 

Southern Illinois Power Coop Marion Marion IL 

Springfield, City of Dallman Springfield IL 

Ameren Energy Resources Generating E D Edwards Bartonville IL 

Ameren Energy Resources Generating Duck Creek Canton IL 

Alcoa Power Generating, Inc. Warrick Newburgh IN 

Hoosier Energy R E C, Inc. Frank E Ratts Petersburg IN 

Hoosier Energy R E C, Inc. Merom Sullivan IN 

Indiana-Kentucky Electric Corp Clifty Creek Madison IN 

Indianapolis Power & Light Co. Harding Street Indianapolis IN 

Indianapolis Power & Light Co. Eagle Valley Martinsville IN 

Indianapolis Power & Light Co. AES Petersburg Petersburg IN 

Indiana Michigan Power Co. Tanners Creek Lawrenceburg IN 

Indiana Michigan Power Co. Rockport Rockport IN 

Northern Indiana Pub Serv Co. Bailly Chesterton IN 

Northern Indiana Pub Serv Co. Michigan City Michigan City IN 

Northern Indiana Pub Serv Co. R M Schahfer Wheatfield IN 

PSI Energy, Inc. Cayuga Cayuga IN 

PSI Energy, Inc. Edwardsport Edwardsport IN 

PSI Energy, Inc. R Gallagher New Albany IN 

PSI Energy, Inc. Wabash River Terre Haute IN 

PSI Energy, Inc. Gibson Mt Carmel IN 

Southern Indiana Gas & Elec Co. F B Culley Newburgh IN 

Southern Indiana Gas & Elec Co. A B Brown Mount Vernon IN 

State Line Energy LLC State Line Energy Hammond IN 

Kansas City, City of Quindaro Fairfax Station KS 

Kansas City, City of Nearman Creek Robert L Roberts STA KS 

Kansas City Power & Light Co. La Cygne La Cygne KS 

Sunflower Electric Power Corp Holcomb Holcomb KS 

Westar Energy Lawrence Energy Center Lawrence, Kansas KS 

Westar Energy Tecumseh Energy Center Tecumseh KS 

Westar Energy Jeffrey Energy Center Belvue KS 

Cincinnati Gas & Electric Co. East Bend Rabbit Hash KY 

East Kentucky Power Coop, Inc. Cooper Burnside KY 

East Kentucky Power Coop, Inc. Dale Winchester KY 

East Kentucky Power Coop, Inc. H L Spurlock Maysville KY 

Kentucky Utilities Co. E W Brown Burgin KY 

Kentucky Utilities Co. Ghent Ghent KY 

Kentucky Utilities Co. Green River Central City KY 

Kentucky Utilities Co. Tyrone Versailles KY 

Louisville Gas & Electric Co. Cane Run Louisville KY 

Louisville Gas & Electric Co. Mill Creek Louisville KY 

Louisville Gas & Electric Co. Trimble County Bedford KY 

Owensboro, City of Elmer Smith Daviess KY 

Tennessee Valley Authority Shawnee West Paducah KY 

Western Kentucky Energy Corp Kenneth C Coleman Hawesville KY 

Western Kentucky Energy Corp HMP&L Station Two Henderson Sebree KY 
C-23

Utility Name Plant Name City State 

Western Kentucky Energy Corp R D Green Sebree KY 

Western Kentucky Energy Corp D B Wilson Centertown KY 

Kentucky Power Co. Big Sandy Louisa KY 

Cleco Power LLC Dolet Hills Mansfield LA 

Cleco Power LLC Rodemacher Lena LA 

Entergy Gulf States, Inc. R S Nelson Lake Charles LA 

International Paper Co. Mansfield Mill Mansfield LA 

Louisiana Generating LLC Big Cajun 2 New Roads LA 

Dominion Energy New England Brayton Point Somerset MA 

U S Gen New England, Inc. Salem Harbor Salem MA 

Northeast Generation Services Co. Mount Tom Holyoke MA 

Somerset Power LLC Somerset Station Somerset MA 

AES WR Ltd Partnership 

AES Warrior Run Cogeneration 

Facility Cumberland MD 

Constellation Power Source Gen Brandon Shores Baltimore MD 

Constellation Power Source Gen C P Crane Baltimore MD 

Constellation Power Source Gen Herbert A Wagner Baltimore MD 

Mirant Mid-Atlantic LLC Chalk Point LLC Aquasco MD 

Mirant Mid-Atlantic LLC Dickerson Dickerson MD 

Mirant Mid-Atlantic LLC Morgantown Generating Plant Newburg MD MD 

Allegheny Energy Supply Co. LLC R Paul Smith Power Station Williamsport MD 

MeadWestvaco Corp Rumford Cogeneration Rumford ME 

S D Warren Co. Somerset Plant Skowhegan ME 

FPL Energy Wyman LLC William F Wyman Yarmouth ME 

Consumers Energy Co. B C Cobb Muskegon MI 

Consumers Energy Co. Dan E Karn Essexville MI 

Consumers Energy Co. J H Campbell West Olive MI 

Consumers Energy Co. J C Weadock Essexville MI 

Consumers Energy Co. J R Whiting Erie MI 

Detroit Edison Co. Harbor Beach Harbor Beach MI 

Detroit Edison Co. Monroe Monroe MI 

Detroit Edison Co. River Rouge River Rouge MI 

Detroit Edison Co. St Clair East China MI 

Detroit Edison Co. Trenton Channel Trenton MI 

Detroit Edison Co. Belle River Belle River MI 

Lansing, City of Eckert Station Lansing MI 

Lansing, City of Erickson Station Lansing MI 

MeadWestvaco Corp Escanaba Paper Company Escanaba MI 

Wisconsin Electric Power Co. Presque Isle Marquette MI 

Allete, Inc. Syl Laskin Aurora MN 

Allete, Inc. Clay Boswell Cohasset MN 

Allete, Inc. Taconite Harbor Energy Center Schroeder MN 

Cleveland Cliffs, Inc. Silver Bay Power Silver Bay MN 

Northern States Power Co. Black Dog Burnsville MN 

Northern States Power Co. High Bridge St. Paul MN 

Northern States Power Co. Allen S King Bayport MN 

Northern States Power Co. Riverside Minneapolis MN 

Northern States Power Co. Sherburne County Becker MN 
C-24

Utility Name Plant Name City State 

Otter Tail Power Co. Hoot Lake Fergus Falls MN 

Aquila, Inc. Sibley Sibley MO 

Aquila, Inc. Lake Road St Joseph MO 

Associated Electric Coop, Inc. New Madrid Marston MO 

Associated Electric Coop, Inc. Thomas Hill Moberly MO 

Empire District Electric Co. Asbury Asbury MO 

Independence, City of Blue Valley Independence MO 

Kansas City Power & Light Co. Hawthorn Kansas City MO 

Kansas City Power & Light Co. Montrose Clinton MO 

Kansas City Power & Light Co. Iatan Weston MO 

Sikeston, City of Sikeston Power Station Sikeston MO 

Springfield, City of James River Power Station Springfield MO 

Springfield, City of Southwest Power Station Springfield MO 

Ameren UE Labadie Labadie MO 

Ameren UE Meramec St Louis MO 

Ameren UE Sioux West Alton MO 

Ameren UE Rush Island Festus MO 

Mississippi Power Co. Jack Watson Gulfport MS 

Mississippi Power Co. Victor J Daniel Jr Escatawpa MS 

South Mississippi El Pwr Assn R D Morrow Purvis MS 

Tractebel Power, Inc. Red Hills Generating Facility Ackerman MS 

Weyerhaeuser Co. Weyerhaeuser Columbus MS Columbus MS 

PPL Montana LLC J E Corette Plant Billings MT 

PPL Montana LLC Colstrip Colstrip MT 

Carolina Power & Light Co. Asheville Arden NC 

Carolina Power & Light Co. Cape Fear Moncure NC 

Carolina Power & Light Co. Lee Goldsboro NC 

Carolina Power & Light Co. Roxboro Semora NC 

Carolina Power & Light Co. L V Sutton Wilmington NC 

Carolina Power & Light Co. W H Weatherspoon Lumberton NC 

Carolina Power & Light Co. Mayo Roxboro NC 

Cogentrix of Rocky Mount, Inc. 

Cogentrix Dwayne Collier Battle 

Cogen Battleboro NC 

Duke Energy Corp G G Allen Belmont NC 

Duke Energy Corp Buck Spencer NC 

Duke Energy Corp Cliffside Cliffside NC 

Duke Energy Corp Dan River Eden NC 

Duke Energy Corp Marshall Terrell NC 

Duke Energy Corp Riverbend Mount Holly NC 

Duke Energy Corp Belews Creek Walnut Cove NC 

Weyerhaeuser Co. Weyerhaeuser Plymouth NC Plymouth NC 

Basin Electric Power Coop Leland Olds Stanton ND 

Basin Electric Power Coop Antelope Valley Beulah ND 

Great River Energy Stanton Stanton ND 

Great River Energy Coal Creek Underwood ND 

MDU Resources Group, Inc. R M Heskett Mandan ND 

Minnkota Power Coop, Inc. Milton R Young Center ND 

Otter Tail Power Co. Coyote Beulah ND 
C-25

Utility Name Plant Name City State 

Fremont, City of Lon Wright Fremont NE 

Nebraska Public Power District Sheldon Hallam NE 

Nebraska Public Power District Gerald Gentleman Sutherland NE 

Omaha Public Power District North Omaha Florence NE 

Omaha Public Power District Nebraska City Nebraska City NE 

Grand Island, City of Platte Grand Island NE 

Public Service Co. of NH Merrimack Concord NH 

Public Service Co. of NH Schiller Portsmouth NH 

Public Service Co. of NH Newington Portsmouth NH 

Atlantic City Electric Co. B L England Marmora NJ 

Atlantic City Electric Co. Deepwater Penns Grove NJ 

Chambers Cogeneration LP Chambers Cogeneration LP Carneys Point NJ 

Logan Generating Co. LP Logan Generating Plant Swedesboro NJ 

PSEG Fossil LLC PSEG Hudson Generating Station Jersey City NJ 

PSEG Fossil LLC PSEG Mercer Generating Station Trenton NJ 

Arizona Public Service Co. Four Corners Fruitland NM 

Public Service Co. of NM San Juan Waterflow NM 

Tri-State G & T Assn, Inc. Escalante Prewitt NM 

Nevada Power Co. Reid Gardner Moapa NV 

Sierra Pacific Power Co. Fort Churchill Yerington NV 

Sierra Pacific Power Co. North Valmy Valmy NV 

Southern California Edison Co. Mohave Laughlin NV 

AES Greenidge LLC AES Greenidge LLC Dresden NY 

Dynegy Northeast Gen, Inc. Danskammer Generating Station Newburgh NY 

Dynegy Northeast Gen, Inc. Roseton Generating Station Newburgh NY 

Eastman Kodak Co. Kodak Park Site Rochester NY 

Mirant New York, Inc. Lovett Tomkins Cove NY 

NRG Huntley Operations, Inc. C R Huntley Generating Station Tonawanda NY 

Dunkirk Power LLC Dunkirk Generating Station Central Avenue NY 

Rochester Gas & Electric Corp Rochester 7 Rochester NY 

AES Cayuga LLC AES Cayuga Lansing NY 

AES Somerset LLC AES Somerset LLC Barker NY 

AES Westover LLC AES Westover Johnson City NY 

Cardinal Operating Co. Cardinal Brilliant OH 

Cincinnati Gas & Electric Co. Walter C Beckjord New Richmond OH 

Cincinnati Gas & Electric Co. Miami Fort North Bend OH 

Cincinnati Gas & Electric Co. W H Zimmer Cincinnati OH 

Cleveland Electric Illum Co. Ashtabula Ashtabula OH 

Cleveland Electric Illum Co. Eastlake Eastlake OH 

Cleveland Electric Illum Co. Lake Shore Cleveland OH 

Columbus Southern Power Co. Conesville Conesville OH 

Columbus Southern Power Co. Picway Lockbourne OH 

Dayton Power & Light Co. O H Hutchings Miamisburg OH 

Dayton Power & Light Co. J M Stuart Aberdeen OH 

Dayton Power & Light Co. Killen Station Manchester OH 

Hamilton, City of Hamilton Hamilton OH 

Ohio Edison Co. R E Burger Shadyside OH 
C-26

Utility Name Plant Name City State 

Ohio Edison Co. W H Sammis Stratton OH 

Ohio Power Co. Muskingum River Beverly OH 

Ohio Power Co. General James M Gavin Cheshire OH 

Ohio Valley Electric Corp Kyger Creek Cheshire OH 

Orion Power Midwest LP Avon Lake Avon Lake OH 

Orion Power Midwest LP Niles Niles OH 

Toledo Edison Co. Bay Shore Oregon OH 

American Mun Power-Ohio, Inc. Richard Gorsuch Marietta OH 

AES Shady Point, LLC AES Shady Point Panama OK 

Fort James Operating Co. Muskogee Mill Muskogee OK 

Grand River Dam Authority GRDA Chouteau OK 

Oklahoma Gas & Electric Co. Muskogee Ft Gibson OK 

Public Service Co. of Oklahoma Northeastern Oologah OK 

Western Farmers Elec Coop, Inc. Hugo Fort Towson OK 

Portland General Electric Co. Boardman Boardman OR 

AES Beaver Valley 

AES Beaver Valley Partners Beaver 

Valley Monaca PA 

Exelon Generation Co. LLC Cromby Generating Station Phoenixville PA 

Exelon Generation Co. LLC Eddystone Generating Station Chester PA 

Midwest Generation Homer City Station Homer City PA 

Orion Power Midwest LP Elrama Power Plant Elrama PA 

Orion Power Midwest LP Cheswick Power Plant Cheswick PA 

Orion Power Midwest LP New Castle Plant West Pittsburg PA 

Pennsylvania Power Co. Bruce Mansfield Shippingport PA 

PPL Corp PPL Brunner Island York Haven PA 

PPL Corp PPL Martins Creek Martins Creek PA 

PPL Corp PPL Montour Washingtonville PA 

Reliant Energy NE Mgt Co. Conemaugh New Florence PA 

Reliant Energy NE Mgt Co. Keystone Shelocta PA 

Reliant Energy Mid-Atlantic PH Portland Portland PA 

Reliant Energy Mid-Atlantic PH Titus Birdboro PA 

Reliant Energy Mid-Atlantic PH Shawville Clearfield PA 

TIFD VIII-W, Inc. Colver Power Project Colver PA 

Sunbury Generation LLC WPS Energy Servs Sunbury Gen Shamokin Dam PA 

PG&E National Energy Group Northhampton Generating LP Northampton PA 

Allegheny Energy Supply Co. LLC Armstrong Power Station Kittaning PA 

Allegheny Energy Supply Co. LLC Hatfields Ferry Power Station Masontown PA 

Allegheny Energy Supply Co. LLC Mitchell Power Station Courtney PA 

Carolina Power & Light Co. H B Robinson Hartsville SC 

Duke Energy Corp W S Lee Pelzer SC 

International Paper Co.-Eastovr International Paper Eastover Facility Eastover SC 

South Carolina Electric & Gas Co. Canadys Steam Canadys SC 

South Carolina Electric & Gas Co. McMeekin Irmo SC 

South Carolina Electric & Gas Co. Urquhart Urquhart SC 

South Carolina Electric & Gas Co. Wateree Eastover SC 

South Carolina Electric & Gas Co. Cope Cope SC 

South Carolina Pub Serv Auth Cross Cross SC 

South Carolina Pub Serv Auth Dolphus M Grainger Conway SC 
C-27

Utility Name Plant Name City State 

South Carolina Pub Serv Auth Jefferies Moncks Corner SC 

South Carolina Pub Serv Auth Winyah Georgetown SC 

South Carolina Genertg Co., Inc. Williams Goose Creek SC 

Stone Container Corp Stone Container Florence Mill Florence SC 

Otter Tail Power Co. Big Stone Big Stone City SD 

Eastman Chemical Co.-TN Ops Tennessee Eastman Operations Kingsport TN 

Tennessee Valley Authority Bull Run Clinton TN 

Tennessee Valley Authority Cumberland Cumberland City TN 

Tennessee Valley Authority Gallatin Gallatin TN 

Tennessee Valley Authority John Sevier Rogersville TN 

Tennessee Valley Authority Johnsonville New Johnsonville TN 

Tennessee Valley Authority Kingston Kingston TN 

Alcoa, Inc. Sandow Station Rockdale TX 

Topaz Power Group LLC Coleto Creek Fannin TX 

Lower Colorado River Authority Fayette Power Project La Grange TX 

San Antonio Public Service Bd J T Deely Downtown Station TX 

San Antonio Public Service Bd J K Spruce Downtown Station TX 

San Miguel Electric Coop, Inc. San Miguel Christine TX 

Sempra Energy Resources Twin Oaks Power One Bremond TX 

Southwestern Electric Power Co. Welsh Pittsburg TX 

Southwestern Electric Power Co. Pirkey Hallsville TX 

Southwestern Public Service Co. Harrington Amarillo TX 

Southwestern Public Service Co. Tolk Muleshoe TX 

Texas Municipal Power Agency Gibbons Creek Anderson TX 

Texas Genco Limestone Jewett TX 

Texas Genco W A Parish Thompsons TX 

AEP Texas North Co. Oklaunion Vernon TX 

TXU Electric Co. Big Brown Fairfield TX 

TXU Electric Co. Martin Lake Tatum TX 

TXU Electric Co. Monticello Mt. Pleasant TX 

TXU Electric Co. Sandow No 4 Rockdale TX 

Los Angeles, City of Intermountain Power Project Delta UT 

PacifiCorp Carbon Helper UT 

PacifiCorp Hunter Castledale UT 

PacifiCorp Huntington Huntington UT 

Deseret Generation & Tran Coop Bonanza Vernal UT 

Kennecott Utah Copper Corporation KUCC Magna Post Office UT 

Appalachian Power Co. Clinch River Cleveland VA 

Appalachian Power Co. Glen Lyn Glen Lyn VA 

Birchwood Power Partners LP Birchwood Power King George VA 

St Laurent Paper Products Co. West Point Mill West Point VA 

Cogentrix of Richmond, Inc. Cogentrix of Richmond Richmond VA 

Covanta Fairfax, Inc. Covanta Fairfax Energy Lorton VA 

Mirant Mid-Atlantic LLC Potomac River George Washington VA 

Virginia Electric & Power Co. Bremo Bluff Bremo Bluff VA 

Virginia Electric & Power Co. Chesterfield Chester VA 

Virginia Electric & Power Co. Chesapeake Chesapeake VA 
C-28

Utility Name Plant Name City State 

Virginia Electric & Power Co. Yorktown Yorktown VA 

Virginia Electric & Power Co. Clover Clover VA 

DPS Mecklenburg LLC Mecklenburg Power Station Clarksville VA 

TransAlta Centralia Gen LLC Transalta Centralia Generation Centralia WA 

Dairyland Power Coop Alma Alma WI 

Dairyland Power Coop Genoa Genoa WI 

Dairyland Power Coop John P Madgett Alma WI 

Fort James Operating Co. Green Bay West Mill Green Bay WI 

Madison Gas & Electric Co. Blount Street Madison WI 

Wisconsin Electric Power Co. Port Washington Generating Station Port Washington WI 

Wisconsin Electric Power Co. South Oak Creek Oak Creek WI 

Wisconsin Electric Power Co. Valley Milwaukee WI 

Wisconsin Electric Power Co. Pleasant Prairie Kenosha WI 

Wisconsin Power & Light Co. Edgewater Sheboygan WI 

Wisconsin Power & Light Co. Columbia Pardeeville WI 

Wisconsin Public Service Corp Pulliam Green Bay WI 

Wisconsin Public Service Corp Weston Rothschild WI 

Appalachian Power Co. John E Amos St Albans WV 

Appalachian Power Co. Kanawha River Glasgow WV 

Appalachian Power Co. Mountaineer New Haven WV 

Central Operating Co. Philip Sporn New Haven WV 

Monongahela Power Co. Albright Albright WV 

Monongahela Power Co. Fort Martin Power Station Maidsville WV 

Monongahela Power Co. Harrison Power Station Haywood WV 

Monongahela Power Co. Rivesville Rivesville WV 

Monongahela Power Co. Willow Island Williow Island WV 

Monongahela Power Co. Pleasants Power Station Willow Island WV 

Ohio Power Co. Kammer Moundsville WV 

Ohio Power Co. Mitchell Moundsville WV 

PPG Industries, Inc. PPG Natrium Plant New Martinsville WV 

Virginia Electric & Power Co. Mt Storm Mt Storm WV 

Basin Electric Power Coop Laramie River Station Wheatland WY 

PacifiCorp Dave Johnston Casper WY 

PacifiCorp Naughton Kemmerer WY 

PacifiCorp Wyodak Gillette WY 

PacifiCorp Jim Bridger Rock Springs WY 
APPENDIX D: 

RMC BENEFICIAL USE MODEL – TECHNICAL APPROACH
D-1 

Recovered Mineral Components (RMC) Beneficial Use Model 

Technical Approach 

 

As described in the main body of this report, beneficial use of RMCs in concrete can have 

environmental benefits associated with avoided portland cement production.3 In addition to the 

general evaluation of these benefits, the report provides quantified estimates of a suite of 

environmental impacts for three of the RMCs identified by Congress: coal combustion fly ash; 

ground granulated blast furnace slag (GGBFS); and silica fume. In this appendix, we describe 

the model used to quantify these environmental benefits and provide the full model results. 

The model estimates avoided resource use and avoided emissions when a specified quantity of 

coal fly ash, GGBFS, or silica fume is used in place of finished portland cement in federallyfunded concrete projects.4

 To capture the full magnitude of benefits, the model follows a 

modified life-cycle approach in which the benefits of using RMC in concrete are evaluated 

across all stages of the product’s life, from resource extraction through disposal.5

 

We illustrate the three primary steps in modeling the environmental benefits of using RMCs in 

Federal concrete applications in Figure D-1. As shown in this figure, the analytic process 

includes: 

(1) Development of RMC substitution scenarios, representing the estimated annual 

quantity of each RMC (in metric tons) used in federally-funded concrete projects, 

including current and expanded substitution scenarios; 

(2) Estimation of environmental impact values for the substitution of one unit (metric 

ton) of RMC as a partial substitute for finished portland cement in concrete; and 

(3) Calculation of national-scale impacts under current use and expanded use scenarios 

by multiplying per-unit impacts by national-level RMC reuse quantities 

We describe each of these steps in greater detail below. 

 

3

 The Agency recognizes that these environmental benefits may represent the reduced need for new or expanded 

portland cement producing capacity in future years. With the use of RMCs, the same amount of portland 

cement/clinker will likely be produced, but will result in more concrete production than with 100% virgin material. 

4

 As described in Section 2 of this report, RMCs can be used to offset virgin materials at more than one point in the 

cement production process. It is important to note that we are modeling the use of RMCs as a direct replacement for 

finished portland cement in concrete. This analysis does not evaluate use of RMCs in clinker production. 

5

 We focus on coal fly ash, GGBFS, and silica fume because more comprehensive and robust life cycle data were 

available to analyze them. Relevant life cycle data for the substitution of other RMCs were not available for 

purposes of this report. 
D-2 

Environmental Impact Profile

•For each RMC and substitution scenario by year, multiply substitution level (in metric tons of RMC) by suite of environmental metrics.•Yields profile of environmental benefits (resource use, emissions, waste) for RMC beneficial use.

RMC Substitution Scenarios

•Scenario projection: 2004-2015•RMC substitution levels for federal projects (in metric tons per year for each RMC):-Fly Ash: “current use” and “expanded use” substitution scenarios-GGBFS and Silica Fume: “current use” substitution scenario only

Figure D-1

Conceptual Schematic of RMC Beneficial Use Model

Decrease in non-hazardous waste disposal (kilograms)

Waste

Decrease in air emissions (CO2,CO, Pb, Hg, NOx, PM10, 

and Sox), soil emissions, and water emissions (BOD, COD, suspended matter, and copper) (grams)

Emissions

Decrease in energy and water consumption (joules, liters)

Resource Use

Environmental Metrics

Benefit per metric ton of RMC 

Substituted for Portland Cement

Environmental Impact Values
D-3 

Step 1 - Estimation of RMC Usage in Federal Concrete Projects

In order to estimate the quantity of coal fly ash, GGBFS, and silica fume used in Federal 

concrete projects, we first estimate the quantity of each RMC used in the U.S. and multiply these 

estimates by the percentage assumed to be used in federally-funded projects. The Federal 

Highway Administration (FHWA) estimates that approximately 20% of all cement usage in the 

U.S. is incorporated in to federally-funded projects. Therefore, for this analysis, we assumed 

that 20% of the national RMC usage is incorporated into Federal projects. Table below 1 shows 

the derivation of the 20% FHWA estimate. 

Table D-1: Derivation of FHWA Estimate for Concrete use in Federal Projects 

PCA Cement Use in Federal 

Construction Estimatea Expert Estimate Cement Use 

in Federal Construction Type 

thousand metric tons percent thousand metric tons1

Classroom buildings & Labs 2,270.5 1%b 22.7 

Public Administrative/Services 498.8 10%b 49.9 

Low rise hospitals 947 10%b 94.7 

High-rise Hospitals 432.9 10%b 43.3 

Passenger Terminals 84.7 20%b 16.9 

State Highways (Urban and Rural) 15,415.4 74%c 11,418.4 

Urban Streets & Roadways 6,240.1 74%c 4,622.0 

Rural Roadways 424.7 4%d 17.0 

Vehicle / Pedestrian Bridges 7,289.6 43%e 3,137.3 

Maintenance & repair 4,055.7 1%d 40.6 

Dams & Reservoirs 661.7 90%b 595.5 

River & Harbor Development & Control 716.7 90%b 645.0 

Water Supply Systems 3,597.1 50%b 1,798.6 

Sanitary/Storm Sewers 2,265.6 30%b 679.7 

Water & Sewer Tunnels 40.0 80%b 32.0 

Airport Runways/Taxi ways/Lighting 1,269.2 99%b 1,256.5 

Defense/Space facilities 122.1 100%b 122.1 

Total Tons 46,331.8 24,592.2 

National Total 114,889 114,889 

Percent Used in Federal Construction 40% 20% 

Notes: 

1. Values may not add due to rounding. 

Sources: 

a. Portland Cement Association, "2004 Apparent Use of Portland Cement by Market," 2004. Skokie, IL.

b. Personal communication and follow-up email with Jon Mullarky, Federal Highway Administration, July 17, 

2007 and July 18, 2007. 

c. Federal Highway Administration, “Funding for Highways and Disposition of Highway-User Revenues, All 

Units of Government, 2004,” Modified March 21, 2006. 

http://www.fhwa.dot.gov/policy/ohim/hs04/htm/hf10.htm Accessed on August 14, 2007. 

d. Federal Highway Administration, “Pubic Road Length-2004,” Modified March 14, 2006. 

http://www.fhwa.dot.gov/policy/ohim/hs04/htm/hm10.htm Accessed on August 14, 2007. 

e. Federal Highway Administration, “National Bridge Inventory.” Modified July 10, 2007. 

http://www.fhwa.dot.gov/bridge/nbi.htm Accessed on August 14, 2007. 
D-4 

Section 3 of this report describes the assumptions used to develop historical and projected 

estimates of the quantity of each RMC used as a substitute for finished portland cement under 

both current and expanded use scenarios. These assumptions are described in greater detail 

below. 

Current Use Estimates 

Cement:

One of the primary assumptions used in the development of current use estimates for coal fly ash 

and GGBFS is that use of these RMCs will grow at the same rate as use of cement. For portland 

cement, USGS provides data for the years 2004 and 2005 on estimated U.S. cement production, 

imports and exports. Using these data, U.S. cement consumption for the years 2004 and 2005 

was estimated as total imports plus total U.S. production minus U.S. exports. Using this 

approach, it was estimated that U.S. apparent cement consumption was 121,980 thousand metric 

tons in 2004, and 125,700 thousand metric tons in 2005. 

The Portland Cement Association estimates that U.S. cement demand will be 195 million metric 

tons in 2030 (PCA, 2006a). Using the PCA estimate in 2030, demand for the years 2006 through 

2015 was estimated by assuming a linear increase from 125,700 thousand metric tons in 2005 to 

195,000 thousand metric tons in 2030. By applying the 20% Federal use estimate to the 

projections for total U.S. cement use, we derive the Federal substitution projections for cement. 

Cement consumption estimates for the years 2004 through 2015 are presented in Table D-2. 
D-5 

Table D-2: Projected Cement Usage 

Estimated U.S. Cement 

Consumption 

Cement Consumption 

in Federal Projects 

Cement Consumption 

in Non-Federal 

Year Projects 

-------------------------------------thousand metric tons--------------------------------

2004 121,980 24,396 97,584 

2005 125,700 25,140 100,560 

2006 128,472 25,694 102,778 

2007 131,244 26,249 104,995 

2008 134,016 26,803 107,213 

2009 136,788 27,358 109,430 

2010 139,560 27,912 111,648 

2011 142,332 28,466 113,866 

2012 145,104 29,020 116,083 

2013 147,876 29,575 118,301 

2014 150,648 30,130 120,518 

2015 153,420 30,684 122,736 

Coal Fly Ash:

The current use estimates for coal fly ash as an SCM are broken out into a “baseline” and “C2

P2” 

scenario in order to account for the impact of EPA’s C2

P2 program on coal fly ash use. The 

baseline scenario estimates coal fly ash use in the absence of the C2P2 program. The C2P2

scenario estimates coal fly ash use assuming the C2

P2 program achieves the targeted use of coal 

fly ash under the program. 

For both scenarios, 2004 and 2005 estimates of coal fly ash usage in cement are taken from the 

American Coal Ash Association’s (ACAA) annual survey of electric utilities (see Section 2). 

ACAA estimates that 12,811 thousand metric tons of coal fly ash were used as a finished 

portland cement substitute in 2004, and that 13,599 thousand metric tons were used in 2005. 

Under the current use baseline scenario, it is assumed that in the absence of the C2

P2 program, 

coal fly ash usage as a finished portland cement substitute would increase linearly after 2005 at 

the same rate as U.S. cement demand over 2004 levels, which is approximately 2.2%, or 

approximately 300,000 metric tons per year. Projected coal fly ash usage under the current use 

baseline scenario is shown in the top-half of Table D-3. 

Under the current use C2

P2 scenario, it is assumed that coal fly ash as a finished portland cement 

substitute will increase to 18.6 million short tons (approximately 16.9 million metric tons) by 

2011. This is the goal of the C2

P2 program.6 A second order polynomial fit was used to estimate 

usage for the years 2006 through 2010. The equation used is y = -8,765.346x2 + 

35,420,372.024x - 35,775,515,275.736 where y = fly ash use as an SCM, and x = years projected 

past 2005. For the years 2011 through 2015, coal fly ash usage under the C2P2 scenario was 

estimated to increase at the same rate as U.S. cement demand over 2004 levels. As with cement, 

 

6

 For an overview of the C2P2 program, see section 5 of this report. Additional program information can be found 

at: http://www.epa.gov/epaoswer/osw/conserve/c2p2/pubs/facts508.pdf. 
D-6 

it was assumed that 20% of coal fly ash is used in Federal projects and 80% is used in nonFederal projects. Table D-3 shows current use estimates for coal fly ash under the current use 

baseline and current use C2P2 scenarios. It is assumed that the difference between coal fly ash 

usage in these scenarios, also shown in Table D-3, represents the increment of coal fly ash usage 

attributable to the C2P2 program. 

Table D-3: Coal Fly Ash Usage Under Current Use Scenarios

Estimated U.S. Coal 

Fly Ash Consumption 

Coal fly ash Consumption 

in Federal Projects 

Coal fly ash Consumption 

Year in Non-Federal Projects 

---------------------------------thousand metric tons--------------------------------

Baseline 

2004 12,811 2,562 10,249 

2005 13,599 2,720 10,879 

2006 13,900 2,780 11,120 

2007 14,200 2,840 11,360 

2008 14,498 2,900 11,598 

2009 14,798 2,960 11,838 

2010 15,098 3,020 12,078 

2011 15,398 3,080 12,318 

2012 15,698 3,140 12,558 

2013 15,998 3,200 12,798 

2014 16,298 3,260 13,038 

2015 16,598 3,320 13,278 

C2P2

2004 12,811 2,562 10,249 

2005 13,599 2,720 10,879 

2006 14,208 2,842 11,366 

2007 14,820 2,964 11,856 

2008 15,390 3,078 12,312 

2009 15,915 3,183 12,732 

2010 16,395 3,279 13,116 

2011 16,875 3,375 13,500 

2012 17,203 3,441 13,762 

2013 17,530 3,506 14,024 

2014 17,860 3,572 14,288 

2015 18,188 3,638 14,550 

Quantity Attributable to C2P2 (C2P2 – Baseline) 

2004 0 0 0 

2005 0 0 0 

2006 308 62 246 

2007 620 124 496 

2008 892 178 714 

2009 1,117 223 894 

2010 1,297 259 1,038 

2011 1,477 295 1,182 

2012 1,505 301 1,204 

2013 1,532 306 1,226 

2014 1,562 312 1,250 

2015 1,590 318 1,272 
D-7 

GGBFS:

Under current use, it was assumed that demand for GGBFS would increase linearly from 2004 

use rates at the same rate as U.S. cement demand (which is approximately 2.2% per year). For 

GGBFS, this equals an annual increase of 76,000 metric tons. It was also assumed that 20% of 

GGBFS is used in Federal concrete projects with the remainder being used in non-Federal 

projects. Values for GGBFS usage under the current use scenario are shown in Table D-4. 

Table D-4: GGBFS Usage Under Current Use Scenario 

Estimated U.S. 

GGBFS 

Consumption 

GGBFS 

Consumption in 

Federal Projects 

GGBFS 

Consumption in 

Non-Federal 

Projects 

Year 

------------------------------thousand metric tons-------------------------

2004 3,460 692 2,768 

2005 3,536 707 2,829 

2006 3,612 722 2,890 

2007 3,688 738 2,950 

2008 3,764 753 3,011 

2009 3,840 768 3,072 

2010 3,916 783 3,133 

2011 3,992 798 3,194 

2012 4,068 814 3,254 

2013 4,144 829 3,315 

2014 4,220 844 3,376 

2015 4,296 859 3,437 

Silica Fume:

For current use, we assume that domestic silica fume supply is inelastic, as a result of relatively 

inelastic global supply of silicon metal and ferrosilicon and related ferroalloys production. 

Therefore, we assume that current (i.e., base year) rates of silica fume use in U.S. concrete 

projects will remain constant into the future (i.e., roughly 60,000 metric tons).7 Values for silica 

fume under the current use scenario are shown in Table D-5. It was also assumed that 20% of 

GGBFS and 40% of silica fume were used in Federal projects with the remainder being used in 

non-Federal projects. 

 

7

 Personal communication with Hendrick van Oss, USGS, July 12, 2007, and analysis of data from USGS 2005

Minerals Yearbook – Ferroalloys, accessed at: 

http://minerals.usgs.gov/minerals/pubs/commodity/ferroalloys/feallmyb05.pdf.
D-8 

Table D-5: Silica Fume Usage Under Current Use Scenario 

Estimated U.S. Silica 

Fume Consumption 

Silica Fume 

Consumption in Federal 

Projects 

Silica Fume Consumption 

in Non-Federal Projects Year 

------------------------------thousand metric tons-------------------------

2004 60 12 48 

2005 60 12 48 

2006 60 12 48 

2007 60 12 48 

2008 60 12 48 

2009 60 12 48 

2010 60 12 48 

2011 60 12 48 

2012 60 12 48 

2013 60 12 48 

2014 60 12 48 

2015 60 12 48 

Expanded Use Estimates 

In order to estimate potential impacts associated with Federal initiatives to increase beneficial 

use rates, two expanded usage scenarios were developed for coal fly ash. Expanded use scenarios 

were not developed for GGBFS and silica fume since utilization of these materials is already 

very high, and it is unlikely that new initiatives could significantly impact reuse rates. 

Under the first expanded usage scenario for coal fly ash (15% scenario), it was assumed that coal 

fly ash substitution in Federal projects would increase from current reuse rates of approximately 

10% to the levels recommended under the comprehensive procurement guidelines (CPG), which 

is 15% substitution by 2015. Under the second expanded usage scenario (30% scenario), it was 

assumed that coal fly ash substitution in Federal projects would increase from current reuse rates 

of approximately 10% to the maximum levels recommended under the CPG program, which is 

30%, by 2015. For both scenarios, it was assumed that the increase from current reuse to the 

expanded reuse rates would occur incrementally and linearly starting in the year 2009 and 

continuing through the year 2015.8

 Using this methodology, expanded usage for coal fly ash was 

calculated as shown in Table D-6. Figure D-2 illustrates coal fly ash consumption estimates 

under both expanded and current use scenarios.

 

8

 The Bill language instructs all agency heads to implement recommendations of the 30 month study with regard to 

procurement guidelines no later than one year after the release of the study, or approximately early to mid 2009 
D-9 

Table D-6: Coal Fly Ash Usage Under Expanded Use Scenarios 

Estimated U.S. Coal Fly 

Ash Consumption 

Coal Fly Ash Consumption 

in Federal Projects 

Coal Fly Ash Consumption 

Year in Non-Federal Projects 

---------------------------thousand metric tons---------------------------

15% Scenario 

2004 12,811 2,562 10,249 

2005 13,599 2,720 10,879 

2006 14,208 2,842 11,366 

2007 14,820 2,964 11,856 

2008 15,390 3,078 12,312 

2009 16,347 3,269 13,078 

2010 17,221 3,444 13,777 

2011 18,114 3,623 14,491 

2012 18,925 3,785 15,140 

2013 19,754 3,951 15,804 

2014 20,603 4,121 16,482 

2015 21,467 4,293 17,173 

30% Scenario 

2004 12,811 2,562 10,249 

2005 13,599 2,720 10,879 

2006 14,208 2,842 11,366 

2007 14,820 2,964 11,856 

2008 15,390 3,078 12,312 

2009 17,689 3,538 14,151 

2010 19,962 3,992 15,970 

2011 22,311 4,462 17,848 

2012 24,630 4,926 19,704 

2013 27,021 5,404 21,617 

2014 29,486 5,897 23,589 

2015 32,021 6,404 25,616 
D-10

Figure D-2: U.S. Coal Fly Ash Consumption Under Current and Expanded Usage 

Scenarios 

0

2

4

6

8

10

12

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Year

Million Metric Tons

Expanded Use

30%

Expanded Use

15%

Current Use C2P2

Current Use

Baseline

Step 2: Estimation of RMC Unit Impact Values 

The second modeling step involves developing environmental benefit metrics for each RMC, on 

a per metric ton basis. Each metric provides a basis for converting RMC substitution quantities 

into a measure of environmental impact. For example, substituting one metric ton of coal fly ash 

for finished portland cement in concrete has consequent effects on energy usage, water 

consumption, and air emissions related to the portland cement manufacturing process. 

Life cycle analysis (LCA) is a tool that illustrates the full spectrum of these benefits by providing 

quantified estimates of the environmental impacts of a product across all stages in the product’s 

life, from resource extraction through disposal (i.e., “cradle to grave”). The first stage of LCA 

involves developing a life cycle inventory (LCI). The LCI identifies and quantifies the 

environmental flows associated with a product, including energy and raw materials consumed, 

and emissions and wastes released, as a result of its manufacture and use. Life cycle data for 

concrete products that incorporate RMCs are a useful basis for calculating the unit metrics 

described above. Specifically, the model compares the LCIs for a representative concrete 

product using 100% portland cement versus one using a blended cement containing an RMC. 

The difference between these LCIs represents incremental environmental benefit. 
D-11

The remainder of this section summarizes the life cycle data sources that provide the basis for the 

unit metrics, outlines the method of deriving unit metrics from these sources, and presents the 

unit metric values. 

Life Cycle Data Sources 

To generate life cycle impacts from RMC substitution, we rely primarily on data derived from 

the Building for Environmental and Economic Sustainability (BEES) model. With support from 

EPA, the National Institute of Standards and Technology (NIST) developed BEES to compare 

the life cycle environmental impacts of alternative building products.9

 The BEES methodology 

measures environmental performance using an LCA approach, following guidance in the 

International Standards Organization 14040 series of standards for LCA. Thus, all stages in the 

life of the product are analyzed: raw material acquisition, manufacture, transportation, 

installation, use, and recycling and waste management.10 

BEES includes LCI data from concrete industry sources for both generic and brand name 

concrete products. The brand name product data are specific to operations at Lafarge and 

Headwaters Resources (formerly ISG Resources) concrete plants, whereas the generic product 

data reflect concrete industry averages. BEES contains several LCI data sets for concrete 

products that incorporate RMCs at various substitution levels, as well as data for concrete 

products made with 100% portland cement (i.e., without blended cement). The exception 

concerns data for products that incorporate silica fume. BEES includes Lafarge data for products 

with silica fume cement but does not include Lafarge data for products made with 100% portland 

cement. The closest approximation to a 100% portland cement mix-design for Lafarge products 

in BEES is a Portland Type I Cement mix-design, which includes 95% portland cement and 5% 

coal fly ash in the mix. For concrete products made with blended cement, BEES assumes a 1:1 

replacement ratio for portland cement on the basis of mass.11

In this analysis, we use BEES LCI data to estimate the beneficial environmental impacts of coal 

fly ash, GGBFs and silica fume as a partial substitute for portland cement in concrete. The 

beneficial impacts of using RMCs in concrete are measured as the difference in life cycle 

impacts for a concrete product made with 100% portland cement (or the closest approximation 

thereof) and one made with blended cement containing an RMC. Of all the concrete products for 

which LCI data are provided in BEES, we arbitrarily selected a concrete beam with a 

compressive strength of 4 KSI (4,000 psi) and a lifespan of 75 years as the basis of this analysis. 

Selection of a different concrete product in BEES with a different compressive strength (e.g., a 

 

9

 The BEES model and supporting documentation can be downloaded at: www.bfrl.nist.gov/oae/software/bees.html. 10 BEES is a Life Cycle Assessment (LCA) model designed to quantify physical flows of energy, resources, and 

environmental effects at a process-level resolution for specific use applications. An alternative approach would be 

to use an input-output (IO) model. An IO model provides the capacity to evaluate economic and environmental 

effects across the entire supply chain for hundreds of industry sectors. While this approach avoids some of the 

system boundary limitations of process-flow LCAs, our focus for this study was on energy and environmental 

benefits for targeted use applications, for which an LCA process-flow model is more appropriate. 11 Silica fume does not actually replace portland cement in a 1:1 ratio (as is the case with fly ash and GGBFS). The 

addition of silica fume to concrete has a synergistic effect on compressive strength, making the replacement ratio 

complex. For simplicity, however, our model assumes a 1:1 replacement ratio for silica fume and portland cement in 

concrete when modeling life cycle impacts. This is likely to overstate the benefits of the use of this material as an 

SCM. 
D-12

concrete column with a compressive strength of 5 KSI) does not effect the calculation of unit 

impact values. Table D-7 presents the specific BEES data files for a 4 KSI concrete beam that 

were used to calculate unit impact values for coal fly ash, GGBFS and silica fume. It is 

important to note that data files representing higher RMC substitution levels in a concrete beam 

(e.g., 20% fly ash instead of 15% fly ash) could have been selected without effect on the 

calculation of the unit impact value. 

Table D-7: BEES LCI Data files Used to Calculate Unit Impact Values 

4 KSI Concrete Beam 

RMC Category Without Blended Cement With Blended Cement 

Coal Fly Ash 100% portland 

cement Data file B1011A 15% fly ash, 85% portland cement Data file B1011B 

GGBFS 100% portland 

cement Data file B1011A 20% GGBFS, 80% portland cement Data file B1011D 

Silica Fume 

95% portland 

cement, 5% fly ash 

(Portland Type I) 

Data file B1011CC 

10% silica fume, 

85% portland 

cement, 5% fly ash 

Data file B1011S 

For each data file listed in Table D-7, BEES provides complete environmental life cycle 

inventory data. The life cycle inventory data are quantified estimates of the energy and resource 

flows going into the product and the releases to the environment coming from the product, 

summed across all stages of the product life cycle for one cubic yard of concrete product. 

Differences in these flows across products with different RMC substitution levels provide the 

basis for deriving unit values for a suite of environmental metrics. BEES quantifies these flows 

for hundreds of environmental metrics but, to capture the general spectrum of impacts, this 

analysis focused on the following: 

(1) Total primary energy (quantity and dollars); 

(2) Water use (quantity and dollars); 

(3) Greenhouse gas emissions (CO2 from fossil fuels, CF4, CH4, and N20) 

(4) CO emissions; 

(5) Pb emissions to air; 

(6) Hg emissions to air; 

(7) NOx emissions to air; 

(8) PM10 emissions to air; 

(9) SOx emissions to air; and 

(10) Biochemical oxygen demand in water 

(11) Chemical oxygen demand in water 

(12) Copper emissions to water 

(13) Suspended matter in water 

(14) Emissions to soil (sum of all emissions reported by BEES) 

(15) End of life (non-hazardous) waste. 
D-13

Table D-8 presents the complete BEES lifecycle inventory data for the metrics listed above. The 

data fields in Table D-8 are defined as follows: 

a. XPORT DIST: Transport distance of concrete beam to construction site. 

b. FLOW: The environmental impact being reported. 

c. UNIT: The unit in which the environmental flow is reported. 

d. TOTAL: The total impact across all life cycle stages for all three components 

(i.e., the sum of fields COMP1, COMP2 and COMP3). 

e. COMP1: The total impact across all life cycle stages for Component 1. 

Component 1 is the main component, which is a 1 cubic yard concrete beam. 

f. COMP2: The total impact across all life cycle stages for Component 2. 

Component 2 refers to the first installation component associated with the 

concrete beam, but BEES does not provide a specific definition. 

g. COMP3: The total impact across all life cycle stages for Component 3. 

Component 3 refers to the second installation component associated with the 

concrete beam, but BEES does not provide a specific definition. 

h. RAW1: Impacts associated with raw materials extraction for Component 1. 

i. RAW2: Impacts associated with raw materials extraction for Component 2. 

j. RAW3: Impacts associated with raw materials extraction for Component 3. 

k. MFG1: Impacts associated with manufacturing of Component 1. 

l. MFG2: Impacts associated with manufacturing of Component 2. 

m. MFG3: Impacts associated with manufacturing of Component 3. 

n. XPORT1: Impacts associated with transport of Component 1. 

o. XPORT2: Impacts associated with transport of Component 2. 

p. XPORT3: Impacts associated with transport of Component 3. 

q. USE1: Impacts associated with use of the total product (all three components). 

r. WASTE1: Impacts associated with disposal of the total product (all three 

components). 
D-14

Table D-8: BEES Life Cycle Inventory Data 

BEES Data file B1011A: Generic Concrete Beam, 100% Portland Cement (4KSI) 

FLOW UNIT TOTAL COMP1 COMP2 COMP3 RAW1 RAW2 RAW3 MFG1 MFG2 MFG3 XPORT1 

Water Used (total) liter 1,702.10 1,055.10 570.94 4.39 1,011.14 570.02 4.25 6.05 0.00 0.07 37.91 Concrete Beam Cu yd 1.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 1 kg 65.77 0.00 65.77 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Main component kg 1,817.58 1,817.58 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 2 kg 28.57 0.00 0.00 28.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 4 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 5 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 6 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Carbon Dioxide (CO2, fos g 266,110.00 213,972.00 50,991.90 1,146.09 207,804.00 50,863.70 815.22 862.43 0.00 319.85 5,305.62  (a) Carbon Tetrafluoride (CF g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Lead (Pb) g 0.43 0.01 0.42 0.00 0.01 0.42 0.00 0.00 0.00 0.00 0.00  (a) Mercury (Hg) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Methane (CH4) g 297.63 206.68 88.66 2.29 202.58 88.57 1.55 0.57 0.00 0.73 3.52  (a) Nitrogen Oxides (NOx as g 1,299.12 1,171.98 118.58 8.56 1,096.00 117.07 4.87 13.60 0.00 3.56 62.38  (a) Nitrous Oxide (N2O) g 7.10 6.71 0.28 0.12 5.95 0.26 0.08 0.03 0.00 0.04 0.73  (a) Particulates (PM 10) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Sulfur Oxides (SOx as SO g 608.93 479.47 125.58 3.88 471.71 125.41 2.64 0.71 0.00 1.23 7.06  (s) Aluminum (Al) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Arsenic (As) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cadmium (Cd) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Carbon (C) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Calcium (Ca) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Chromium (Cr III, Cr VI) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cobalt (Co) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Copper (Cu) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Iron (Fe) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Lead (Pb) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Manganese (Mn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Mercury (Hg) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nickel (Ni) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nitrogen (N) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Oils (unspecified) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Phosphorus (P) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Sulfur (S) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Zinc (Zn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (w) BOD5 (Biochemical Oxygen g 15.80 7.04 7.47 1.28 6.25 7.45 1.28 0.11 0.00 0.00 0.68  (w) COD (Chemical Oxygen Dem g 82.36 59.57 20.40 2.39 52.89 20.26 2.37 0.92 0.00 0.01 5.76  (w) Copper (Cu+, Cu++) g 0.08 0.00 0.08 0.00 0.00 0.08 0.00 0.00 0.00 0.00 0.00  (w) Suspended Matter (unspec) g 43.64 31.97 9.85 1.81 28.39 9.78 1.80 0.49 0.00 0.01 3.09  Waste (end-of-Life) kg 1,883.35 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  E Total Primary Energy MJ 2,779.14 1,994.61 658.19 126.35 1,904.34 656.30 121.11 12.42 0.00 5.07 77.86 
D-15

BEES Data file B1011B: Generic Concrete Beam, 85% Portland Cement and 15% Fly Ash (4KSI) 

FLOW UNIT TOTAL COMP1 COMP2 COMP3 RAW1 RAW2 RAW3 MFG1 MFG2 MFG3 XPORT1 

 Water Used (total) liter 1,690.06 1,043.05 570.94 4.39 999.10 570.02 4.25 6.05 0.00 0.07 37.91  Concrete Beam Cu yd 1.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 1 kg 65.77 0.00 65.77 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Main component kg 1,817.58 1,817.58 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 2 kg 28.57 0.00 0.00 28.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 4 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 5 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 6 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Carbon Dioxide (CO2, fos g 243,685.00 191,547.00 50,991.90 1,146.09 185,379.00 50,863.70 815.22 862.43 0.00 319.85 5,305.62  (a) Carbon Tetrafluoride (CF g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Lead (Pb) g 0.43 0.01 0.42 0.00 0.01 0.42 0.00 0.00 0.00 0.00 0.00  (a) Mercury (Hg) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Methane (CH4) g 278.61 187.66 88.66 2.29 183.56 88.57 1.55 0.57 0.00 0.73 3.52  (a) Nitrogen Oxides (NOx as g 1,231.00 1,103.86 118.58 8.56 1,027.87 117.07 4.87 13.60 0.00 3.56 62.38  (a) Nitrous Oxide (N2O) g 6.68 6.28 0.28 0.12 5.53 0.26 0.08 0.03 0.00 0.04 0.73  (a) Particulates (PM 10) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Sulfur Oxides (SOx as SO g 555.41 425.95 125.58 3.88 418.19 125.41 2.64 0.71 0.00 1.23 7.06  (s) Aluminum (Al) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Arsenic (As) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cadmium (Cd) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Carbon (C) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Calcium (Ca) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Chromium (Cr III, Cr VI) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cobalt (Co) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Copper (Cu) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Iron (Fe) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Lead (Pb) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Manganese (Mn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Mercury (Hg) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nickel (Ni) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nitrogen (N) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Oils (unspecified) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Phosphorus (P) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Sulfur (S) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Zinc (Zn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (w) BOD5 (Biochemical Oxygen g 15.69 6.93 7.47 1.28 6.14 7.45 1.28 0.11 0.00 0.00 0.68  (w) COD (Chemical Oxygen Dem g 81.45 58.66 20.40 2.39 51.98 20.26 2.37 0.92 0.00 0.01 5.76  (w) Copper (Cu+, Cu++) g 0.08 0.00 0.08 0.00 0.00 0.08 0.00 0.00 0.00 0.00 0.00  (w) Suspended Matter (unspec g 43.14 31.48 9.85 1.81 27.90 9.78 1.80 0.49 0.00 0.01 3.09  Waste (end-of-Life) kg 1,883.35 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  E Total Primary Energy MJ 2,629.00 1,844.47 658.19 126.35 1,754.19 656.30 121.11 12.42 0.00 5.07 77.86 
D-16

BEES Data file B1011D: Generic Concrete Beam, 20% Slag Cement (4KSI) 

FLOW UNIT TOTAL COMP1 COMP2 COMP3 RAW1 RAW2 RAW3 MFG1 MFG2 MFG3 XPORT1 

 Water Used (total) liter 1,695.90 1,048.90 570.94 4.39 1,004.95 570.02 4.25 6.05 0.00 0.07 37.91  Concrete Beam Cu yd 1.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 1 kg 65.77 0.00 65.77 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Main component kg 1,817.58 1,817.58 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 2 kg 28.57 0.00 0.00 28.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 4 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 5 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 6 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Carbon Dioxide (CO2, fos g 237,595.00 185,457.00 50,991.90 1,146.09 179,289.00 50,863.70 815.22 862.43 0.00 319.85 5,305.62  (a) Carbon Monoxide (CO) g 578.28 374.49 202.06 1.74 355.98 201.70 1.16 3.82 0.00 0.55 14.69  (a) Carbon Tetrafluoride (CF g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Lead (Pb) g 0.42 0.01 0.42 0.00 0.01 0.42 0.00 0.00 0.00 0.00 0.00  (a) Mercury (Hg) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Methane (CH4) g 273.15 182.20 88.66 2.29 178.10 88.57 1.55 0.57 0.00 0.73 3.52  (a) Nitrogen Oxides (NOx as g 1,213.22 1,086.08 118.58 8.56 1,010.10 117.07 4.87 13.60 0.00 3.56 62.38  (a) Nitrous Oxide (N2O) g 6.60 6.20 0.28 0.12 5.45 0.26 0.08 0.03 0.00 0.04 0.73  (a) Particulates (PM 10) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Sulfur Oxides (SOx as SO g 540.47 411.01 125.58 3.88 403.25 125.41 2.64 0.71 0.00 1.23 7.06  (s) Aluminum (Al) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Arsenic (As) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cadmium (Cd) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Carbon (C) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Calcium (Ca) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Chromium (Cr III, Cr VI) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cobalt (Co) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Copper (Cu) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Iron (Fe) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Lead (Pb) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Manganese (Mn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Mercury (Hg) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nickel (Ni) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nitrogen (N) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Oils (unspecified) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Phosphorus (P) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Sulfur (S) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Zinc (Zn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (w) BOD5 (Biochemical Oxygen g 15.83 7.07 7.47 1.28 6.28 7.45 1.28 0.11 0.00 0.00 0.68  (w) COD (Chemical Oxygen Dem g 82.64 59.85 20.40 2.39 53.17 20.26 2.37 0.92 0.00 0.01 5.76  (w) Copper (Cu+, Cu++) g 0.08 0.00 0.08 0.00 0.00 0.08 0.00 0.00 0.00 0.00 0.00  (w) Suspended Matter (unspec g 43.78 32.12 9.85 1.81 28.54 9.78 1.80 0.49 0.00 0.01 3.09  Waste (end-of-Life) kg 1,883.35 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  E Total Primary Energy MJ 2,599.20 1,814.67 658.19 126.35 1,724.40 656.30 121.11 12.42 0.00 5.07 77.86 
D-17

BEES Data file B1011CC: Lafarge Concrete Beam, Portland Type I Cement (4KSI) 

FLOW UNIT TOTAL COMP1 COMP2 COMP3 RAW1 RAW2 RAW3 MFG1 MFG2 MFG3 XPORT1 

 Water Used (total) liter 1,667.98 1,020.98 570.94 4.39 977.03 570.02 4.25 6.05 0.00 0.07 37.91  Concrete Beam Cu yd 1.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 1 kg 65.77 0.00 65.77 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Main component kg 1,817.58 1,817.58 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 2 kg 28.57 0.00 0.00 28.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 4 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 5 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 6 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Carbon Dioxide (CO2, fos g 316,116.00 263,978.00 50,991.90 1,146.09 257,810.00 50,863.70 815.22 862.43 0.00 319.85 5,305.62  (a) Carbon Monoxide (CO) g 528.02 324.22 202.06 1.74 305.71 201.70 1.16 3.82 0.00 0.55 14.69  (a) Carbon Tetrafluoride (CF g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Lead (Pb) g 0.44 0.02 0.42 0.00 0.02 0.42 0.00 0.00 0.00 0.00 0.00  (a) Mercury (Hg) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Methane (CH4) g 361.22 270.27 88.66 2.29 266.18 88.57 1.55 0.57 0.00 0.73 3.52  (a) Nitrogen Oxides (NOx as g 1,647.13 1,519.99 118.58 8.56 1,444.01 117.07 4.87 13.60 0.00 3.56 62.38  (a) Nitrous Oxide (N2O) g 5.81 5.41 0.28 0.12 4.65 0.26 0.08 0.03 0.00 0.04 0.73  (a) Particulates (PM 10) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Sulfur Oxides (SOx as SO g 1,734.02 1,604.56 125.58 3.88 1,596.80 125.41 2.64 0.71 0.00 1.23 7.06  (s) Aluminum (Al) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Arsenic (As) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cadmium (Cd) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Carbon (C) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Calcium (Ca) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Chromium (Cr III, Cr VI) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cobalt (Co) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Copper (Cu) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Iron (Fe) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Lead (Pb) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Manganese (Mn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Mercury (Hg) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nickel (Ni) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nitrogen (N) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Oils (unspecified) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Phosphorus (P) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Sulfur (S) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Zinc (Zn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (w) BOD5 (Biochemical Oxygen g 15.67 6.92 7.47 1.28 6.13 7.45 1.28 0.11 0.00 0.00 0.68  (w) COD (Chemical Oxygen Dem g 80.79 58.00 20.40 2.39 51.32 20.26 2.37 0.92 0.00 0.01 5.76  (w) Copper (Cu+, Cu++) g 0.08 0.00 0.08 0.00 0.00 0.08 0.00 0.00 0.00 0.00 0.00  (w) Suspended Matter (unspec g 45.91 34.25 9.85 1.81 30.66 9.78 1.80 0.49 0.00 0.01 3.09  Waste (end-of-Life) kg 1,883.35 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  E Total Primary Energy MJ 3,011.48 2,226.95 658.19 126.35 2,136.68 656.30 121.11 12.42 0.00 5.07 77.86 
D-18

BEES Data file B1011S: Lafarge Concrete Beam, 10% Silica Fume Cement (4KSI) 

FLOW UNIT TOTAL COMP1 COMP2 COMP3 RAW1 RAW2 RAW3 MFG1 MFG2 MFG3 XPORT1 

 Water Used (total) liter 1,776.93 1,129.92 570.94 4.39 1,085.97 570.02 4.25 6.05 0.00 0.07 37.91  Concrete Beam Cu yd 1.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 1 kg 65.77 0.00 65.77 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Main component kg 1,817.58 1,817.58 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Installation component 2 kg 28.57 0.00 0.00 28.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 4 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 5 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  Component 6 kg 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Carbon Dioxide (CO2, fos g 301,197.00 249,059.00 50,991.90 1,146.09 242,891.00 50,863.70 815.22 862.43 0.00 319.85 5,305.62  (a) Carbon Monoxide (CO) g 479.46 275.66 202.06 1.74 257.15 201.70 1.16 3.82 0.00 0.55 14.69  (a) Carbon Tetrafluoride (CF g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (a) Lead (Pb) g 0.43 0.01 0.42 0.00 0.01 0.42 0.00 0.00 0.00 0.00 0.00  (a) Mercury (Hg) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Methane (CH4) g 212.79 121.85 88.66 2.29 117.75 88.57 1.55 0.57 0.00 0.73 3.52  (a) Nitrogen Oxides (NOx as g 1,040.88 913.74 118.58 8.56 837.75 117.07 4.87 13.60 0.00 3.56 62.38  (a) Nitrous Oxide (N2O) g 6.81 6.41 0.28 0.12 5.65 0.26 0.08 0.03 0.00 0.04 0.73  (a) Particulates (PM 10) g 0.01 0.01 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00  (a) Sulfur Oxides (SOx as SO g 826.84 697.38 125.58 3.88 689.62 125.41 2.64 0.71 0.00 1.23 7.06  (s) Aluminum (Al) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Arsenic (As) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cadmium (Cd) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Carbon (C) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Calcium (Ca) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Chromium (Cr III, Cr VI) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Cobalt (Co) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Copper (Cu) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Iron (Fe) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Lead (Pb) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Manganese (Mn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Mercury (Hg) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nickel (Ni) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Nitrogen (N) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Oils (unspecified) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Phosphorus (P) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Sulfur (S) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (s) Zinc (Zn) g 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  (w) BOD5 (Biochemical Oxygen g 16.12 7.36 7.47 1.28 6.57 7.45 1.28 0.11 0.00 0.00 0.68  (w) COD (Chemical Oxygen Dem g 85.09 62.30 20.40 2.39 55.62 20.26 2.37 0.92 0.00 0.01 5.76  (w) Copper (Cu+, Cu++) g 0.08 0.00 0.08 0.00 0.00 0.08 0.00 0.00 0.00 0.00 0.00  (w) Suspended Matter (unspec g 47.09 35.42 9.85 1.81 31.84 9.78 1.80 0.49 0.00 0.01 3.09  Waste (end-of-Life) kg 1,883.35 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00  E Total Primary Energy MJ 2,309.89 1,525.36 658.19 126.35 1,435.09 656.30 121.11 12.42 0.00 5.07 77.86 
D-19

Figure D-3 shows the assumed life cycle system boundaries for a 4 KSI concrete beam in BEES made 

without blended cement. The LCI data presented in Table D-8 reflect these system boundaries. 

Figure D-3: System boundaries for 4 KSI concrete beam without blended cement 

Figure D-4 shows the assumed life cycle system boundaries for a 4 KSI concrete beam in BEES made 

with blended cement (i.e., incorporating an RMC). 

Figure D-4: System boundaries for 4 KSI concrete beam with blended cement
D-20

Estimating the Unit Impact of Using RMCs 

The BEES data presented in Table D-8 above were used to calculate the benefits of using a specified 

unit (in this case, one metric ton) of each RMC in concrete by taking the difference in environmental 

impacts between a concrete product made with 100% portland cement and one made with an RMC at a 

given substitution level (holding compressive strength and assumed transport distance constant for 

both products). To illustrate the methodology, a sample calculation of an environmental impact metric 

concerning CO2 emissions reductions resulting from the substitution of coal fly ash for portland 

cement is presented (see Table D-9). As illustrated in this table, the process proceeds through two 

steps: 

• Step 1 - derive impact per cubic yard of concrete. This step relies on the BEES data, which 

is derived on a cubic yard basis, using the LCIs described above. Specifically, it derives a CO2

emissions profile for a concrete product using two mix designs: one using 100% portland 

cement and one using 15% coal fly ash and 85% portland cement. The difference between the 

CO2 emissions profiles for the two mix designs represents the initial measure of environmental 

impact. For example, the manufacture of one cubic yard of concrete using 15% coal fly ash 

results in 22,425 fewer grams of CO2 emissions compared to a cubic yard of concrete made 

with 100% portland cement. 

• Step 2 - derive impact per metric ton of coal fly ash. This step translates the CO2 emissions 

per cubic yard of concrete into a measure per metric ton of coal fly ash. This translation is 

required to match the RMC substitution scenarios, which are presented in metric tons. The 

process requires first estimating the proportion of one metric ton of coal fly ash present in a 

cubic yard of concrete, given a 15% substitution rate. This proportion is dependent upon the 

pounds of cementitious material present in a cubic yard of concrete, which varies depending 

upon concrete mix design. As shown in the table, the calculations yield an estimate of avoided 

CO2 emissions per metric ton of coal fly ash substituted equal to 701,378 grams. 

A similar process is repeated for each of the environmental metrics listed above, for each RMC. 
D-21

Table D-9: Example Calculation of Impact Metric for Avoided CO2 Related to 15% Coal Fly Ash 

Substitution 

Impacts per cubic Yard Concrete 

 Code 

Note/Sources 

100% portland 

cement 

[a] 266,110 grams 

per cubic yard 

of concrete 

Values represent impacts related to building products 

and pavement as characterized in BEES data file 

B1011A. BEES Version 3.0 Performance Data. 

15% coal fly 

ash 

[b] 243,685 grams 

per cubic yard 

of concrete 

Values represent impacts related to building products 

and pavement as characterized in BEES data file 

B1011B. BEES Version 3.0 Performance Data. 

Incremental 

benefit 

[c]=[a]-[b] 22,425 grams 

per cubic yard 

of concrete 

Represents CO2 reduced per cubic yard of concrete 

produced with 15% fly ash substitution for portland 

cement. 

Impacts per Metric Ton Coal Fly Ash 

lbs cement/yd3

concrete 

[d] 470 lbs 

cement/cubic 

yard of 

concrete 

Represents proportion of cubic yard of concrete made 

up of cementitious material, given a mix-design or 

constituent density (Lipiatt, 2002, p. 40). 

% coal fly ash 

substitution 

[e] 15% Fifteen percent of cementitious material is replaced with 

coal fly ash. 

lbs/metric ton [f] 2,205 

lbs/metric ton 

Conversion for pounds to metric tons. 

MT coal fly 

ash/yd3

concrete 

[g]=[d]*[e]/[f] 0.032 MT coal 

fly ash/cubic 

yard of 

concrete 

Conversion of quantity of coal fly ash in one cubic yard 

of concrete from pounds to metric tons. 

unit impact [h]=[c]/[g] 701,378 grams 

per metric ton 

of coal fly ash 

substituted for 

cement 

Represent unit impact values for CO2 (in grams), based 

on substitution of one metric ton of coal fly ash in a 

concrete building product or pavement. 
D-22

The greenhouse gas metrics taken from BEES (i.e., CO2, CH4, N20 and CF4 emissions) were 

converted to equivalent impacts such as Carbon Dioxide equivalent, passenger cars removed 

from the road for one year, passenger cars and light trucks removed from the road for one year, 

avoided gasoline consumption, and avoided oil consumption, using the Greenhouse Gas 

Equivalencies Calculator developed by the U.S. Climate Technology Cooperation (U.S.-CTC).12

It is important to note that these metrics are equivalent expressions of the avoided greenhouse 

gas metrics reported by BEES; they do not represent additional benefits. 

Unit Impact Values 

Table D-10 presents estimates of the environmental impacts avoided per metric ton of RMC used 

as a substitute for finished portland cement. As shown in the table, separate estimates were 

developed for coal fly ash, GGBFS, and silica fume. 13

 

12 The Greenhouse Gas Equivalencies Calculator can be accessed at: http://www.usctcgateway.net/tool/. Avoided 

Carbon Dioxide equivalent is an expression of the cumulative global warming potential of all four greenhouse 

gasses for which BEES data were available (CO2, CF4, CH4, and N20). It is calculated from the global warming 

potentials of individual greenhouse gasses, using the global warming potential of C02 as the reference point. 13 Analysis of life cycle impacts is, in its simplest form, the calculation of all impacts associated with a single 

production system. However, when one production system (or a set of linked production systems) makes two or 

more products with market value (i.e., co-products) it is accepted practice in life cycle analysis to allocate the total 

life cycle production impacts across products. It is important to consider whether co-products of electricity 

generation (e.g., fly ash) that are beneficially used should have some portion of the production impacts associated 

with coal combustion (e.g., energy use, greenhouse gas equivalents) attributed to them. The allocated impacts from 

coal-fired generation would likely associate only very small flows to the RMCs modeled in this Report. For this 

reason, we do not include either an economic or mass-based allocation in our analysis. 
D-23

Table D-10: Environmental Impacts Avoided per Metric Ton of RMC Used as a Substitute 

for Finished Portland Cement in Concrete 

-----------------------Material --------------------- 

Metric

Coal Fly Asha GGBFS Silica Fumeb

Energy Savings (megajoules) 4,695.9 4,220.9 32,915.0

Energy Savings (US $) 129.1 116.1 905.2

Water Savings (Liters) 376.3 145.2 -5,111.4

Water Savings (US $) 0.2 0.1 -3.2

Avoided CO2 Equivalent (GHG) (grams)c 718,000.0 Not calculated Not calculated

Avoided CO2 Emissions (grams) 701,377.7 668,889.1 699,923.3

Avoided CF4 Emissions(grams) 0.0 Not calculated Not calculated

Avoided CH4 Emissions (grams) 594.8 Not calculated Not calculated

Avoided N2O Emissions (grams) 13.2 Not calculated Not calculated

Passenger cars not driven for one yeard 0.2 Not calculated Not calculated

Passenger cars and light trucks not driven 

for one yeard 0.1 Not calculated Not calculated

Avoided gasoline consumption (liters)d 310.0 Not calculated Not calculated

Avoided oil consumption (barrels) b 1.7 Not calculated Not calculated

Avoided NO2 Emissions (grams) 2,130.2 2,014.8 28,442.2

Avoided PM10 Emissions (grams) 0.0 0.0 -0.1

Avoided SOx Emission (grams) 1,673.9 1,605.8 42,560.1

Avoided CO Emissions (grams) 654.3 621.5 2,278.2

Avoided Hg Emissions (grams) 0.0 0.0 -0.3

Avoided Pb Emissions (grams) 0.0 0.0 0.6

Avoided biochemical oxygen demand in 

water (grams) 3.4 -0.8 -21.0

Avoided chemical oxygen demand in water 

(grams) 28.7 -6.5 -201.4

Avoided copper water emissions (grams) 0.0 0.0 0.0

Avoided suspended matter in water (grams) 15.4 -3.5 -55.1

Avoided emissions to soil (grams) 0.0 0.0 0.0

Avoided end of life waste (kilograms) 0.0 0.0 0.0

Notes: 

a. Impact metrics based upon representative concrete products for building and pavement applications. 

b. Negative values represent an incremental increase in impacts relative to the use of portland cement. 
D-24

-----------------------Material --------------------- 

Metric

Coal Fly Asha GGBFS Silica Fumeb

c. Avoided CO2 equivalent is an expression of the cumulative global warming potential of all four 

greenhouse gasses for which BEES data were available (CO2, CF4, CH4, and N20). It can be calculated 

from the global warming potentials of individual greenhouse gasses, using the global warming potential of 

C02 as the reference point. Avoided CO2 equivalent was calculated using the Greenhouse Gas 

Equivalencies Calculator developed by the U.S. Climate Technology Cooperation (accessed at: 

http://www.usctcgateway.net/tool/). 

d. The greenhouse gas metrics taken from BEES were converted to equivalent impacts such as passenger 

cars removed from the road for one year, passenger cars and light trucks removed from the road for one 

year, avoided gasoline consumption, and avoided oil consumption, using the Greenhouse Gas 

Equivalencies Calculator. It is important to note that these metrics are equivalent expressions of the 

avoided greenhouse gas metrics reported by BEES; they do not represent additional benefits. 

GHG equivalency metrics were not calculated for GGBFS and silica fume, due primarily to the fact that 

use of these materials is unlikely to change significantly across scenarios. 

Step 3: Environmental Impact Profile Calculations

The final step in estimating an environmental impact profile for each RMC is to multiply the 

appropriate RMC substitution figures by the set of relevant impact metrics. Table D-11 below 

illustrates a profile for coal fly ash, based on estimated substitution levels for 2004. Column "c" 

captures the environmental benefit measures. 
D-25

Table D-11: Example Environmental Impact Profile for Coal fly ash Substituted for 

Portland Cement, 2004 

Incremental Impact 

Avoided per 1 MT Fly

Ash 

MT of Fly Ash 

Substituted (2004) 

Environmental Impact 

Profile 

 Metric 

[a] [b] c =[a]*[b] 

Energy Savings (megajoules) 4,695.9 2,562,000 12,030,806,021 

Energy Savings (US $) 129.1 2,562,000 330,847,166 

Water Savings (Liters) 376.3 2,562,000 963,971,579 

Water Savings (US $) 0.2 2,562,000 595,887 

Avoided CO2 Equivalent (GHG) 

(grams) 718,000.0 2,562,000 1,839,516,000,000 

Avoided CO2 Emissions (grams) 701,377.7 2,562,000 1,796,929,563,830 

Avoided CF4 Emissions (grams) 0.0 2,562,000 0 

Avoided CH4 Emissions (grams) 594.8 2,562,000 1,523,844,349 

Avoided N2O Emissions (grams) 13.2 2,562,000 33,787,885 

Passenger cars not driven for one yeard 0.2 2,562,000 409,920 

Passenger cars and light trucks not 

driven for one yeard 0.1 2,562,000 333,060 

Avoided gasoline consumption (liters) 310.0 2,562,000 794,220,000 

Avoided oil consumption (barrels) 1.7 2,562,000 4,278,540 

Avoided NO2 Emissions (grams) 2,130.2 2,562,000 5,457,697,774 

Avoided PM10 Emissions (grams) 0.0 2,562,000 29,248 

Avoided SOx Emission (grams) 1,673.9 2,562,000 4,288,431,500 

Avoided CO Emissions (grams) 654.3 2,562,000 1,676,332,953 

Avoided Hg Emissions (grams) 0.0 2,562,000 108,898 

Avoided Pb Emissions (grams) 0.0 2,562,000 80,852 

Avoided biochemical oxygen demand in 

water (grams) 3.4 2,562,000 8,678,148 

Avoided chemical oxygen demand in 

water (grams) 28.7 2,562,000 73,439,730 

Avoided copper water emissions 

(grams) 0.0 2,562,000 0 

Avoided suspended matter in water 

(grams) 15.4 2,562,000 39,424,274 

Avoided emissions to soil (grams) 0.0 2,562,000 0 

Avoided end of life waste (kilograms) 0.0 2,562,000 0 
D-26

The environmental impact profile is calculated in this way for the quantity of each RMC used in 

Federal concrete projects under current and expanded substitution scenarios for years 2004 to 

2015.14 Table D-12 presents the detailed results of these calculations.

 

14 The detailed results utilize certain additional refinements for consistent reporting purposes. For example, 

emission impacts may be converted from grams to metric tons. In addition, certain of the metrics, including water 

and energy consumption, are monetized. Appropriate discounting protocols are applied to these monetized figures. 
D-27

Table D-12: Detailed Environmental Impact Calculations 

Fly Ash Current Use Baseline Scenario 2004 2005 2006 2007 2008 2009 2010 2011 2012 Energy Savings billion megajoules 12.0 12.8 13.1 13.3 13.6 13.9 14.2 14.5 14.7 Energy Savings billion ($ 2006) 0.3 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Energy Savings billion ($ discounted @ 7%) 0.3 0.4 0.4 0.3 0.3 0.3 0.3 0.3 0.3 Water Savings billion liters 1.0 1.0 1.0 1.1 1.1 1.1 1.1 1.2 1.2 Water Savings million ($ 2006) 0.6 0.6 0.6 0.7 0.7 0.7 0.7 0.7 0.7 Water Savings million ($ discounted @ 7%) 0.6 0.6 0.6 0.6 0.6 0.6 0.5 0.5 0.5 Avoided C02 Equivalent (air) million metric tons 1.8 2.0 2.0 2.0 2.1 2.1 2.2 2.2 2.3 

Avoided CO2 million metric tons 1.8 1.9 1.9 2.0 2.0 2.1 2.1 2.2 2.2 Avoided CF4 metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided CH4 thousand metric tons 1.5 1.6 1.7 1.7 1.7 1.8 1.8 1.8 1.9 Avoided N20 metric tons 33.8 35.9 36.7 37.5 38.2 39.0 39.8 40.6 41.4 

Passenger cars not driven for one year million passenger cars 0.4 0.4 0.4 0.5 0.5 0.5 0.5 0.5 0.5 Passenger cars and light trucks not driven for one year 

million passenger cars and light trucks 0.3 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 

Avoided gasoline consumption billion liters 0.8 0.8 0.9 0.9 0.9 0.9 0.9 1.0 1.0 Avoided oil consumption billion barrels 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided NOx (air) thousand metric tons 5.5 5.8 5.9 6.0 6.2 6.3 6.4 6.6 6.7 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 4.3 4.6 4.7 4.8 4.9 5.0 5.1 5.2 5.3 Avoided CO (air) thousand metric tons 1.7 1.8 1.8 1.9 1.9 1.9 2.0 2.0 2.1 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Avoided biochemical oxygen demand (water) metric tons 8.7 9.2 9.4 9.6 9.8 10.0 10.2 10.4 10.6 Avoided chemical oxygen demand (water) metric tons 73.4 78.0 79.7 81.4 83.1 84.8 86.6 88.3 90.0 Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) metric tons 39.4 41.9 42.8 43.7 44.6 45.5 46.5 47.4 48.3 Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
D-28

Fly Ash Current Use C2P2 Scenario 2004 2005 2006 2007 2008 2009 2010 2011 2012 Energy Savings billion megajoules 12.0 12.8 13.3 13.9 14.5 14.9 15.4 15.8 16.2 Energy Savings billion ($ 2006) 0.3 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Energy Savings billion ($ discounted @ 7%) 0.3 0.4 0.4 0.4 0.3 0.3 0.3 0.3 0.3 Water Savings billion liters 1.0 1.0 1.1 1.1 1.2 1.2 1.2 1.3 1.3 Water Savings million ($ 2006) 0.6 0.6 0.7 0.7 0.7 0.7 0.8 0.8 0.8 Water Savings million ($ discounted @ 7%) 0.6 0.6 0.7 0.6 0.6 0.6 0.6 0.5 0.5 Avoided C02 Equivalent (air) million metric tons 1.8 2.0 2.0 2.1 2.2 2.3 2.4 2.4 2.5 

Avoided CO2 million metric tons 1.8 1.9 2.0 2.1 2.2 2.2 2.3 2.4 2.4 Avoided CF4 metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided CH4 thousand metric tons 1.5 1.6 1.7 1.8 1.8 1.9 2.0 2.0 2.0 Avoided N20 metric tons 33.8 35.9 37.5 39.1 40.6 42.0 43.2 44.5 45.4 

Passenger cars not driven for one year million passenger cars 0.4 0.4 0.5 0.5 0.5 0.5 0.5 0.5 0.6 Passenger cars and light trucks not driven for one year 

million passenger cars and light trucks 0.3 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 

Avoided gasoline consumption billion liters 0.8 0.8 0.9 0.9 1.0 1.0 1.0 1.0 1.1 Avoided oil consumption billion barrels 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided NOx (air) thousand metric tons 5.5 5.8 6.1 6.3 6.6 6.8 7.0 7.2 7.3 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 4.3 4.6 4.8 5.0 5.2 5.3 5.5 5.6 5.8 Avoided CO (air) thousand metric tons 1.7 1.8 1.9 1.9 2.0 2.1 2.1 2.2 2.3 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Avoided biochemical oxygen demand (water) metric tons 8.7 9.2 9.6 10.0 10.4 10.8 11.1 11.4 11.7 Avoided chemical oxygen demand (water) metric tons 73.4 78.0 81.5 85.0 88.2 91.2 94.0 96.7 98.6 Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) metric tons 39.4 41.9 43.7 45.6 47.4 49.0 50.5 51.9 53.0 Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
D-29

Impacts Attributable to C2P2a 2004 2005 2006 2007 2008 2009 2010 2011 2012 Energy Savings billion megajoules 0.0 0.0 0.3 0.6 0.8 1.0 1.2 1.4 1.4 Energy Savings billion ($ 2006) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Energy Savings billion ($ discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water Savings billion liters 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 0.1 Water Savings million ($ 2006) 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 Water Savings million ($ discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided C02 Equivalent (air) million metric tons 0.0 0.0 0.0 0.1 0.1 0.2 0.2 0.2 0.2 

Avoided CO2 million metric tons 0.0 0.0 0.0 0.1 0.1 0.2 0.2 0.2 0.2 Avoided CF4 metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided CH4 thousand metric tons 0.0 0.0 0.0 0.1 0.1 0.1 0.2 0.2 0.2 Avoided N20 metric tons 0.0 0.0 0.8 1.6 2.3 2.9 3.4 3.9 4.0 

Passenger cars not driven for one year million passenger cars 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Passenger cars and light trucks not driven for one year 

million passenger cars and light trucks 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Avoided gasoline consumption billion liters 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 0.1 Avoided oil consumption billion barrels 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided NOx (air) thousand metric tons 0.0 0.0 0.1 0.3 0.4 0.5 0.6 0.6 0.6 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 0.0 0.0 0.1 0.2 0.3 0.4 0.4 0.5 0.5 Avoided CO (air) thousand metric tons 0.0 0.0 0.0 0.1 0.1 0.1 0.2 0.2 0.2 Avoided Hg (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Pb (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Biochemical oxygen demand (water) metric tons 0.0 0.0 0.2 0.4 0.6 0.8 0.9 1.0 1.0 Avoided chemical oxygen demand (water) metric tons 0.0 0.0 1.8 3.6 5.1 6.4 7.4 8.5 8.6 Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) metric tons 0.0 0.0 1.0 1.9 2.7 3.4 4.0 4.5 4.6 Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the Fly Ash Current Use C2P2 Scenario minus the Fly Ash Current Use Baseline Scenario. 
D-30

GGBFS Current Use Scenario 2004 2005 2006 2007 2008 2009 2010 2011 2012 Energy Savings billion megajoules 2.9 3.0 3.1 3.1 3.2 3.2 3.3 3.4 3.4 Energy Savings billion ($ 2006) 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Energy Savings billion ($ discounted @ 7%) 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Water Savings billion liters 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Water Savings million ($ 2006) 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Water Savings million ($ discounted @ 7%) 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.0 0.0 Avoided CO2 million metric tons 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 Avoided NOx (air) thousand metric tons 1.4 1.4 1.5 1.5 1.5 1.5 1.6 1.6 1.6 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 1.1 1.1 1.2 1.2 1.2 1.2 1.3 1.3 1.3 Avoided CO (air) thousand metric tons 0.4 0.4 0.4 0.5 0.5 0.5 0.5 0.5 0.5 Avoided Hg (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Pb (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Biochemical oxygen demand (water) metric tons 

-0.5 -0.5 -0.6 -0.6 -0.6 -0.6 -0.6 -0.6 -0.6 

Avoided chemical oxygen demand (water) metric tons 

-4.5 -4.6 -4.7 -4.8 -4.9 -5.0 -5.1 -5.2 -5.3 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) metric tons 

-2.4 -2.5 -2.5 -2.6 -2.6 -2.7 -2.7 -2.8 -2.8 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
D-31

Silica Fume Current Use Scenario 2004 2005 2006 2007 2008 2009 2010 2011 2012 Energy Savings billion megajoules 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Energy Savings billion ($ 2006) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Energy Savings billion ($ discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water Savings billion liters -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 Water Savings million ($ 2006) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water Savings million ($ discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided CO2 million metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided NOx (air) thousand metric tons 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 Avoided CO (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Hg (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Pb (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Biochemical oxygen demand (water) metric tons 

-0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 

Avoided chemical oxygen demand (water) metric tons 

-2.4 -2.4 -2.4 -2.4 -2.4 -2.4 -2.4 -2.4 -2.4 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) metric tons 

-0.7 -0.7 -0.7 -0.7 -0.7 -0.7 -0.7 -0.7 -0.7 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
D-32

Total Current Use C2P2 Scenarioa 2004 2005 2006 2007 2008 2009 2010 2011 2012 Energy Savings billion megajoules 15.3 16.2 16.8 17.4 18.0 18.6 19.1 19.6 20.0 Energy Savings billion ($ 2006) 0.4 0.4 0.5 0.5 0.5 0.5 0.5 0.5 0.5 Energy Savings billion ($ discounted @ 7%) 0.4 0.4 0.5 0.4 0.4 0.4 0.4 0.4 0.4 Water Savings billion liters 1.0 1.1 1.1 1.2 1.2 1.2 1.3 1.3 1.4 Water Savings million ($ 2006) 0.6 0.7 0.7 0.7 0.7 0.8 0.8 0.8 0.8 Water Savings million ($discounted @ 7%) 0.6 0.7 0.7 0.7 0.6 0.6 0.6 0.6 0.5 Avoided CO2 million metric tons 2.3 2.4 2.5 2.6 2.7 2.8 2.8 2.9 3.0 Avoided NOx (air) thousand metric tons 7.2 7.6 7.9 8.1 8.4 8.7 8.9 9.1 9.3 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 5.9 6.2 6.4 6.7 6.9 7.1 7.3 7.4 7.6 Avoided CO (air) thousand metric tons 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.7 2.8 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.2 0.2 0.2 0.2 0.2 0.2 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Avoided Biochemical oxygen demand (water) metric tons 

7.9 8.4 8.8 9.2 9.6 9.9 10.3 10.6 10.8 

Avoided chemical oxygen demand (water) metric tons 

66.5 71.0 74.4 77.8 80.9 83.8 86.5 89.1 90.9 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) metric tons 

36.4 38.7 40.6 42.4 44.1 45.6 47.1 48.5 49.5 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the sum of the fly ash current use C2P2, current use GGBFS and current use silica fume scenarios. The expanded GHG metrics are not included 

were not evaluated for either GGBFS or silica fume. 
D-33

Fly Ash Expanded Use 15% Scenario 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 12.0 12.8 13.3 13.9 14.5 16.0 17.3 18.8 20.2 21.7 Energy Savings billion ($2006) 0.3 0.4 0.4 0.4 0.4 0.4 0.5 0.5 0.6 0.6 Energy Savings billion ($discounted @ 7%) 0.3 0.4 0.4 0.4 0.3 0.4 0.4 0.4 0.4 0.4 Water Savings billion liters 1.0 1.0 1.1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Water Savings million ($2006) 0.6 0.6 0.7 0.7 0.7 0.8 0.9 0.9 1.0 1.1 Water Savings million ($discounted @ 7%) 0.6 0.6 0.7 0.6 0.6 0.6 0.6 0.6 0.6 0.6 Avoided C02 Equivalent (air) million metric tons 1.8 2.0 2.0 2.1 2.2 2.4 2.7 2.9 3.1 3.3 

Avoided CO2 million metric tons 1.8 1.9 2.0 2.1 2.2 2.4 2.6 2.8 3.0 3.2 Avoided CF4 metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided CH4 thousand metric tons 1.5 1.6 1.7 1.8 1.8 2.0 2.2 2.4 2.6 2.7 Avoided N20 metric tons 33.8 35.9 37.5 39.1 40.6 44.8 48.7 52.7 56.7 60.9 

Passenger cars not driven for one year million passenger cars 0.4 0.4 0.5 0.5 0.5 0.5 0.6 0.6 0.7 0.7 Passenger cars and light trucks not driven for one year 

million passenger cars and light trucks 0.3 0.4 0.4 0.4 0.4 0.4 0.5 0.5 0.6 0.6 

Avoided gasoline consumption billion liters 0.8 0.8 0.9 0.9 1.0 1.1 1.1 1.2 1.3 1.4 Avoided oil consumption billion barrels 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided NOx (air) thousand metric tons 5.5 5.8 6.1 6.3 6.6 7.2 7.9 8.5 9.2 9.8 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 Avoided SOx (air) thousand metric tons 4.3 4.6 4.8 5.0 5.2 5.7 6.2 6.7 7.2 7.7 Avoided CO (air) thousand metric tons 1.7 1.8 1.9 1.9 2.0 2.2 2.4 2.6 2.8 3.0 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.2 0.2 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Avoided biochemical oxygen demand (water) 

metric tons 

8.7 9.2 9.6 10.0 10.4 11.5 12.5 13.5 14.6 15.6 

Avoided chemical oxygen demand (water) 

metric tons 

73.4 78.0 81.5 85.0 88.2 97.4 105.8 114.5 123.3 132.4 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

39.4 41.9 43.7 45.6 47.4 52.3 56.8 61.5 66.2 71.1 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
D-34

Fly Ash Expanded Use 30% Scenario 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 12.0 12.8 13.3 13.9 14.5 19.1 23.8 28.6 33.6 38.7 Energy Savings billion ($2006) 0.3 0.4 0.4 0.4 0.4 0.5 0.7 0.8 0.9 1.1 Energy Savings billion ($discounted @ 7%) 0.3 0.4 0.4 0.4 0.3 0.4 0.5 0.5 0.6 0.6 Water Savings billion liters 1.0 1.0 1.1 1.1 1.2 1.5 1.9 2.3 2.7 3.1 Water Savings million ($2006) 0.6 0.6 0.7 0.7 0.7 0.9 1.2 1.4 1.7 1.9 Water Savings million ($discounted @ 7%) 0.6 0.6 0.7 0.6 0.6 0.8 0.9 1.0 1.1 1.2 Avoided C02 Equivalent (air) million metric tons 1.8 2.0 2.0 2.1 2.2 2.9 3.6 4.4 5.1 5.9 

Avoided CO2 million metric tons 1.8 1.9 2.0 2.1 2.2 2.9 3.6 4.3 5.0 5.8 Avoided CF4 metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided CH4 thousand metric tons 1.5 1.6 1.7 1.8 1.8 2.4 3.0 3.6 4.3 4.9 Avoided N20 metric tons 33.8 35.9 37.5 39.1 40.6 53.7 66.8 80.4 94.3 108.8 

Passenger cars not driven for one year million passenger cars 0.4 0.4 0.5 0.5 0.5 0.7 0.8 1.0 1.1 1.3 Passenger cars and light trucks not driven for one year 

million passenger cars and light trucks 0.3 0.4 0.4 0.4 0.4 0.5 0.7 0.8 0.9 1.1 

Avoided gasoline consumption billion liters 0.8 0.8 0.9 0.9 1.0 1.3 1.6 1.9 2.2 2.6 Avoided oil consumption billion barrels 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided NOx (air) thousand metric tons 5.5 5.8 6.1 6.3 6.6 8.7 10.8 13.0 15.2 17.6 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 Avoided SOx (air) thousand metric tons 4.3 4.6 4.8 5.0 5.2 6.8 8.5 10.2 12.0 13.8 Avoided CO (air) thousand metric tons 1.7 1.8 1.9 1.9 2.0 2.7 3.3 4.0 4.7 5.4 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.3 0.3 0.4 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.2 0.3 Avoided biochemical oxygen demand (water) 

metric tons 

8.7 9.2 9.6 10.0 10.4 13.8 17.1 20.6 24.2 27.9 

Avoided chemical oxygen demand (water) 

metric tons 

73.4 78.0 81.5 85.0 88.2 116.7 145.1 174.7 205.1 236.5 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

39.4 41.9 43.7 45.6 47.4 62.6 77.9 93.8 110.1 127.0 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
D-35

Total 15% Scenarioa 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 15.3 16.2 16.8 17.4 18.0 19.6 21.0 22.5 24.0 25.6 Energy Savings billion ($2006) 0.4 0.4 0.5 0.5 0.5 0.5 0.6 0.6 0.7 0.7 Energy Savings billion ($discounted @ 7%) 0.4 0.4 0.5 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Water Savings billion liters 1.0 1.1 1.1 1.2 1.2 1.3 1.4 1.6 1.7 1.8 Water Savings million ($2006) 0.6 0.7 0.7 0.7 0.7 0.8 0.9 1.0 1.0 1.1 Water Savings million ($discounted @ 7%) 0.6 0.7 0.7 0.7 0.6 0.7 0.7 0.7 0.7 0.7 Avoided CO2 million metric tons 2.3 2.4 2.5 2.6 2.7 2.9 3.1 3.3 3.6 3.8 Avoided NO2 (air) thousand metric tons 7.2 7.6 7.9 8.1 8.4 9.1 9.8 10.5 11.1 11.8 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 Avoided SOx (air) thousand metric tons 5.9 6.2 6.4 6.7 6.9 7.4 7.9 8.5 9.0 9.6 Avoided CO (air) thousand metric tons 2.1 2.2 2.3 2.4 2.5 2.7 2.9 3.1 3.3 3.6 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.2 0.2 0.2 0.2 0.2 0.2 0.2 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.2 Avoided biochemical oxygen demand (water) 

metric tons 

7.9 8.4 8.8 9.2 9.6 10.7 11.7 12.7 13.7 14.8 

Avoided chemical oxygen demand (water) 

metric tons 

66.5 71.0 74.4 77.8 80.9 90.0 98.3 106.9 115.6 124.6 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

36.4 38.7 40.6 42.4 44.1 49.0 53.4 58.0 62.7 67.5 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the sum of the fly ash expanded use 15% scenario, the current use GGBFS scenario and the current use silica fume scenario. The expanded GH

these totals because these metrics were not evaluated for either GGBFS or silica fume. 
D-36

Total 30% Scenarioa 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 15.3 16.2 16.8 17.4 18.0 22.7 27.5 32.4 37.4 42.6 Energy Savings billion ($2006) 0.4 0.4 0.5 0.5 0.5 0.6 0.8 0.9 1.0 1.2 Energy Savings billion ($discounted @ 7%) 0.4 0.4 0.5 0.4 0.4 0.5 0.6 0.6 0.7 0.7 Water Savings billion liters 1.0 1.1 1.1 1.2 1.2 1.6 2.0 2.3 2.7 3.2 Water Savings million ($2006) 0.6 0.7 0.7 0.7 0.7 1.0 1.2 1.5 1.7 2.0 Water Savings million ($discounted @ 7%) 0.6 0.7 0.7 0.7 0.6 0.8 0.9 1.0 1.1 1.2 Avoided CO2 million metric tons 2.3 2.4 2.5 2.6 2.7 3.4 4.1 4.8 5.6 6.3 Avoided NO2 (air) thousand metric tons 7.2 7.6 7.9 8.1 8.4 10.6 12.7 14.9 17.2 19.6 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 Avoided SOx (air) thousand metric tons 5.9 6.2 6.4 6.7 6.9 8.6 10.2 12.0 13.8 15.7 Avoided CO (air) thousand metric tons 2.1 2.2 2.3 2.4 2.5 3.2 3.8 4.5 5.2 5.9 Avoided Hg (air) metric tons 0.1 0.1 0.1 0.2 0.2 0.2 0.2 0.3 0.3 0.4 Avoided Pb (air) metric tons 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.2 0.3 0.3 Avoided biochemical oxygen demand (water) 

metric tons 

7.9 8.4 8.8 9.2 9.6 12.9 16.3 19.8 23.4 27.1 

Avoided chemical oxygen demand (water) 

metric tons 

66.5 71.0 74.4 77.8 80.9 109.3 137.6 167.0 197.4 228.7 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

36.4 38.7 40.6 42.4 44.1 59.3 74.5 90.3 106.6 123.4 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the sum of the fly ash expanded use 30% scenario, the current use GGBFS scenario and the current use silica fume scenario. The expanded GH

these totals because these metrics were not evaluated for either GGBFS or silica fume. 
D-37

Total 15% Scenario Incremental to Total C2P2 Scenarioa 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 0.0 0.0 0.0 0.0 0.0 1.0 1.9 2.9 4.0 5.2 Energy Savings billion ($2006) 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 Energy Savings billion ($discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 Water Savings billion liters 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.2 0.3 0.4 Water Savings million ($2006) 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.2 0.3 Water Savings million ($discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.2 Avoided CO2 million metric tons 0.0 0.0 0.0 0.0 0.0 0.2 0.3 0.4 0.6 0.8 Avoided NO2 (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 0.5 0.9 1.3 1.8 2.4 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 0.4 0.7 1.0 1.4 1.9 Avoided CO (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 0.1 0.3 0.4 0.6 0.7 Avoided Hg (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided Pb (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided biochemical oxygen demand (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 0.7 1.4 2.1 2.9 3.8 

Avoided chemical oxygen demand (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 6.2 11.8 17.7 24.7 31.9 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 3.3 6.4 9.5 13.2 17.1 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the 15% Scenario Total minus Total C2P2. The expanded GHG metrics are not included in these totals because these metrics were not evaluate

fume. 
D-38

Total 30% Scenario Incremental to Total C2P2 Scenarioa 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 0.0 0.0 0.0 0.0 0.0 4.2 8.4 12.8 17.4 22.3 Energy Savings billion ($2006) 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.4 0.5 0.6 Energy Savings billion ($discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.2 0.3 0.4 Water Savings billion liters 0.0 0.0 0.0 0.0 0.0 0.3 0.7 1.0 1.4 1.8 Water Savings million ($2006) 0.0 0.0 0.0 0.0 0.0 0.2 0.4 0.6 0.9 1.1 Water Savings million ($discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.2 0.3 0.4 0.6 0.7 Avoided CO2 million metric tons 0.0 0.0 0.0 0.0 0.0 0.6 1.3 1.9 2.6 3.3 Avoided NO2 (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 1.9 3.8 5.8 7.9 10.1 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 Avoided SOx (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 1.5 3.0 4.5 6.2 7.9 Avoided CO (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 0.6 1.2 1.8 2.4 3.1 Avoided Hg (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.2 0.2 Avoided Pb (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 Avoided biochemical oxygen demand (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 3.0 6.0 9.2 12.6 16.1 

Avoided chemical oxygen demand (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 25.4 51.1 77.9 106.4 136.0 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 13.6 27.5 41.8 57.1 73.0 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the 30% Scenario Total minus Total C2P2. The expanded GHG metrics are not included in these totals because these metrics were not evaluate

fume. 
D-39

Total 30% Scenario Incremental to Total 15% Scenarioa 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Energy Savings billion megajoules 0.0 0.0 0.0 0.0 0.0 3.2 6.4 9.9 13.4 17.1 Energy Savings billion ($2006) 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.3 0.4 0.5 Energy Savings billion ($discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.2 0.2 0.3 Water Savings billion liters 0.0 0.0 0.0 0.0 0.0 0.3 0.5 0.8 1.1 1.4 Water Savings million ($2006) 0.0 0.0 0.0 0.0 0.0 0.2 0.3 0.5 0.7 0.8 Water Savings million ($discounted @ 7%) 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.3 0.4 0.5 Avoided CO2 million metric tons 0.0 0.0 0.0 0.0 0.0 0.5 1.0 1.5 2.0 2.5 Avoided NO2 (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 1.4 2.9 4.5 6.1 7.7 Avoided PM10 (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided SOx (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 1.1 2.3 3.5 4.8 6.1 Avoided CO (air) thousand metric tons 0.0 0.0 0.0 0.0 0.0 0.4 0.9 1.4 1.9 2.4 Avoided Hg (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.2 Avoided Pb (air) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 Avoided biochemical oxygen demand (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 2.3 4.6 7.1 9.7 12.3 

Avoided chemical oxygen demand (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 19.2 39.3 60.2 81.8 104.1 

Avoided copper (water) metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided suspended matter (water) 

metric tons 

0.0 0.0 0.0 0.0 0.0 10.3 21.1 32.3 43.9 55.9 

Avoided soil emissions metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Avoided end of life waste metric tons 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 a. Calculated as the Total 30% Scenario minus the Total 15% Scenario. The expanded GHG metrics are not included in these totals because these metrics were 

GGBFS or silica fume. 
D-40

General Limitations of Analysis 

Beyond the specific assumptions and modeling constraints cited throughout this appendix, there 

are several broad limitations with respect to the analysis, including: 

• Uncertainty concerning applicable RMC substitution levels. Two sources of 

uncertainty exist. First, it has been noted that there is difficulty in identifying both the 

quantity of concrete procured for federally-funded projects, and the quantities of each 

RMC used in these projects. Second, it is difficult to isolate, for quantification, the effect 

of current procurement regulations on RMC substitution. Thus, the results may over- or 

understate actual benefits depending upon the accuracy of the estimated quantities. In 

addition, the results likely overstate benefits attributable to current procurement 

regulations.

• Static nature of unit impact values. The BEES model presents an LCI based upon 

current manufacturing processes and related energy intensity and emissions levels, which 

may change over time. Thus, the accuracy of the impact values derived from these LCIs 

likely declines the further out they are applied to the 10-year projection of RMC 

substitution levels. 

• Social welfare impacts of RMC substitution. The benefit results capture absolute 

differences in resource use and emissions between two concrete product types. These 

absolute differences likely overstate marginal welfare impacts resulting from RMC 

substitution. For example, a portion of energy savings from RMC substitution may be 

consumed elsewhere within the economy. Accordingly, the results are best viewed as a 

relative measure of benefits across RMCs and concrete product types.
D-41

WARM Analysis of Coal fly ash Substitution 

EPA’s Waste Reduction Model (WARM) is another lifecycle tool capable of evaluating the 

greenhouse gas and energy impacts of coal fly ash substitution in concrete. For comparison with 

BEES results for coal fly ash substitution, we calculate the avoided greenhouse gas and energy 

impacts per metric ton coal fly ash substitution using WARM. As with BEES, we do not run the 

WARM model for coal fly ash but instead use underlying energy and greenhouse gas emissions 

factors for the coal fly ash recycling scenario.15 Table D-13 presents a comparison of the energy 

and greenhouse gas unit impacts derived from WARM and BEES. 

Table D-13: Comparison of WARM and BEES Unit Impacts 

Impacts per One MT Coal Fly Ash as Cement 

Replacement 

 

 

WARMa

 BEES 

Avoided energy (million Btu) 5.26 4.45 

Avoided CO2 (MT) NAb 0.70 

Avoided CH4 (MT) NAb 0.00 

Metric tons carbon dioxide equivalent (MTCO2E) 0.96 0.71c

Metric tons carbon equivalent (MTCE) 0.26 0.20c

Notes:

a. WARM impacts on a short ton coal fly ash basis were converted to a metric ton basis by multiplying each 

impact by 1.10231131 short tons/MT. 

b. WARM does not report these metrics. 

c. BEES impacts for avoided CO2 and CH4 were converted to MTCO2E and MTCE using the U.S. Climate 

Technology Cooperation Gateway’s Greenhouse Gas Equivalencies Calculator, accessed at: 

http://www.usctcgateway.net/tool/.

As shown, the unit impacts calculated from BEES and WARM are very similar. 

 

15 The coal fly ash recycling scenario energy and emissions factors in WARM are calculated as the difference in 

energy use and greenhouse gas emissions between virgin production of one ton of cement and production of one ton 

of coal fly ash. The same general calculation is used to derive the coal fly ash unit impacts in BEES. We do not run 

WARM as a comparison between coal fly ash landfill disposal and coal fly ash recycling because such an analysis 

would be inconsistent with the impacts being measured in BEES. 
D-42

Beneficial Use of Blast Furnace Slag Aggregate (BFSA) 

As described in section two of this report, blast furnace slag aggregate can replace virgin 

aggregate in concrete mixes or in roadbase. When used in this capacity, blast furnace slag 

aggregate reduces the need to quarry, crush, sort, and transport virgin aggregate. Extraction and 

processing of virgin crushed rock is a resource and energy intensive process. To the extent that 

virgin aggregate production can be offset by use of blast furnace slag aggregate, these energy and 

resource requirements are reduced. 

The life cycle analysis presented in section three of this report evaluates the substitution of 

ground, granulated blast furnace slag (GGBFS) for finished portland cement, but does not 

evaluate substitution of blast furnace slag aggregate for virgin aggregate in concrete or roadbase. 

Using a modified-LCA approach, we illustrate the magnitude of environmental and energy 

savings that can be realized through beneficial use of blast furnace slag aggregate. We modeled 

the environmental and energy savings from beneficial use of blast furnace slag aggregate as the 

avoided lifecycle impacts of extracting, processing and transporting an equivalent quantity of 

virgin aggregate. This approach provides a reasonable approximation of the magnitude of 

benefits since virgin aggregate extraction is the only significant process change when BFSA is 

used in place of virgin aggregate in concrete mixes, or as base material. 

We rely on life cycle inventory data contained in the Pavement Life Cycle Assessment Tool for 

Environmental and Economic Effects (PaLATE) to quantify the environmental savings from one 

ton of avoided virgin aggregate extraction.16 We then multiply the unit environmental impacts of 

avoided virgin aggregate extraction by the total 2004 baseline17 quantity of BFSA under two 

alternative scenarios. 

Based on available data and communications with experts in the field, we estimated that 

approximately 8.1 million metric tons of BFSA were sold in the U.S. in our baseline year of 

2004 (see Chapter 2). Available data at the time of our analysis indicated that virtually 100% of 

BFSA generated annually in the U.S. was beneficially used. However, recent information 

received from the National Slag Association (Kiggins, 2007) indicates that as much as 1.4 

million metric tons of BFSA may go unused annually, resulting in only 6.7 million metric tons 

being beneficially used (based on 2004 data). To determine the maximum level of potential 

BFSA beneficial use impacts we first estimated benefits based on the full quantity (8.1 million 

metric tons) of BFSA reported sales for 200418. These results are presented under Scenario 1 in 

Table D-14. Assuming that approximately 1.4 million metric tons of BFSA goes unused 

annually, this would mean that society is currently enjoying the environmental benefits 

 

16 PaLATE is an Excel-based tool developed by the Consortium for Green Design and Manufacturing at U.C. 

Berkeley for life cycle analysis of environmental and economic performance of pavements and roads.. The model 

was developed for pavement designers and engineers, transportation agency decision-makers, civil engineers, and 

researchers. PaLATE can evaluate the relative impacts of using different virgin and secondary materials in the 

construction and maintenance of roads. For additional information on PaLATE, or to obtain a copy of the model, see 

http://www.ce.berkeley.edu/~horvath/palate.html. 17 We did not develop beneficial use trends and projected benefit estimates through the year 2015, as we did for 

GGBFS, fly ash and silica fume due to our inability to reliably link projected BFSA use as an aggregate to future 

cement use (see Section 3.3.1 of the Report). 

18 This quantity includes an estimated 1.8 percent of the total that was actually used as clinker raw material. 
D-43

associated with the use of only 6.7 million metric tons. Scenario 2 in Table D-14 presents the 

incremental benefits associated with using the additional 1.4 million metric tons of potentially 

available BFSA. Consistent with our analysis in Chapter 3, and earlier in this Appendix, we 

estimate that BFSA use in Federal projects would represent approximately 20% of the total 

estimated benefits. 

TABLE D-14: ESTIMATED ENVIRONMENTAL BENEFITS FROM USE OF BLAST FURNACE SLAG AGGREGATE AS A 

SUBSTITUTE FOR VIRGIN AGGREGATE 

METRIC UNITS 

UNIT IMPACT 

 

(per metric ton virgin

aggregate) 

SCENARIO 1* 

Impacts for 8.1 

million metric tons 

BFSA as substitute for

virgin aggregate 

SCENARIO 2** 

Impacts for use of an

additional 1.4 million

metric tons BFSA as 

substitute for virgin 

aggregate

CO2 grams 12,039.83 97,522,590,241 16,855,756,338

CO grams 15.85 128,402,187 22,192,971

NO2 grams 24.26 196,507,899 33,964,328

SO2 grams 11.82 95,734,247 16,542,878

PM10 grams 172.52 1,397,444,725 241,478,448

MJ 170.00 1,377,028,355 237,950,500 Energy 

Btu 161,129 1,305,170,991,400 225,533,547,560

Electricity (kWh) kWh 11.20 90,688,961 15,671,052

Hg grams 0.00 4 0.7

Pb grams 0.00 28,178 4,869

RCRA Hazardous Waste 

Generated grams 197.57 1,600,281,470 276,528,638

Water Consumption thousand gallons 23.68 191,797,367 33,142,585

* Scenario 1 assumes 100% BFSA usage (8.1 million metric tons) during our baseline year of 2004 

(see Chapter 2). 

** Scenario 2 presents the estimated incremental benefits of 1.4 million metric tons only, reflecting the NSA 

estimate that approximately 1.4 million metric tons of BFSA goes unused each year. Under this scenario, the 

baseline 2004 usage would be 6.7 million metric tons, leaving the additional 1.4 million metric tons available 

for beneficial use. 

MJ = megajoule 

Although not quantified in our analysis, the National Slag Association has indicated that the 

beneficial use of BFSA provides a further economic benefit by helping the U.S. Steel Industry 

remain competitive in the global steel market. (Kiggins, 2007). 

 
APPENDIX E: 

SUMMARY OF INDUSTRY REPRESENTATIVE COMMENTS ON 

MECHANISMS TO INCREASE RMC SUBSTITUTION
E-1 

Table E-1 below summarizes suggestions from six key industry stakeholders on potential 

mechanisms to address barriers and increase use of coal fly ash, foundry sand, and other RMCs. 

Table E-1: Summary of Suggestions from Industry on Potential Mechanisms 

Industry 

Member Suggestions 

National 

Ready Mixed 

Concrete 

Association 

(NRMCA) 

• Mandates for use of RMCs, including requiring specific minimum 

quantities, should be avoided. All mechanisms for increased use should 

ensure that the resulting concrete meets quality standards that will not 

compromise its service life. 

• Government should implement education efforts aimed at harmonizing 

policy by ensuring that state transportation agencies (on Federally 

supported projects) do not restrict the beneficial use unless there are 

technically valid reasons locally. 

• Government should provide financial (economic) and other incentives to 

the industry to increase the beneficial use of RMCs.

Headwaters, 

Inc. 

The U.S. government should: 

• Continue on-going activities aimed at removing informational barriers 

including, but not be limited to: 

o Education through various media regarding the safety and 

performance- enhancing capabilities of RMCs. 

o Elimination of use restrictions not supported by technical 

considerations. 

o Support for performance-based specifications for concrete and 

RMCs used in concrete. 

• Substantially increase efforts to overcome logistical barriers. This may 

include creation of infrastructure incentives. Financial (economic) 

incentives, such as tax credits or accelerated depreciation of capital 

expenditures could assist companies that invest in the construction of 

infrastructure to store, process, transport or improve the quality of RMCs. 

American 

Coal Ash 

Association 

(ACAA) 

In Federal projects, current requirements that contractors use recovered mineral 

resources do not have adequate "teeth." A number of caveats make it easy for a 

contractor to opt-out of beneficial use material options. If the procurement 

process directed contractors to use RMC materials whenever the design 

specification allows it, RMCs would be more likely be used. Furthermore, other 

CCPs including FGD gypsum, boiler slag, bottom ash, and cenospheres could 

also be included. 
E-2 

Industry 

Member Suggestions 

Holcim, Ltd. General Comments: 

• Create greater transparency about the use of RMCs 

• Create a centralized reporting system that tallies the amount and type of 

recycled cement/concrete products used in Federally funded projects. 

State Agencies:

• Where Federal funds are involved, include requirements in state and local 

contracts requiring contractors to use cement/concrete containing RMCs 

(unless cost, availability or technical specifications prohibit such use). 

Federal Agencies:

• Review and update Federal procurement rules to require that contractors 

bidding on Federal construction projects use cement/concrete containing 

RMCs (unless cost, availability or technical specifications prohibit such 

use). 

• On an annual basis, each Federal agency should provide EPA with copies 

of their procurement plans and rules, grant regulations, and information 

submitted to them by Federal contractors and state and local governments 

as to the amount and type of recycled cement/concrete being used, or 

reasons it is not being used, in Federally funded projects. 

• Require states to adopt specifications including RMCs in order to in order 

to receive Federal funds. 

Silica Fume 

Association 

(SFA) 

• Since cement production is a pound for pound contributor of CO2

emissions, SFA suggests a strong program that requires elimination of 

cement-only concretes or requiring the use of SCMs in Federal projects 

using concrete. Give weighted financial credit (economic incentive) for 

using CPG materials to produce concrete on Federal projects. 

• Any program of this sort must include a technology transfer element, as 

most concrete producers in the US are not well versed in cement and 

cement replacement technology. To help provide this education or 

technology transfer, we recommend the Federal agencies using concrete 

join with the concrete industry organizations, and together provide this 

education to the industry. 
E-3 

Industry 

Member Suggestions 

Slag Cement 

Association 

(SCA) 

• The CPGs can be much more effective if they had more explicit 

requirements regarding replacement rates, use of ternary mixtures, and 

had actual “teeth” so that non-compliance would have negative project 

impacts. Create minimum upper limits on slag cement (and fly ash) 

percentages in concrete based on application. 

• Require that specifications allow the use of ternary mixtures. 

• Establish a review protocol to allow a technical evaluation by an outside 

party if a project stakeholder challenges compliance of a specification to 

the CPGs. This “outside party” could be an appropriate functional agency 

for the project (e.g. FHWA for transportation, DOD for military, GSA for 

general facilities), or the EPA or a combination thereof. 

• Add “teeth” to the CPGs so that if the review protocol recommends 

specification changes, 1) reissue specifications if there is a reasonable 

amount of time prior to the project bid date (if time frame is too short 

before the bid date, then the bid date would need to be delayed); 2) if the 

project has already been bid, then re-bidding would be required; 3) if the 

project specifications are not changed then Federal funding should be 

withheld. 

• Provide incentives that encourage more domestic granulation capacity, 

such as tax incentives for new granulator installation (such as accelerated 

depreciation or tax credits), and provide funding for training programs on 

the proper use of GGBF slag (and other RMCs). 

• Provide funding for the nascent Green Highways Partnership, which is 

attempting to incorporate sustainable design concepts into highway 

design.