Texas Department of Transportation 

DEWITT C GREER STATE HIGHWAY BLDG.• 125 E. 11TH STREET· AUSTIN, TEXAS 78701-2483 • (512) 463-8585 

September 17, 2009 

Ms. Lisa Jackson, EPA Administrator 

USEPA Headquarters 

Ariel Rios Building, Room 3000 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

Dear Ms. Jackson: 

It has come to my attention that the U.S. Senate Committee on Environment and Public 

Works is conducting hearings on the possible reclassification of fly ash from a solid 

waste to a hazardous solid waste. The Texas Department of Transportation (TxDOT) is 

concerned that the reclassification of coal fly ash as hazardous solid waste would 

drastically, if not totally eliminate, fly ash from the Texas market. Although we 

understand the hazardous classification is not intended to impact fly ash for beneficial 

use, we believe that this classification will have a severely negative impact on the 

supply of fly ash for beneficial use. 

TxDOT concrete operations annually consume approximately 300,000 tons of fly ash 

that would have otherwise been disposed of in landfills. TxDOT relies heavily on fly ash 

as a method for mitigating alkali-silica reaction and external sulfate attack, controlling 

heat generation in mass concrete structures and prestressed concrete products, and 

reducing the potential of corrosion of reinforcing steel in marine environments. It is also 

utilized in areas of the state that use deicing chemicals. If the supply of fly ash is 

impacted by reclassification, TxDOT will be hard-pressed to build transportation 

structures that will last their intended service life. The projected annual savings from 

initial cost alone is estimated to be $16,000,000. Savings due to the benefits of more 

durable concrete far outweighs the savings from the initial cost. 

There are limited supplies of alternative materials that can be used in lieu of fly ash, 

most of which are not readily available in Texas. Compared to fly ash, these alternative 

materials are two to three times the cost of cement, whereas fly ash is only one-third the 

cost of cement. TxDOT cannot afford to rely on these alternative materials as a means 

to specify economically durable concrete. 

THE TEXAS PLIl,N
 

REDUCE CONGESTION· ENHANCE SAFETY· EXPAND ECONOMIC OPPORTUNITY· IMPROVE AIR QUALITY
 

INCREASE THE VALUE OF OUR TRANSPORTATION ASSETS
 

An Equal Opportumty Employer 
Ms. Lisa Jackson -2-	 September 17, 2009 

Reclassifying fly ash as a hazardous solid waste could potentially eliminate a vital 

resource that TxDOT depends on to build long-lasting durable concrete structures. We 

strongly urge you to consider the consequences that TxDOT as well as other DOT's and 

users of concrete products will face if fly ash is no longer supplied for beneficial use. 

For more detailed information on TxDOT's utilization of fly ash, please contact 

Ms. Lisa Lukefahr at (512) 506-5858. 

a:e~~ h I 

Amadeo Saenz, Jr., P.E. ) 

Executive Director 

cc:	 Dianna F. Noble, P.E., Director, Environmental Affairs Division, TxDOT 

Thomas Bohuslav, P.E., Director, Construction Division, TxDOT 

Lisa Lukefahr, P.E., Construction Division, TxDOT 

Toribio Garza, P.E., Director, Maintenance Division, TxDOT 

Texas Congressional Delegation