## Waste and Materials

- Flow Benchmark Sector Report:

Beneficial Use of Secondary Materials

-

Coal Combustion Products

Economics and Risk Analysis Staff
Office of Resource Conservation and Recovery Office of Solid Waste and Emergency Response
U.S. E nvironmental Protection Agency Washington, D.C. 20460



## April 2011

Revised July 19, 2011

### ACKNOWLEDGMENTS

Industrial Economics, Incorporated (IEc), under contract with EnDyna, Inc., is responsible for the overall organization and developme nt of this report. This report was developed with the assistance of Dr. H. Scott Mathews of the Carnegie Mellon Green Design Institute, Dr. Jim Boyd of Resources for the Future, Dave Goss of the American Coal Ash Association (ACAA), and with input and dat a from various EPA Office of Resource Conservation and Recovery and Office of Policy Economics and Innovation representatives. Lyn D. Luben of the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery , provided guidance and re view.i



### TABLE OF CONTENTS

EXECUTIVE SUMMARY ES

- 1



### CHAPTER 1: INTRODUC TION 1

- 1 

### Overview of the Report 1

- 1 

### Organization of Report 1

- 2



### CHAPTER 2: BASELINE CHARACTERIZATION OF CCP GENERATION AND

BENEFICIAL USE 2

- 1 

### Current Quantities of CCPs Generated and Managed 2

- 3 

### Beneficial Use Options 2

- 5



### CHAPTER 3: MARKET S TRUCTURE OF BENEFICI AL USE FOR CCP s 3

- 1



### Coal

- Fired Utility Practices: CCP Supply 3

- 1



### Intermediaries 3

- 3



### End

- Users and Purchasers: CCP Demand 3

- 3 

### Market Dynamics of Specific Use Applications 3

- 5



### Concrete 3

- 7 

### Gypsum Wallboard 3

- 8



### CHAPTER 4: IMPACTS ASSOCIATED WITH BENE FICIAL USE OF CCP s 4

- 1 

### Life Cycle Inventory Analysis and EPA Program Outcomes 4

- 1 

### Life Cycle Assessment and Economic Benefit Assessment 4

- 2



### Assessme nt of Beneficial Impacts of CCP Use 4

- 3 

### Methodology for Evaluating Unit Impacts of Beneficial Use 4

- 5 

### BEES Analysis of Use of Fly Ash in Concrete 4

- 6 

### SimaPro Analysis of FGD Gypsum in Wallboard 4

- 7 

### Allocation of Life Cycle Impacts to CCPs 4

- 7



### Resul ts 4

- 9 

### Limitations and Assumptions 4

- 11



### CHAPTER 5: ESTIMATI NG PROGRAM LEVEL IMP ACTS 5

- 1 

### Development of Defensible Beneficial Use Scenarios 5

- 1 

### Current Market Dynamics: Factors Affecting Beneficial Use 5

- 1 

### Structural Changes to the Market 5

- 3



### Att ribution of Impacts to EPA Programs 5

- 3 

### Beneficial Impacts Associated with Current Use of CCPS 5

- 5ii



### Economic Distribution of CCP Beneficial Use Impacts 5

- 8 

### Conclusions and Next Steps 5

- 8



### REFERENCES R

- 1



### APPENDIX A: KEY BENE FICIAL USE APPLICATI ONS FO R CCPS

APPENDIX B: USE OF L IFE CYCLE ASSESSMENT IN EVALUATION OF ECO NOMIC

BENEFITS

APPENDIX C: ANALYSIS OF BENEFITS USING ALTERNATE LIFE CYCLE MODELS

APPENDIX D: DETAILS OF LIFE CYCLE INVENTORY ANALYSIS METHODOLOGI ES

APPENDIX E: POTENTIA L IMPACTS OF ALL OCATION OF LCI RESUL TS TO CCPSiii



### Note on Updates to Quantitative Estimates in Document:



## This document updates a 2008 version of this report. Quantitative and monetized benefits estimates have changed significantly from the prior analysis to reflect new life cycle inventory data, updated model versions (BEES 4.0), updated estimates of current beneficial use, and refined approaches to monetizing impacts. Specifically, updates reflect the following:

 Revised energy mix: The energy mix used for the SimaPro analysis for FGD Gypsum in wallboard reflects data that are updated from Franklin US 98 “Electricity avg. kWh USA” data set to the Ecoinvent 2.0 “Electricity, medium voltage, at grid/US” data set. This substitution resulted in significant changes in
envir onmental impacts across all aspects of the analysis.

 Updated water use data: The change in energy mix from the Franklin US 98 data set to the Ecoinvent 2.0 data set in the SimaPro analysis for FGD Gypsum resulted in a subsequent increase in water usage bec ause of the inclusion of water used in turbines. We do not attempt to monetize the total quantity estimates of
water used.

 Primary Energy: An error in the total primary energy calculation for FGD Gypsum was corrected, resulting in a significant decrease in total primary energy.

 Current use: The extrapolated current use quantities for fly ash in concrete and FGD gypsum in wallboard were updated from the 2005 estimates using the American Coal Ash Association’s Coal Combustion Products Survey from 2008.

 Pr icing: The monetized energy impacts for fly ash were calculated using a price figure from the average price of purchased energy to the cement manufacturing industry in 2006 and converted to 2009 dollars using NASA’s GDP Deflator
Inflation Calculator. The m onetized energy impacts for FGD Gypsum were calculated using a price figure derived from the average cost of diesel fuel in 2009. The monetized water impacts were calculated using the NUS Consulting Group’s average water cost estimates for 2008 converted t o 2009 dollars using the
NASA calculator.ES

- 1



# EXECUTIVE SUMMARY

INTRODUCTION The U.S. Environmental Protection Agency’s Office of Resource Conservation and Recovery (EPA
ORCR ) is currently developing methods to evaluate the environmental, human health, and e conomic outcomes of specific EPA programs. As an initial step, ORCR is examining the extent to which the costs and benefits of source reduction, reuse, and recycling may be quantified for a range of materials targeted by the Sustainable Materials Manageme nt (SMM) program ( formerly known as the Resource Conservation Challenge ( RCC) )

. Coal combustion products (CCPs) are among the materials targeted by EPA’s SMM program . The SMM

program is designed to facilitate changes in the economics and practice of wa ste generation, handling, and disposal (e.g., by promoting market opportunities for beneficial use). Two potential milestones for increasing CCP beneficial use are as follows :

 Increase overall beneficial use of CCPs to at least half of total generation; an d

 Increase the use of coal fly ash in concrete by significant percentage over 10 years (e.g., increase of over half from 2001 beneficial reuse).

C oal combustion residues (CCRs) are formed during coal

- burning processes in power plants and

industrial boiler s. Coal combustion produces various forms of CC R s, which are categorized by the process in which they are generated. CCPs are the subset of CCRs that are targeted for beneficial reuse; this document uses the term broadly to describe all categories of CCRs in which some portion have been beneficially used. Common CCPs include: fly ash, bottom ash, f lue g as d esulphurization (FGD) material, boiler slag, f

luidized b ed c ombustion (FBC) ash, and cenospheres. CCPs may be beneficially used as a component of buildi ng materials or as a replacement for other virgin materials such as sand, gravel, or gypsum. Size, shape, and chemical composition determine the suitability of these materials for beneficial use. Higher value applications, such as use in cement or concre te products, require moderately stringent specifications (in terms of size, shape and chemical composition), whereas lower value uses, such as structural or mining fills, can accept more variable materials.

This report serves two purposes: (1) To provide a n initial assessment of the market dynamics that affect the generation, disposal, recovery, and beneficial use of CCPs; and (2) to provide a preliminary life cycle inventory analysis of the beneficial impacts of CCP use, including an initial estimate of th e baseline beneficial use impacts with current (200 8 ) CCP levels and an estimate of the beneficial impacts associated with increasing use of fly ash in concrete to 18.6 million tons (an increase of roughly 50 percent over the 2001 estimated use of 12.4 mil lion tons).



## CCP GENERATION AND M ARKET DYNAMICS The American Coal Ash Association (ACAA), a trade association whose purpose is to advance the beneficial use of CCPs, reports that the electric power industry generate d approximately 136 million short
tons of CCPs in 2008 . Of these, the industry disposed of approximately 75 million short tons to landfills, while beneficially using approximately 61 million short tons in products. 1 

### Exhibit ES

- 1 summarizes

1 The ACAA survey is administered to both ACAA members and non

- members. ACAA members account for approximately 40 percent of private
power generation. Not all survey recipients complete the survey each year. ACAA extrapolates survey respondent data to the entire coal

- fired
electricity generation industry. ACAA includes mining applications as a bene ficial use, but EPA considers large fill operations to be disposal.
Therefore, total beneficial use figures and percentages presented in this report may overstate what EPA considers to be benef icial use. EPA, 2010,ES

- 2



### results of the most recent ( 2008 ) ACAA survey of generators of CCPs, which indicates that the most common beneficial use applications for CCPs are as a replacement for virgin materials in concrete and

cement

- making, structural fill, and gypsum wallboard.

The CCP beneficial use market is c omposed of three primary segments. These are:

 Generators: An estimated 495 coal

- fired electric utilit y plants currently operate in the United

States. 2 

### Since the coal power industry consumes approximately 92 percent of all U.S. coal, it is responsible fo r producing the vast majority of CCPs in the country. Other industries that use coal as a fuel source in commercial or industrial boilers (e.g., mineral and grain processors) also produce small quantities of CCPs. Several factors influence a generator’s decision to either dispose or seek beneficial use options for spent CCPs. Key considerations include the costs of landfill disposal, transport, processing, storage, and marketing.

 Intermediaries: Some coal

- fired utilities market CCPs for beneficial use through a third

- party instead of selling directly to users. In these cases, a utility perceives an efficiency in outsourcing the marketing of its CCPs. Marketers typically accept all of a generator’s CCPs as a service to the company, sell the marketable p ortion, and dispose of the portion that is not salable. The marketer typically bears the cost of hauling CCPs from the utility and the liability associated with moving or storing the materials.

 End

- Users: Several economic factors determine an end

- user’ s decision to use CCPs in its product. These factors include: the price of CCPs relative to the price of virgin materials for specific uses; the technical fit between CCPs and the use application; access to sufficient quantities of CCPs; and federal and st ate policies associated with CCP use.

Additionally, EPA is currently undertaking a rulemaking that would implement management criteria for coal combustion residuals (CCR) generated by electric utilities and independent power producers. The purpose of the rule is to address risks associated with the disposal of these wastes in landfills and surface impoundments. As part of this rulemaking, EPA strongly supports the beneficial use of fly ash in the manufacture of concrete, FGD Gypsum in the manufacture of w allboard, and fly ash in the manufacture of bricks (cinder blocks), so long as this beneficial use is conducted in an environmentally sound manner

. These beneficial uses are known to result in significant environmental benefits

, both locally and globall y.

“ Hazardous and Solid Waste Management Sy stem; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals f rom Electric
Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010) , p. 35148.

2 EPA, 2010, “Regulatory Impact Analysis for EPA’s Proposed RCRA Regulation Of Coal Comb ustion Residues (CCR) Generated by the Electric Utility
Industry,” EPA

- HQ

- RCRA

- 2009

- 0640

- 0003.ES

- 3

EXHIBIT ES

- 1: ACAA SURVEY OF KEY B ENEFICIAL USE APPLIC ATIONS FOR CCPS IN 2008 (MILLION

SHORT TONS)

APPLICATION

(INDUSTRY) COAL

FLY ASH BOTTOM

ASH FGD

GYPSUM FGD MATERIAL

WET SCRUBBERS FGD MATERIAL

DRY SCRUBBERS FGD

OTHER BOILER

SLAG FBC

ASH TOTAL

Conc rete a
(Construction) 12.59 0.72 0.68 0 0.02 0 0 0.004 14.02

Structural fill b
(Construction) 8.01 3.00 0 0 0.13 0.11 0.18 0.08 11.50
Mining applications c 0.96 0.06 0 0.69 0.11 0 0.003 8.64 10.47

Wallboard d
(Construction) 0 0 8.53 0 0 0 0 0 8.53

Raw fee d for

cement clinker e
(Construction) 3.17 0.61 0.41 0 0 0 0 0 4.20

Waste stabilization f
(Waste Mgmt) 2.92 0.08 0.74 0 0.001 0.03 0 0 3.78

Road base g 1.03 0.77 0 0 0 0 0 0.01 1.80

Total

- Key Uses 28.69 5.24 10.37 1 0.26 0.14 0.18 8.73 54.30

Total

- Oth er

Uses h 1.45 2.83 0.29 0.00 0.08 0.00 1.51 0.13 6.29

TOTAL

- ALL USES 30.14 8.08 10.65 0.69 0.35 0.14 1.69 8.86 60.59

2008 QUANTITY

GENERATED 72.45 18.43 17.75 12.98 1.40 1.54 2.03 9.49 136.07

CCP UTILIZATION

RATE g 42% 44% 60% 5% 25% 9% 83% 93% 45%

Notes:

a. CCPs are frequently used as a replacement for a portion of p ortland cement in the manufacture of concrete.
b. Structural fill is an engineered material that is used to raise or change the surface contour of an area and to provide groun d support beneath highway roadbeds, pavements and building foundations. It can also be used to form embankments.

c. FBC ash and other CCPs can be used in mine reclamation to refill mines and to help mitigate acid mine drainage. EPA considers large fill operations such as this use to be disposal and not a beneficial use (75 FR 118 p. 35148).
d. FGD gypsum is used as a substitute for virgin gypsum in wallboard manufacturing.

e

. CCPs can be blended with limestone or shale in the cement kiln to make clinker, which is then ground into Portland cement.
f

. T he chemical properties of CCPs make them effective stabilizers of biosolids (i.e., sludge from municipal waste water treatmen t).

g

. Coal ash is used as in ingredient in road base and sub

- base. h. Presents quantities beneficially used in minor applications not included in this exhibit, but listed in Appendix A.
i

. CCP utilization rates reflect all use applications, some of which are omitted from this table but are included in Appendix A. Utilization rates are calculat ed by dividing the total quantity used by the total quantity generated.

Sources : 1. ACAA

, “2008 Coal Combustion Product (CCP ) Production and Use Survey,” accessed Oct. 18, 2010 at
h ttp://acaa.affiniscape.com/associations/8003/files/200 8_ACAA_CCP_Survey_Report_FINAL_100509.pdf

. 2. Western Region Ash Group, “Applications and Competing Materials, Coal Combustion Byproducts,” accessed at http://www.wrashg.org/compmat.htm

.ES

- 4



## ESTIMA TING THE IMPACTS OF THE BENEFICIAL USE O F CCPS To quantify the environmental impacts of increased beneficial use of CCPs in various applications, we use a life cycle inventory analysis approach, as both a first step in an economic analysis, and, where

econ omic analysis is not practical, as a meaningful proxy.

To estimate beneficial impacts of CCP use, we first develop preliminary estimates of the incremental impacts associated with using a specific quantity (e.g., one ton) of CCPs in different applications. These impacts can then be extrapolated in specific scenarios designed to address program

- level outcomes. To fully capture the beneficial impacts of EPA program achievements, it is necessary to model each beneficial use application of all CCPs targeted b y the SMM . However, the time, data, and resources required to perform this task are beyond the scope of this report. For this preliminary analysis, therefore, we have selected two common CCPs, fly ash and FGD gypsum, whose beneficial use applications are well understood, and for which life cycle model ing option s and existing data are available.

We conduct separate analyses to evaluate incremental changes in emissions, energy, and water use associated with beneficially using a specific quantity (e.g., on e ton) of fly ash and FGD gypsum. We use two life cycle modeling applications, Building for Environmental and Economic Sustainability (BEES)

4.0 and SimaPro with EcoInvent v2. 2 data , to provide the inventory data we used . Both models have been peer

- revie wed and evaluate a large suite of environmental metrics. We employ BEES to investigate
the changes in emissions to the environment that result from using one short ton of fly ash as a substitute for finished portland cement in concrete, and SimaPro to eva luate the use of one short ton of FGD gypsum as a substitute for virgin gypsum in wallboard. Both analyses assume that the beneficial use material (fly ash or FGD gypsum) substitutes for virgin material (finished portland cement or virgin gypsum) on a one

- to

- one, mass

- based basis.

While it is not optimal to use two different models in a single analysis, in this case we employed the BEES tool to be consistent with previous analyses of beneficial use of materials in other reports; BEES does not address g ypsum. This analysis is designed to examine the general magnitude of potential environmental impacts, and the use of SimaPro for specific materials not addressed in BEES provide s additional insights into the potential impacts of beneficial use of CCPs . E xhibit ES

- 2 below presents the

results of the BEES and SimaPro analys e s. Negative values indicate a reduction in emissions or use of energy or water associated with using recycled materials in place of virgin materials. P ositive values
suggest a n increase in emissions or impacts

. W e express beneficial use quantities in short tons (consistent with EPA and ACAA), but report impacts in metric units, consistent with BEES and SimaPro results.

The results of the fly ash and FGD gypsum analyses suggest many posi tive environmental impacts from beneficial use. For most metrics, there is a significant difference between the unit impact value for fly ash and FGD gypsum. The difference in unit impact values reflects different avoided processes when fly ash

is used to offset portland cement versus when FGD gypsum is used to offset virgin gypsum. For example, the primary driver of benefits when fly ash is used in concrete is avoided raw materials extraction and avoided portland cement production. 3



### In comparison, the pr imary driver of benefits when FGD gypsum is used in wallboard is avoided virgin gypsum extraction and the processing of virgin gypsum into stucco. Portland cement production generates relatively high greenhouse gas emissions. Thus, the avoided CO 2 

### and meth ane emissions are greater for

3 It is unclear from the documentation provided for BEES what impacts (e.g. virgin materials extraction, plant infrastructure, etc.) are modeled for
portland cem ent production. For this reason, it is not possible to explain the differences in unit impact results between the FGD gypsum and fly
ash analysis.ES

- 5



### fly ash than for FGD gypsum in this analysis. In contrast, gypsum mining requires higher q uantities of

water and the life cycle data in EcoInvent includes water used in turbines for power generation , so water savings are much greater for FGD gypsum in this analysis than for portland cement. In addition, the difference in unit impacts likely reflects minor differences in the system boundaries in each analysis and the data sets utilized by each model.

EXHIBIT ES

- 2: INCREMENTAL B ENEFICIAL IMPACTS OF USING FLY ASH IN POR TLAND CEMENT AND

FGD GYPSUM IN WALLBO ARD

AVOIDED IMPACTS PER 1 TON FLY ASH AS PORTLAND

CEMENT SUBSTITUTE IN CONCRETE f PER 1 TON FGD GYPSUM IN

WALLBOARD f

ENERGY USE

NONRENEWABLE ENERGY (MJ) a 5,361.70 1,319.69

RENEWABLE ENERGY (MJ ) b 0.00 14.56

TOTAL PRIMARY ENERGY (MJ) 5,361.70 1,334.25

TOTAL PRIMARY ENERGY (US$) c 23.59 21.67

WATER USE

TOTAL WATER USE (L) 689.36 88,973.02

TOTAL WATER USE (US$ ) d 0.44 67.39

GREENHOUSE GAS EMISS IONS

CO 2 (G) 995,744.68 78 ,830.56

METHANE (G) 842.55 171.71

AIR EMISSIONS

CO (G) 1,378.72 38.04

NOX (G) 2,680.85 152.43

SOX (G) 2,451.06 192.01

PARTICULATES GREATER THAN PM 10 (G) 0.00 1,209.24

PARTICULATES LESS TH AN OR EQUAL TO PM 10 (G) 7.66 472.58

PARTICULATES UNSPECI FIED (G) 2,374.47 0.00

MERCURY (G) 0.08 0.00

LEAD (G) 0.00 0.03

WATERBORNE WASTES

SUSPENDED MATTER (G) 490.21 12.63

BIOLOGICAL OXYGEN DE MAND (G) 22.98 23.11

CHEMICAL OXYGEN DEMA ND (G) 45.96 24.14

COPPER (G) 0.00 0.00

MERCURY (G) 0.00 0.00

LEAD ( G) 0.00 0.01

SELENIUM (G) 0.00 0.01

NONHAZARDOUS WASTE ( KG) e 0.00 Not reportedES

- 6 AVOIDED IMPACTS PER 1 TON FLY ASH AS PORTLAND

CEMENT SUBSTITUTE IN CONCRETE f PER 1 TON FGD GYPSUM IN

WALLBOARD f

Notes:

a. Nonrenewable energy refers to energy derived from fossil fuels such as coal, natural gas and oil.
b. Renewable energy refers to energy derived from renewable source s, but BEES does not specify what sources these include.

c. We monetize energy impacts for fly ash using a price figure ($0.0044/MJ) derived from the average price of purchased energy to the cement manufacturing sector in 2006 ($4.36/million BTU) , from Tab le 7.2, accessed on Nov. 16, 2010 at http://www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html

. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.go v/inflateGDP.html

. We monetize energy impacts for FGD Gypsum using a price/MJ figure ($0.0179/MJ), derived from the average cost of diesel fuel in 2009 ($2.467/gallon)

, assuming 130,500 BTUs/gallon of diesel fuel. Diesel price is 2009 weekly price of on

- highway diesel accessed on April 22, 2010 at http://tonto.eia.doe.gov/dnav/pet/pet_pri_gnd_dcus_nus_a.htm ; d iesel energy value accessed April 22, 2010 at http://bioenergy.ornl.gov/papers/misc/energy_conv.html

. http://www.npga.org/14a/pages/index.cfm?pageid= 914
d. We monetize water impacts using the average cost of water in 2008 ($2.81/KGal) converted to 2009 dollars ($2.87/KGal). The 2008 cost of water is taken from NUS Consulting Group, accessed on April 22, 2010 at http://www.marketwire.com/press

- release/ Average

- US

- Water

- Costs

- Increase

- by

- 73

- 903477.htm. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html.

e. BEES reports waste as “en d of life waste.” In contrast, the datasets used in SimaPro do not report this endpoint, but this does not indicate that there is no solid waste output

. f. ACAA tracks quantities of CCP use in short tons, while outputs from SimaPro and BEES are given in SI units.



## ESTIMATING PROGRAM L EVEL IMPACTS In order to extrapolate the beneficial impacts presented in Exhibit ES

- 2 to evaluate EPA’s program

- level efforts, two critical steps are necessary.

 Development of defensible beneficial use scenarios that accura tely identify the extent to which different beneficial uses are likely to increase; and

 Implementation of a well

- supported attribution protocol for assigning beneficial use impacts to specific EPA programs.

At this time, the data necessary to develop accu rate beneficial use scenarios and to support a clear attribution of impacts are not sufficient to inform a detailed program analysis. In the absence of such data, we present a preliminary analysis of the total impacts associated with current (baseline) be neficial use patterns. While these impacts do not strictly reflect EPA program achievements, they represent the best available information on the environmental benefits of beneficially using certain CCPs, and reflect the impacts of all EPA, state, and ind ustry efforts to increase CCP use to its 2008 level. The beneficial use impacts of current fly ash and FGD gypsum use are calculated by extrapolating the impacts identified
in Exhibit ES

- 2 to the current quantity of each material beneficially used in each application. For fly ash, we also extrapolate the beneficial impacts associated with increasing fly ash use in concrete to 18.6 million tons (an increase of 50 percent in the ten years since 2001) . Exhibit ES

- 3 presents the key impacts

of the beneficial u se of CCPs extrapolated to current use quantities. Note that the impacts presented in
Exhibit ES

- 3 form an upper bound estimate of the impact of EPA programs related to these materials, but may understate total beneficial impacts because not all materials are considered. Beneficial use of fly ash as a substitute for finished portland cement in concrete and FGD gypsum in wallboard accounts for only

35 percent ( 21.1 million tons) of all beneficially used CCPs in 2008 (or 42 percent if excluding mining appli cations)

.ES

- 7

EXHIBIT ES

- 3: EXTRAPOLATED IMPACTS OF THE BENEFICIAL US E OF CCP s

AVOIDED IMPACTS FLY ASH IN

CONCRETE

EXTRAPOLATED

TO 18.6 MILLION

TONS a FLY ASH IN

CONCRETE

EXTRAPOLATED

TO 2008 USE
(1 2.6 MILLION
TONS) b FGD GYPSUM IN

WALLBAORD

EXTAPOLATED

TO 2008 USE
(8. 5 MILLION
TONS) c PARTIAL SUM OF

2008 USE

BENEFICIAL

IMPACTS d

ENERGY USE

NONRENEWABLE ENERGY (MJ) e 99.7 billion 67.5 billion 11.3 billion 78.8 billion

RENEWABLE ENERGY (MJ ) f 0 0 124.2 million 124.2 million

TOTAL PRIMARY ENERGY (MJ) 99.7 billion 67.5 billion 11.4 billion 78.9 billion

TOTAL PRIMARY ENERGY (US$) g 438.8 million 297.1 million 184.9 million 482 million

WATER USE

TOTAL WATER USE (LIT ERS) 12.8 billion 8.7 billion 759.3 billion 768 billion

TOTAL WATER USE (US$ ) h 8.1 million 5.5 milli on not valued > 5.5 million

GREENHOUSE GAS EMISS IONS

CO 2 ( MT ) 18.5 million 12.5 million 0.7 million 13.2 million

METHANE ( MT ) 15, 700 10,6 0 0 1, 500 12, 1 0 0

METRIC TONS CO 2 EQUIVALENT i 18.8 million 12.8 million 0.7 million 13.5 million

AIR EMISSIONS

CO ( M T ) 25,6 00 17, 400 3 00 17, 700

NO x ( MT ) 49, 900 33, 800 1,30 0 35, 1 0 0

SO x ( MT ) 45, 600 30, 900 1,6 00 32,50 0

PARTICULATES GREATER THAN PM 10 ( MT ) 0 0 10,3 00 10,3 00

PARTICULATES LESS TH AN OR EQUAL TO PM 10 ( MT ) 143 97 4,0 00 4,1 00

PARTICULATES UNSPECI FIED ( MT ) 44, 200 29,900 0 29,900

MERCURY ( K G) 1,4 00 1,000 8 1,000

LEAD ( K G) 0 0 300 300

WATERBORNE WASTES

SUSPENDED MATTER ( K G) 9.1 million 6.2 million 0.1 million 6.3 million

BIOLOGICAL OXYGEN DE MAND ( K G) 0.4 million 0.3 million 0.2 million 0.5 million

CHEMICAL OXYGEN DEMAND ( K G) 0.9 million 0.6 million 0.2 million 0.8 million

COPPER (G) 0 0 17,000 17,000

MERCURY (G) 1 0 500 500

LEAD (G) 0 0 49,000 49,000

SELENIUM (G) 3 0 52,000 52,000

NON

- HAZARDOUS WASTE (KG) j 0 0 0 0ES

- 8 AVOIDED IMPACTS FLY ASH IN

CONCRETE

EXTRAPOLATED

TO 18.6 MILLION

TONS a FLY ASH IN

CONCRETE

EXTRAPOLATED

TO 2008 USE
(1 2.6 MILLION
TONS) b FGD GYPSUM IN

WALLBAORD

EXTAPOLATED

TO 2008 USE
(8. 5 MILLION
TONS) c PARTIAL SUM OF

2008 USE

BENEFICIAL

IMPACTS d

Notes:

a. We extrapolate the incremen tal impacts (i.e., impacts associated with use of 1 ton fly ash) in BEES to estimate impacts of increasing fly ash use in concrete to 18.6 million tons.
b. We extrapolate the incremental impacts (i.e., impacts associated with use of 1 ton fly ash) to esti mate the impacts of current beneficial use of fly ash in concrete (1 2.6 million tons). The current quantity of fly ash that is beneficially used as a substitute for finished portland cement in concrete is reported by ACAA’s 200 8 CCP Survey. We multiply ea ch of the incremental impacts calculated by BEES by 1 2.6 million tons to extrapolate these impacts to reflect current use.

c. We extrapolate the incremental impacts (i.e., impacts associated with use of 1 ton FGD gypsum) to estimate the impacts of cur rent beneficial use of FGD gypsum in wallboard (8. 5 million tons). The current quantity of FGD gypsum that is beneficially used as a substitute for mined gypsum in wallboard is reported by ACAA’s 200 8 CCP Survey. We multiply each of the incremental impacts cal culated by SimaPro by 8. 5 million to extrapolate these impacts to reflect current use.
d. Calculated as the sum of the fly ash and FGD gypsum current use extrapolations.

e. Nonrenewable energy refers to energy derived from fossil fuels such as coal, natura l gas and oil.
f. Renewable energy refers to energy derived from renewable sources, but BEES does not specify what sources these include.

g. We monetize energy impacts for fly ash using a price figure ($0.0044/MJ) derived from the average price of purchase d energy to the cement manufacturing sector in 2006 ($4.36/million BTU), from Table 7.2, accessed on Nov. 16, 2010 at http://www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Def lator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html. We monetize energy impacts for FGD Gypsum using a price/MJ figure ($0.0179/MJ), derived from the average cost of diesel fuel in 2009 ($2.467/gallon), assum ing 130,500 BTUs/gallon of diesel fuel. Diesel price is 2009 weekly price of on

- highway diesel accessed on April 22, 2010 at http://tonto.eia.doe.gov/dnav/pet/pet_pri_gnd_dcus_nus_a.htm; diesel energy value accessed April 22, 201 0 at http://bioenergy.ornl .gov/papers/misc/energy_conv.html.
h. We monetize water impacts using the average cost of water in 2008 ($2.81/KGal) converted to 2009 dollars ($2.87/KGal). The 2008 cost of water is taken from NUS Consulting Group, accessed on April 22, 2010 at http://ww w.marketwire.com/press

release/Average

- US

- Water

- Costs

- Increase

- by

- 73

- 903477.htm. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.htm l.
i. We converted greenhouse gas emissions to tons of CO 2 equivalent using U.S. Climate Technology Cooperation Gateway’s Greenhouse Gas Equivalencies Calculator accessed on Nov. 7, 2010 at http://www.epa.gov/cleanenergy/energy

resources/calculator.html

. This calculation only includes CO 2 and methane. j. BEES reports waste as “end of life waste.” In contrast, the EcoInvent data sets used in SimaPro do not report waste. This does not imply that these systems do not produce solid waste

.



### The results show t hat current beneficial use of fly ash in concrete and FGD gypsum in wallboard results in positive environmental impacts. The most significant impacts include energy savings and water use

reductions , though water use reductions for FGD gypsum include turbi ne use and likely overstate consumption . Energy savings associated with the use of fly ash and FGD gypsum totals approximately

78.9 billion megajoules of energy ( or approximately $ 482 m illion in 2009 producer energy prices). Based on the average monthly consumption of residential electricity customers, this is enough energy to power roughly 2 million homes for an entire year. 4 

### Total a voided water use including turbine use totals approximately 768 billion liters , but we value on ly the 8.7 billion liters u sed in the cement manufacturing process; this is equivalent to approximately $ 5.5 million in 2009 water prices , or the annual water consumption of 4

, 4 00 Americans. 5 

### The extrapolated beneficial impacts also include key impacts such as avoided greenhouse ga s ( 1 3.5 million metric tons of avoi ded CO 2 

### equivalent ), and avoided air emissions ( 35, 100 metric tons of avoided NOx, and 32,50 0 metric tons of SOx)

.

4 Based on the assumption that an average residential customer uses 908 kilowatt

- hours per month. EIA, “Tabl e 5A. Residential Average Monthly
Bill by Census Division and State, 2009” accessed Dec. 3, 2010 at www. eia .doe.gov/cneaf/electricity/esr/ table5_a .xls

.

5 Based on 2000 USGS per capita water use estimate of 1,430 gallons per day. Lumia et al., United Stat es Department of the Interior, United
States Geological Survey, Summary of Water Use in the United States, 2000.ES

- 9



### This report also presents a distributional screening analysis using the EIO

- LCA model that indicates signi ficant avoided environmental impacts from reductions in the demand for cement or virgin gypsum that are distributed across several economic sectors. From the perspective of energy and air emissions, cement manufacturing leads to large impacts, and is in g eneral the largest source of emissions across the supply chain. Reducing the amount of cement produced by beneficially reusing products can lead to large supply chain

- wide reductions of emissions. Comparatively, the impact of the substitution of FGD

gyps um for virgin gypsum in wallboard manufacturing is less clear, as the model was not able to adequately represent the wallboard sector. 6



### The preliminary results of this initial analysis suggest that a more detailed evaluation of the beneficial impacts of th e beneficial use of CCPs could assist EPA in the more specific estimation of the
achievements of the SMM program. A more detailed analysis would require:

 The development of realistic and effective beneficial use scenarios that incorporate more detailed

de scriptions of markets, beneficial uses, and policies. Realistic scenarios should reflect key market dynamics and limits such as distance to markets and virgin material prices, and be able to assess the impacts of these dynamics on the growth potential for specific beneficial uses.

 The development of a methodology to attribute beneficial use impacts to specific EPA/ SMM efforts and programs. A phased approach may be employed that initially assumes all impacts result from EPA actions. This assumption coul d then be refined to reflect specific strategies, policies, and other efforts, and link these, where possible, to specific changes in beneficial use practices and markets.

 The expansion of the assessment to include additional CCPs and beneficial use appl ications. This analysis only examines the beneficial impacts of substituting fly ash for finished portland cement in concrete and substituting FGD gypsum for virgin gypsum in wallboard manufacturing. The two processes represent just 35 percent of the to tal beneficial use of CCPs (42 percent if excluding mining applications). Additional high volume applications that may be analyzed include: the use of fly ash as a raw feed in cement clinker; the use of boiler slag as blasting grit; the use of FGD gypsum in agricultural applications; and the use of various CCPs in structural fill and waste stabilization. In addition, the Agency may investigate the beneficial impacts of lower volume applications to identify those that may have potentially high incremental impacts.

6 EIO

- LCA models impacts at the sector level using NAICS codes but an individual NAICS code does not exist for the wallboard manufa cturing se ctor.1

- 1



# CHAPTER 1: INTRODUC TION

The U.S. Environmental Protection Agency’s Office of Resource Conservation and Recovery (EPA

ORCR ) is currently considering the strategic direction of solid and hazardous waste policy. As part of this effort, ORCR is de veloping methods to evaluate the environmental, human health, and economic

outcomes of EPA efforts to support strategic planning and program evaluation. Three important areas of

focus in this transition are:

 Measurement of materials flow and life cycle im pacts related to waste minimization and materials recovery and reuse, including an emphasis on “upstream” resource conservation beneficial impacts;

 Documentation of the impacts of voluntary programs, including the various efforts and materials targeted by EPA’s Sustainable Materials Management (SMM) program (formerly known as the Resource Conservation Challenge (RCC) ) ; 7 

### and

 Development of data and approaches that can support annual performance reporting under the Government Performance and Results Act (GPR A) and OMB’s Performance Assessment Rating Tool (PART) evaluations.

As an initial step in the development of methods to assess the beneficial impacts of program benefits for both voluntary programs and PART, ORCR is examining the extent to which the costs and benefits of source reduction, reuse, and recycling may be quantified for a range of materials targeted by the SMM

. This report examines one of the materials targeted under the SMM : coal combustion products (CCPs). CCPs are produced during coal

- burni ng process at electric utilities and in industrial boilers. EPA is
committed to the safe and protective b eneficial use of CCPs , which refers to the use or substitution of CCPs for other products based on performance criteria.



## OVERVIEW OF REPORT

This re port serves two purposes: (1) To provide an initial assessment of the market dynamics that affect the generation, disposal, recovery, and beneficial use of CCPs; and (2) to provide a preliminary life cycle inventory analysis of beneficial impacts of CCP us e, including an initial estimate of the baseline beneficial use impacts with current ( 2008 ) CCP levels and an estimate of the beneficial impacts associated with increasing us e of fly ash in concrete to over 18 million tons (an increase of roughly 50

percen t in ten years from a 2001 baseline beneficial use of 12.6 million tons ) . Ultimately, in combination with specific information about explicit SMM efforts, this report can be used to support the development and implementation of measures of program efficien cy.

7 The SMM is an EPA initiative that seeks to identify and encourage innovative, flexible, and protective ways to conserve natur al resources and
energy. Specifically, the SMM is a cross

- Office program that assists in developing voluntary programs tha t promote the source reduction, reuse,
and recycling of materials.1

- 2



## Organization of Report The report proceeds in four chapters following this introduction. To provide market context, the second chapter characterizes the current generation and management of CCPs. The third chapter summarizes the

current market structure for CCPs and outlines specific EPA efforts to increase their beneficial use. The fourth chapter uses baseline and available LCA tools to provide a preliminary life cycle inventory analysis of the impacts of beneficial use of FGD gypsum and fly ash. The final chapter discusses the potential to extrapolate these beneficial use impacts and attribute them to EPA program efforts.2

- 1



# CHAPTER 2: BASELINE CHARACTERIZATION OF CCP GENERATION AND BENEF ICIAL USE

Coal combustion residues (CCRs) are formed dur ing coal

- burning processes in power plants and industrial boilers. Coal combustion produces various forms of CCRs, which are categorized by the process in which they are generated. CCPs are the subset of CCRs that are targeted for beneficial reuse;
this document uses the term broadly to describe all categories of CCRs in which some portion have been beneficially used.

The coal

- fired power industry is the largest generator of CCPs. Other industries, such as commercial boilers and mineral and grain processo rs that use coal as a fuel source also produce small quantities of CCPs. Because these other industries generate such small quantities of CCPs relative to the coal

- fired electric power industry, this report focuses solely on the coal

- fired electric power industry. 8



### CCPs are categorized by the process in which they are generated, which varies by plant. CCPs include the following materials:

 Fly ash. Exhaust gases leaving the combustion chamber of a power plant entrain fly ash particl es during the coal combustion process. To prevent fly ash from entering the atmosphere, power plants use various collection devices to remove it from the gases that are leaving the stack. Fly

ash is the finest of coal ash particles. The American Society for Testing and Material (ASTM) identifies two classes of fly ash suitable for beneficial use based on chemical composition. Class F fly ash results from the burning of anthracite or bituminous coal, while Class C fly ash results from the burning of ligni te or subbituminous coal.

 Bottom ash. With grain sizes ranging from fine sand to fine gravel, bottom ash is coarser than fly ash. Utilities collect bottom ash from the floor of coal burning furnaces used in the generation of steam, the production of el ectric power, or both. The physical characteristics of the product generated depend on the characteristics of the furnace.

 Flue Gas Desulphurization (FGD) material. FGD material results from the flue gas desulphurization scrubbing process that transforms gaseous SO 2 

### , released during coal combustion, to sulfur compounds. Coal

- fired power plants employ either a wet or dry scrubbing

method to remove SO 2 

### from their emissions. The final by

- product of wet scrubbing is primarily FGD gypsum, although small amoun ts of other materials (e.g., ash, metals) are also produced. 9 

### In this report, we refer to these other materials as “other FGD wet material.” The dry method produces by

- products that consist of mainly calcium sulfite, fly ash, portlandite, and calcite.

Co llectively, we refer to these materials as “FGD dry material.” 10 

### All three materials, FGD gypsum, other FGD wet scrubber material, and FGD dry scrubber material, can be used in a number of beneficial use applications.

8 As of the writing of this report, we were unable to locate data estimating the quantities of CCPs attributable only to the el ectric power industry;
however, since the coal power industry consumes approximately 92 percent of all U.S. coal, it is reasonable to assume that significant majority of
CCPs result from the burning of coal at coal

- fired power plants. EIA, 2007, “U.S. Coal Consumption by End

- Use Sector,”
http://www.eia.doe.gov/cneaf /coal/quarterly/html/t28p01p1.html

.

9 FGD gypsum has a very similar chemical structure (calcium dihydrate) to naturally occurring gypsum (calcium sulfate).

10 Electric Power Research Institute, 1999. Environmental Focus: Flue Gas Desulfurization By

- Products . BR

- 1142392

- 2



###  Boiler Slag. Boiler slag consists of molten ash collected at the base of cyclone boilers. Facilities cool boiler slag with water, which then shatters into black, angular pieces that have a smooth

appearance.

 Fluidized Bed Combustion (FBC) ash (not pictured in Exhibit 2

- 1)

. A fluidized bed combustion boiler, a type of coal boiler that combines the coal combustion and flue gas desulphurization processes within a single furnace, generates FBC ash. FBC ash is rich in lime

and sulfur.

 Cenospheres. Generated as a component of fly ash in high te mperature coal combustion, cenospheres consist of extremely small, lightweight, inert, hollow spheres comprised largely of

silica and alumina that are filled with low

- pressure gases. 11 

### When fly ash is disposed in settlement lagoons, cenospheres can be coll ected on the surface where they can be skimmed for use in manufacturing processes.

At a typical coal

- fired power plant, coal combustion generates CCPs during several phases of the process.

Exhibit 2

- 1 illustrates the collection of several types of CCPs. As depicted below, facilities remove bottom ash and boiler slag from the base of the furnace. Fly ash accumulates in the particulate collection device, while FGD material collects in the SO 2 

### control device.

EXHIBIT 2

- 1: COAL COMBUSTION PROC ESS AT A COAL

- F IRED POWER PLANT

Source: Energy Information Administration, accessed at www.eia.doe.gov.

11 Cenospheres range in size from 20 to 5000 microns.2

- 3



## CURRENT QUANTITIES O F CCPS GENERATED AND MANAGED

In 2008 , the coal

- fueled electric power industry generated approximately 136 million short tons of CCPs. Of these, the industry disposed of approximately 75 million short tons to landfills, while beneficially using approximately 61 million short tons in products. 12 

### Exhibit 2

- 2, below, presents the current quantities of CCPs generated and managed, in the context of othe r materials targeted by the SMM

. Except for construction and demolition material, the U.S. generates larger quantities of CCPs than other types of industrial waste and municipal solid waste (MSW).

EXHIBIT 2

- 2: SMM MATERIAL BY QUANTI TIY

MATERIAL a QUANTITY

GENERATED
(MILLION SHORT
TONS) QUANTITY

RECOVERED/

BENEFICIALLY USED b

(MILLION SHORT
TONS) QUANTITY

DISPOSED
(MILLION SHORT
TONS) YEAR

C&D Material 1 331 214 c 118 2003

CCPs 2 136 61 75 2008

Paper and Paperboard 3 77 43 34 2008

Pack aging 3 77 34 33 2008

Organics 3 65 22 43 2008

Foundry Sand 4, d 9. 4 2.6 6. 8 2006

Chemicals 5 0.04 NA NA 2003

Notes :

a. Under the RCC (now SMM ) 2005 Action Plan, increases in the rate of MSW recovery and reduction of priority and toxi c chemicals are also targeted. We have included these material streams in this exhibit even though they are not targeted specifically for beneficial use.
b. The figures shown for paper and paperboard, packaging, and organics are the quantities recovered f rom the MSW stream. The figures shown for C&D debris, CCPs, and foundry sand are quantities that are beneficially used. The figure for CCPs includes use in mining applications, which EPA considers disposal. EPA, 2010, “Hazardous and Solid Waste Manageme nt System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010), p. 35148.

c. A Construction Materials Recycling Association member survey estimates that appr oximately 270 million tons of C&D material including asphalt and concrete from roads, bridge

- related infrastructure, and land clearing debris was recovered in 2004.
d. The foundry sand quantities shown are based on the AFS survey conducted from 2005 to 20 07. The quantity disposed includes sands used as landfill cover.
Sources : 1. US EPA , “Characterization of Building

- Related Construction and Demolition Debris in the United States” and “Characterization of Road

- related Construction and Demolition Debris in the United States,” 2005. (Note that these documents are preliminary and are currently undergoing peer

- review).
2. ACAA, “ 2008 Coal Combustion Product (CCP) Production and Use Survey,” accessed Oct. 18 , 2010, h ttp://acaa.affiniscape.c om/associations/8003/files/2008_ACAA_CCP_Survey_Report_FINAL_100509.pdf

. 3. EPA, 2009, “Municipal Solid Waste Generation , Recycling, and Disposal in the United States: Facts and Figures for 2008,” accessed on Oct. 18, 2010 at http://www.epa.gov/wastes/no nhaz/municipal/pubs/msw2008data.pdf.
4. American Foundry Society (AFS )

, 2007, “Foundry Industry Benchmarking Survey

. ”
5. US EPA, “Draft National Priority Trends Report (1999

- 2003) Fall 2005,” as reported in the NPEP GPRA 2008 database of TRI data from 199 8

- 2003.

12 This figure includes CCPs used in mining applications, which EPA may consider a “large

- scale filling operation” and therefore consider disposal.
EPA, 2010, “Hazardous and Solid Waste Manag ement System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals
From Electric Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010), p. 35148.2

- 4



### The American Coal Ash Association (ACAA), a trade association whose purpose is to advance the beneficial use of CCPs, conducts an annual survey of coal

- fired electric plants to collect data on the production, disposal, and use of CCPs in the U.S. 13 

### Exhibit 2

- 3 summarizes the 2008 survey on generation, disposal, and beneficial use of various CCP categories.

EXHIBIT 2

- 3: SUMMARY OF CCP GENER ATION AND MANAGEMENT IN 2008

PRODUCT CCPS

GENERATED
(MILLION SHORT
TONS) BENEFICIALLY

USE D
(MILLION SHORT
TONS) B PERCENT

USED QUANTITY

DISPOSED
(MILLION
SHORT TONS) a PERCENT

DISPOSED

Fly Ash 72.45 30.14 42% 42.31 58%

Flue Gas Desulfurization (FGD)

Material 33.67 11.82 35% 21.85 65%

FGD Gypsum 17.75 10.65 60% 7.10 40%

FGD Materia l Wet Scrubbers 12.98 0.69 5% 12.30 95%

FGD Material Dry Scrubbers 1.40 0.35 25% 1.05 75%

FGD Other 1.54 0.14 9% 1.40 91%

Bottom Ash 18.43 8.08 44% 10.36 56%

Boiler Slag 2.03 1.69 83% 0.34 17%

Fluidized Bed Combustion (FBC)

Ash 9.49 8.86 93% 0.62 7%

Cenospheres c Not available 0.005 Not available Not available Not available

Total CCPs 136.07 60.59 45% 75.48 55%

Notes:

a. Calculated by subtracting quantity beneficially used from quantity generated. b. These figures include use in mining ap plications, which EPA appears to consider disposal. EPA, 2010, “Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule,” 75 FR 118 (June 21, 20 10), p. 35148.

c

. The ACAA’s “CCP Production and Use Survey” does not report total generation or disposal quantities for cenospheres, only sales.

Source: ACAA, “2008 Coal Combustion Product (CCP) Production and Use Survey,” accessed Oct. 18 , 2010, h ttp:/ /acaa.affiniscape.com/associations/8003/files/2008_ACAA_CCP_Survey_Report_FINAL_100509.pdf

.

13 The ACAA survey is administered to both ACAA members and non

- members. ACAA me mbers account for approximately 40 percent of private
power generation. Not all survey recipients complete the survey each year. ACAA extrapolates survey respondent data to the entire coal

- fired
electricity generation industry. To the extent that other coal

- burning industries are not represented in the ACAA sample, the survey may
underestimate the quantity of CCPs generated and/or beneficially used.2

- 5



### Exhibit 2

- 3 illustrates several important aspects of the generation, beneficial use, and disposal of CPPs:

 Of reported materials, fly ash constitutes the largest proportion ( 53 percent) of CCP materials generated in 2008 . FGD material follows at 25 percent. 14 

### Bottom ash, boiler slag and FBC ash collectively comprise the remaining 22 percent of CCPs generated in 2008

.

 Boiler slag

, FGD gyps um , and FBC ash have the highest percentage of beneficial use. However

, FBC ash is used mainly in mining applications, which EPA may not consider a beneficial use. 15



###  Fly ash, FGD material other than FGD gypsum, and bottom ash have the highest disposal rate s.
In addition to quantities of fly ash reported in the ACAA survey, stockpiles may provide another potential source of fly ash for certain beneficial uses. Industry sources estimate that between 100 million and 500 million tons of fly ash have accumulate d in U.S. landfills since the 1920s, when disposal of fly ash in landfills began. 16

, 17



## Beneficial Use Options The chemical and physical properties of CCPs allow for their use in a wide range of products. CCPs may be used as a component of various buildin g materials (i.e., as a replacement for portland cement in concrete) or as a direct replacement for other virgin materials such as sand, gravel, or gypsum. The physical properties of CCPs make them especially useful for construction and industrial material s. Size, shape, and chemical composition determine the suitability of specific material flows for beneficial use. Higher value applications, such as use in cement or concrete products, require comparatively stringent specifications (in terms of size, sha pe and chemical composition), whereas lower value uses, such as structural or mining fills, can accept more variable materials. For this reason, EPA has noted that lower technology applications that require large volumes of CCPs may present the greatest p otential for expanded beneficial use. 18



### Exhibit 2

- 4 summarizes the most common beneficial uses for CCPs

. T his table excludes cenospheres as data on the primary beneficial uses of this material are not available.

14 The quantity of cenospheres generated is not reported by ACAA so the 58 percent estimate could be hig her if cenospheres were included.

15 EPA, 2010, “Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Resid uals
From Electric Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010), p. 35148.

16 Personal communications with Dave Goss, ACAA and Tom Janson, WE Energies, November 27, 2006.

17 The quantity of stockpiled fly ash that is available for beneficial use is unclear. The chemical composition of fly ash vari es depending on the type

of coal us ed, and only two types of fly ash

-- class C fly ash and class F fly ash

— meet the ASTM technical requirements for concrete. It is unclear

how much of the estimated 100

- 500 million tons of stockpiled fly ash falls into one of these classes. In addition, exp osure to moisture or
contamination in the stockpiles can limit the beneficial use options of Class C ash, though, this is not a concern with Class F ash. Information on

these standards can be found at http://www.astm.or g

.

18 EPA. 1999. “Report to Congress: Wastes from the Combustion of Fossil Fuels.” Vol. II. EPA

- 530

- R

- 99

- 010, March 1999.2

- 6

EXHIBIT 2

- 4: COMMON BENEFICIAL US ES FOR CC PS

CCP BENEFICIAL USE

Fly Ash Concrete: Concrete consists of a mixture of approximately 25% fine aggregate (sand), 45% gravel,

15% portland cement, and 15% water. Class C and class F fly ash can replace a percentage of the portland cement component of c oncrete. Fly ash contributes to enhanced concrete strength and durability, and is typically less expensive than portland cement.

Cement clinker: Clinker is an intermediary product of the portland cement manufacturing process. Clinker is formed when a raw mix of limestone, clay, bauxite, iron ore and quartz is heated in a kilm at high temperatures. Fly ash can be blended with limestone or shale and fed into the kiln to make clinker, which is then ground into portland cement.

Structural fill: Structural fill is an engineered material used to raise or change the surface contour of an area and to provide ground support beneath building foundations. It can also be used to form embankments. Depending on the soil type, fly ash can replace a percentage (general ly 50 percent) of virgin rock, dirt, sand or gravel in structural fill.

Waste stabilization: Fly ash can be used in place of portland cement, cement kiln dust, or lime to solidify and harden wet or liquid waste before it is landfilled. Class C fly ash ha rdens by itself in contact with moisture, but class F fly ash must be mixed with another hardening agent, such as portland cement, in order to be used in waste stabilization.

FGD Gypsum Wallboard: Gypsum wallboard (drywall) is an interior finish in buildi ng construction. Wallboard is a

layer of gypsum stucco sandwiched between two sheets of heavy paper. FGD gypsum can replace 100 percent of virgin gypsum in wallboard after excess moisture is removed.

Agricultural soil amendment: FGD gypsum can be used to replace liming agents and to provide
certain nutrients as an agricultural soil amendment for specific soil and crop types.

Cement additive: In the production of portland cement, clinker is blended with a small amount of gypsum prior to grinding into fin ished portland cement. FGD gypsum can be used to offset virgin gypsum in cement manufacture.

Bottom Ash Structural fill: Structural fill is an engineered material used to raise or change the surface contour

of an area and to provide ground support beneat h building foundations. It can also be used to form embankments. Bottom ash can be used to offset virgin sand and gravel in structural fill.

Road base: A road base is a foundation layer underlying a pavement and overlaying a subgrade of natural soil or e mbankment fill material. It protects the underlying soil from the detrimental effects of weather conditions and from the stresses and strains induced by traffic loads. Bottom ash can be used to offset virgin sand or gravel in road base.

Concrete: Bottom ash can be used as a coarse aggregate for concrete blocks, with its porous nature often qualifying the product for lightweight classification.

Boiler Slag Blasting Grit: Blasting grit is an industrial abrasive used to shape, cut, sharpen, or finish a vari ety

of other surfaces and materials. Boiler slag can be used as a replacement for other slags or virgin sand as blasting grit.

Structural fill: Structural fill is an engineered material used to raise or change the surface contour of an area and to provid e ground support beneath building foundations. It can also be used to form embankments. Boiler slag is occasionally used to offset virgin sand and gravel in structural fill.

FBC Ash Mining applications : FBC ash can be placed into abandoned mines during re clamation to neutralize

the acidity of mine drainage. EPA considers large fill operations to be disposal, and so would not likely consider mining applications a beneficial use , though it is tracked by ACAA

.



### Exhibit 2

- 5, below, illustrates the quantities of CCPs being used in the most common beneficial use applications. The applications highlighted in the exhibit represent 90 percent of the current use of2

- 7



### CCPs. 19 

### We include an expanded version of this table, which details a more inclusive set of CCP

benef icial use applications, in Appendix A.

EXHIBIT 2

- 5: KEY BENEFICIAL USES FOR CCPS IN 2008 (MILLION SHORT TONS)

APPLICATION

(INDUSTRY) COAL

FLY ASH BOTTOM

ASH FGD

GYPSUM FGD MATERIAL

WET SCRUBBERS FGD MATERIAL

DRY SCRUBBERS FGD

OTHER B OILER

SLAG FBC

ASH TOTAL

Concrete a
(Construction) 12.59 0.72 0.68 0 0.02 0 0 0.004 14.02

Structural fill b
(Construction) 8.01 3.00 0 0 0.13 0.11 0.18 0.08 11.50
Mining applications c 0.96 0.06 0 0.69 0.11 0 0.003 8.64 10.47

Wallboard d
(Construction) 0 0 8.53 0 0 0 0 0 8.53

Raw feed for

cement clinker e
(Construction) 3.17 0.61 0.41 0 0 0 0 0 4.20

Waste stabilization f
(Waste Mgmt) 2.92 0.08 0.74 0 0.001 0.03 0 0 3.78

Road base g 1.03 0.77 0 0 0 0 0 0.01 1.80

Total

- Key Uses 28.69 5.24 10.37 1 0.26 0.1 4 0.18 8.73 54.30

Total

- Other

Uses h 1.45 2.83 0.29 0.00 0.08 0.00 1.51 0.13 6.29

TOTAL

- ALL USES 30.14 8.08 10.65 0.69 0.35 0.14 1.69 8.86 60.59

2008 QUANTITY

GENERATED 72.45 18.43 17.75 12.98 1.40 1.54 2.03 9.49 136.07

CCP UTILIZATION

RATE g 42% 44% 60% 5% 25% 9% 83% 93% 45%

Notes:

a. CCPs are frequently used as a replacement for a portion of portland cement in the manufacture of concrete.
b. Structural fill is an engineered material that is used to raise or change the surface contour of an area and to provide ground support beneath highway roadbeds, pavements and building foundations. It can also be used to form embankments.

c. FBC ash and other CCPs can be used in mine reclamation to refill mines and to help mitigate acid mine drainage. EPA co nsiders large fill operations such as this use to be disposal and not a beneficial use (75 FR 118 p. 35148).
d. FGD gypsum is used as a substitute for virgin gypsum in wallboard manufacturing.

e. CCPs can be blended with limestone or shale in the cement kiln to make clinker, which is then ground into Portland cement.
f. T he chemical properties of CCPs make them effective stabilizers of biosolids (i.e., sludge from municipal waste water treatmen t).

g. Coal ash is used as in ingredient in road base and sub

- base. h. Presents quantities beneficially used in minor applications not included in this exhibit, but listed in Appendix A.
i. CCP utilization rates reflect all use applications, some of which are omitted from this table but are included in Appendix A. Utilization rates are calculated by dividing the total quantity used by the total quantity generated.

Sources : 1. ACAA, “2008 Coal Combustion Product (CCP ) Production and Use Survey,” accessed Oct. 18, 2010 at
h ttp://acaa.affiniscape.c om/associations/8003/files/2008_ACAA_CCP_Survey_Report_FINAL_100509.pdf

. 2. Western Region Ash Group, “Applications and Competing Materials, Coal Combustion Byproducts,” accessed at http://www.wrash g.org/compmat.htm

.

19 Relatively minor applications comprise the remaining 10 percent of CCP beneficial uses. These applications include uses such as bla sting grit, soil
modification and stabilization, and as flowable fill.2

- 8



### Exhibit 2

- 5 illustrates several important aspects regarding the beneficial use options for CCPs:

 Concrete, structural fill, mining applications, and wallboard comprise the highest volume

beneficial uses of CCPs.

 The use of fly ash a s a pozzolanic binder in concrete represents the largest single beneficial use application of a CCP material. 20 

### Fly ash can substitute for finished portland cement in concrete and can be a valuable additive to concrete mixtures that enhances the strength, durability, and workability of the concrete product. 21



###  FBC ash is used in mine reclamation to fill mines and to help prevent acid mine drainage. 22 

### This represents the second largest application of a CCP material as identified b y ACAA , and yields a high use rate for FBC ash of 93 percent . H owever , EPA considers large fill operations to be disposal, and therefore would not likely consider mining applications to be a beneficial use. 23



###  FGD gypsum serves as a substitute for virgin gypsum in wallboard construction . This high

- value use represents the third largest use of a CCP material by volume

.

 Although one of the smaller material streams, facilities beneficially use boiler slag in blasting grit (not shown on this exhibit) and structural fill, yielding a high use rate of 83 percent. Boiler slag is in high demand for beneficial use. Boiler slag particles are highly uniform in size, hard, and

durable . In addition, its permanent black color makes it ideal for asphalt applications and aids in melting snow

. 24



### T he res ults of the 2008 ACAA survey compared with the previous surveys in 2005, 2006 and 2007 show
an overall increase in the CCP utilization rate in recent years. I n 2005, the beneficial use rate was 40.3 percent, and by 2008 it was 44.6 percent, with little de viation from the trend in between. However, both generation and beneficial use of CCPs increased during this period, and the amount disposed actually increased slightly from 73.5 million tons in 2005 to 75.4 million tons in 2008. 25 

### The most significant

c hanges within categories are boiler slag, which decreased in its use rate by 13 percentage points; and FGD gypsum and FGD material from dry scrubbers, which increased their beneficial use rates by 17 and 14 percentage points, respectively. 26

, 27

20 Fly ash is technically a pozzolanic, not a cementitious material. A cementitious material, such as portland cement, is one th at hardens when
mixed with water. A pozzolanic material wi ll also harden with water but only after activation with an alkaline substance such as lime. The
combination of portland cement and water in concrete mixtures creates two products: a durable binder that “glues” concrete ag gregates together

and free lime. F ly ash reacts with this free lime to create more of the desirable binder.

21 Personal communication with Tom Pyle, Caltrans, November 2006.

22 Schueck, Joseph et al, 2001, “The Use of FBC Ash for Alkaline Addition at Surface Coal Mines,” 2002 International A sh Utilization Symposium,
accessed Nov. 19, 2010 at http://www.flyash.info/2001/mining1/49schue.pdf

.

23 EPA, 2010, “Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Resid uals

From Elect ric Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010), p. 35148.

24 EPA

, “Boiler Slag,” accessed Nov. 18, 2010 at http://www.epa.gov/osw/conserve/rrr/imr/ccps/boilslag.htm.

25 Though, part of the increase in beneficial use figures was from an increase of FBC ash in mining applications, which EPA considers disposal

. EPA, 2010, “Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Resid uals
From Electric Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010), p. 35148.

26 ACAA , Coal Combustion Product (CCP) Production and Use Surveys for 2005 to 2008, accessed Oct. 18, 2010 at
http://acaa.affiniscape.com/displaycommon.cfm?an=1&subarticlenbr=3

.

27 Use of boiler slag is decreasing in part because the supply of boiler slag is declining as the types of boilers that produce boiler slag are phased
out. EPA, “Boiler Slag,” accessed at http://www.epa.gov/osw/conserve/rrr/imr/ccps/boilslag.htm

.3

- 1



# CHAPTER 3 : MARKET STRUCTURE F OR BENEFICIAL USE O F CCP s

Understanding the factors that affect beneficial use of CCPs requires consideration of the underlying markets affecting its generation and management. The CCP marke t includes three market segments: (1)
coal

- fired utilities, (2) intermediaries: CCP marketers and consultants, and (3) end

- users. In addition, state regulators determine the extent to which CCPs can be beneficially used by defining the regulatory

context in which these actors operate. This chapter considers the factors affecting beneficial use decisions among these groups participating in the marketplace. We then present a discussion of opportunities for growth in the selected CCP markets, along with a more specific illustration using t wo common beneficial applications. Finally, we discuss our efforts to improve market conditions for CCPs.

Three main challenges exist in developing the beneficial use market for CCPs. First, because CCPs are a heavy mate rial to transport, the distance between the location of the coal

- fired utility generating the CCPs and the potential end

- user is a driving factor in determining whether the CCPs will be beneficially used in a project. Another difficulty in developing the beneficial use market is the capacity for individual coal

fired utilities to provide a quantity of high quality CCPs sufficient to meet end

- users’ demands. The ability of end

- users to obtain enough CCPs for their purposes is an important consideration in estimating and sustaining demand for CCPs. Finally, as noted above, the variability in use options across states poses a challenge to both coal

- burning plants and end

- users in trying to determine applicable beneficial use options for CCPs.



## COAL

- FIRED UT ILITY PRACTICES: CCP SUPPLY

The coal

- fired power industry is the largest generator of CCPs in the United States. As noted previously, other industries that use coal as a fuel source in commercial or industrial boilers (e.g., mineral and grain processors) also produce small quantities of CCPs. Coal

- generated electricity supplies roughly half of electricity consumed in the United States. 28 

### In its 2010 Annual Energy Outlook middle

- range scenario, the EIA projects that electricity demand will increase by 30 pe rcent between 2008 and 2035, and that the share of electricity generation supplied by coal will reach 44 percent, down from 48 percent in 2008. Since coal will continue to be an important fuel source, it is likely that the quantity of CCPs produced and

av ailable for beneficial use will also increase. 29



### An estimated 495 coal

- fired electric utilit y plants currently operate in the U.S. 30 

### Exhibit 3

- 1 shows the geographic distribution of coal consumption by electric power plants across the U.S. Coal consumptio n by power plants is greatest in the East North Central region of the U.S., but consumption remains relatively high throughout the entire Central and Southern United States. Coal consumption is low in the contiguous and noncontiguous Pacific regions of th e U.S. and in New England. CCP generation closely approximates the geographic distribution of coal consumption across the U.S., but is not directly proportional to coal consumption. The composition of coal varies regionally in the U.S. For example, the

n on

- combustible portion (commonly referred to as “ash”) of Western bituminous coal is higher than that

of Western sub

- bituminous coal ( roughly 10 to 15 percent and four to six percent ash, respectively). Coal with a higher non

- combustible ash content will yield greater quantities of CCPs when combusted.

28 EIA , 2010, “Net Generation by Energy Source: Total (All Se ctors),” accessed October 25, 2010 at
http://www.eia.doe.gov/cneaf/electricity/epm/table1_1.html

.

29 EIA, 2010, “Annual Energy Outlook 2010 with Projections to 2035: Electricity Demand,” accessed October 25, 2010 at
http://www.eia.doe.gov/oiaf/aeo/electrici ty.html

.

30 EPA, 2010, “Regulatory Impact Analysis for EPA’s Proposed RCRA Regulation Of Coal Combustion Residues (CCR) Generated by the Electric Utility
Industry,” EPA

- HQ

- RCRA

- 2009

- 0640

- 0003.3

- 2

EXHIBIT 3

- 1: ELECTRIC POWER SECTO R CONSUMPTION OF COA L IN 2009 , BY CENSUS REGION

(MILLION SHORT TONS AND PERCENT CHANGE F ROM 2008 )

Source: Energy Information Administration , 2010

, “Fig ure 3. Electric Power Sector Consumption of Coal by Census Region,
2009, ” accessed Oct. 31, 2010 at http://www.eia.doe.gov/cneaf/coal/page/special/fig3.html

.


### Several factors influence a utility’s decision to supply CCPs for beneficia l use. Economic factors are the primary consideration and include:

 Landfill disposal costs. For many utilities, the sale of CCPs for beneficial use is a means of reducing operating costs through avoidance of landfill tipping fees. In order for beneficial use of CCPs to be competitive, the cost of reselling CCPs, minus revenue from the sale, must be less than the cost of landfill disposal. Landfill tipping fees vary regionally but range from $5 per ton to $45 per ton. 31 

### Avoiding landfill disposal costs may be a significant incentive for a utility to engage in beneficial use.

 Revenue from sale. Depending on the type of CCP, an electric utility may or may not receive revenue for its ash. For some CCP types, marketers will accept ash as a service to the plan t (allowing the plant to avoid disposal costs) but do not pay for the ash. For other CCP types, especially fly ash, boiler slag and cenospheres, the revenue received can be a significant incentive for a utility to market its ash. 32



###  Transport costs. CCPs a re heavy materials, which makes transport over long distances expensive. Transport distance between the utility and the nearest landfill or end

- user is a significant determinant in the management of CCPs.

31 Personal communication with Dave Goss, American Coal Ash Ass ociation, April 2006.

32 Personal communication with Dave Goss, American Coal Ash Association, May 2006.3

- 3



###  Processing costs. Approximately 90 to 95 percent o f CCPs do not require processing prior to beneficial use. However, higher value applications that require specialized CCP products may require processing to meet material specifications.

 Storage costs. In many parts of the country, the production of coal ash is high during both the coldest and hottest months of the year when people are heating and cooling their homes, offices and schools. However, the winter season is often the slowest period for construction and other applications that beneficially use the fly ash. As a result, it is necessary to store CCPs until they can be utilized. Typically, domes are inflated adjacent to boilers for the CCP collection. The cost of storing fly ash or other CCPs during the winter months may be a deterrent to benefi cial use by a utility.

 Marketing costs. In order to attract buyers of CCPs, a marketer must devote financial resources to marketing their specific product(s) for beneficial use. Some utilities market their CCPs directly to end

- use rs, but others pay a third party marketer or broker to negotiate CCP sales.

In the end, a generator’s decision to make CCPs available for beneficial use rather than disposal is a result
of a confluence of all the above factors, as well as non

- economic fac tors such as access to information about permissible applications and availability of technical assistance. Depending on the circumstances, a

coal

- fired utility may weigh certain factors more heavily than others. For example, since off

- site disposal

and transport to a marketer or end

- user both require hauling, total transport distance to the off

- site facility is an important consideration. If the off

- site disposal facility is closer, then a generator may opt to send

its CCPs to the landfill instead of to the marketer or end

- user. However, if the avoided disposal costs from the marketing arrangement are higher than the cost of offsite disposal, then avoided costs may be enough to offset the additional cost to transport the materials to the marketer or end

- user. In addition, a

coal

- fired utility may be more willing to absorb higher costs (of transport, marketing, etc.) for higher

value materials and uses for which it can charge a higher premium (e.g. fly ash as a portland cement substitute in concrete). 33



## INTERMEDIARIES Many coal

- fired electric generators market their CCPs through a third

- party marketer instead of selling directly to the end

- user. In these cases, a utility perceives an efficiency in outsourcing the marketing of its CCPs. Marketers typicall y accept all of a generator’s CCPs as a service to the company, sell the marketable portion, and dispose of the portion that is not salable. The marketer typically bears the cost of hauling CCPs from the utility and incorporates this cost into the sale pr ice.



## END

- USERS AND PURCHASERS : CCP DEMAND

Several factors influence an end

- user’s decision to use CCPs in a product , including :

 Price of CCPs relative to the price of virgin materials. 34 

### If the price of a virgin material is less

than the price of CCPs (which will reflect cost factors such as transport distance, processing and storage costs), end

- users will generally purchase virgin materials. In areas where virgin materials are abundant and inexpensive, CCPs may not be economically vi able. Exhibit 3

- 2 shows the

33 Note that the transfer of CCPs from generators to users may lead to potential cost savings for the generators. It may be pos sible for generators

to s hift liability (and related costs) associated with CCPs to users of the product. The law on this matter is not well

- defined and needs to be
clarified to determine the magnitude of any potential cost savings.

34 Note that the “price” of CCPs represents how much an end

- user would pay for the product.3

- 4



### typical price ranges for CCPs used in various applications relative to the virgin materials they replace.

EXHIBIT 3

- 2: SAMPLE CCP AND VIRGI N MATERIAL PRICES FO R CCP APPLICATIONS

VIRGIN MATERIAL 200 8 AVG

PRICE, (PER

TON, FREE O N
BOARD) a 2009 PRICE b CCP SUBSTITUTE 2003 AVG

PRICE, (PER

TON, FREE ON
BOARD) a 2009 PRICE b

Portland cement $ 93.44 $95.34 Concrete quality fly ash $20 to $45 $22.01 to $49.53
Boiler slag Not available Virgin aggregate for fill $ 4. 08 $4.16 Fly ash f or flowable fill $1 and up $1.10 and up
Virgin aggregate for road base $ 5.79 $5.91 Bottom ash or fly ash for road base $4 to $8 $4.40 to $8.81

Lime for soil stabilization (Hydrated lime) $ 97.30 $99.28 Fly ash for soil stabilization $10 to $20 $11.01 to $ 22.01

Lime for waste stabilization (Quicklime) $ 81.60 $83.26 Fly ash for waste stabilization $15 to $25 $16.51 to $27.52
Virgin aggregate for snow and ice control $ 6. 25 $6.38 Bottom ash for snow and ice control $3 to $6 $3.30 to $6.60

Gypsum for wallboa rd (calcined) $ 38.68 $39.47 FGD Gypsum $0

- $8.00 $0

– $8.81

a. Virgin material prices are reported by USGS while CCP prices are provided by ACAA. This price data represents the best available information, and should be cross

- compared with caution, as th e data may not capture all factors driving price variability. “Free on Board” indicates that the supplier pays the shipping costs (and usually the insurance costs) from the point of manufacture to a specified destination, at which point the buyer takes re sponsibility. Virgin material prices for portland cement, virgin aggregate, and gypsum were originally per metric ton; we converted to price per short ton.
b. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html.

Sources : 1. USGS, 2010, “Mineral Commodity Summaries: Cement, 2010,” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/cement/mcs

- 2010

- cemen.pdf
2. USG S, 2010, “2008 Minerals Yearbook: Sand and Gravel, Construction [Advance Release],” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/sand_&_gravel_construction/myb1

- 2008

- sandc.pdf

. 3. USGS, 2010, “2008 Minerals Yearbook: Lime [Advanc e Release],” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/lime/myb1

- 2008

- lime.pdf

. 4. USGS, 2010, “2008 Minerals Yearbook: Gypsum [Advance Release],” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/gyps um/myb1

- 2008

- gypsu.pdf

. 5. ACAA (American Coal Ash Association), 2008, “Frequently Asked Questions,” accessed Nov. 19, 2010 at http://acaa.affiniscape.com/displaycommon.cfm?an=1&subarticlenbr=5.
6. Miller, Cheri. Gypsum Parameters. Presentation at WOCA Short Cou rse: "Strategies for Development of FGD Gypsum Resources."



###  Technical fit between CCPs and use application. CCPs have varying physical and chemical characteristics due to differences in coal types, combustion processes, air pollution control technologie s, and CCP management practices at individual power plants. To be beneficially used in a particular application, the chemical and physical properties of the CCP must align with the engineering requirements of that application. For example, high carbon co ntent or the presence of air emission additives may render some CCPs unsuitable for some use applications.3

- 5



###  Sufficient quantities of CCPs. Some beneficial use applications require larger volumes of CCPs than are typically produced at a single power plant. Where demand for CCPs is greater than the supply generated by a single plant, the end

- user may need to purchase CCPs from multiple suppliers; this can increase transaction costs.

 State Regulations. Regulations governing beneficial us e of CCPs vary by state. In many states, beneficial use of CCPs must be approved on a project

- by

- project basis. Currently, public and environmental health considerations drive state regulatory decisions concerning beneficial use of

CCPs in end

- use applica tions. 35

, 36



###  Incomplete science. In the absence of definitive data on all health and environmental risks associated with the beneficial use of CCPs, some states have chosen to limit the use of CCPs in building materials. For example, EPA research has found that CCPs may release small quantities of mercury to the ambient air during use in certain industrial processes 37 

### Noting this research, States have questioned the safety of using fly ash in cement to be used in schools. 38

, 39



## MARKET DYNAMICS OF S PECIFIC USE A PPLICATIONS The beneficial use markets for CCPs depend on the physical properties of the materials, the demand for their particular uses, and the supply of materials available for use. Exhibit 3

- 3, below, summarizes the

current state of the beneficial use markets for the suite of CCPs, along with an analysis of the potential for growth in the beneficial use market for each material. An established market contains four key elements,
all of which are interconnected:

 Generators producing a consistent supply of materials;

 End

- users with the demand to use the product;

 Well

- known, accepted beneficial use applications; and

 A distribution system to transport materials from generators to users.

Limited markets may have a subset of these key elements, but likely need a shift in technology, demand, or price to increase beneficial use of the product. Emerging markets are typically unorganized and the connections between the elements are not fully formed.

35 Energy & Environmental Research Center, University of North Dakota, “ Review of Florida Regulations, Standards, and Practices Related to the
Use of Coal Combustion Products: Final Report,” April 2006 , accessed at http://www.undeerc.org/carrc/Assets/TB

- FLStateReviewFinal.pdf

.

36 Some states, such as Wisconsin, have set up regulatory schemes designed to speed up the approval process f or products using beneficial use
materials such as CCPs. Currently, Wisconsin requires initial leachate testing of the material to be beneficially used, whic h leads to a specific
rating. Materials that fall into a standard rating class are automatically approved for specific uses. For example, material found to meet drinking
water standards can be used in any application, whereas material found to have a moderate level of contamination, may only be approved for
encapsulated uses. Users are also required to submit annual reports demonstrating testing of CCPs. Personal communication with Bizhan
Sheikholeslami, Wisconsin Department of Natural Resources, November 2006.

37 Further EPA study has revealed that in laboratory conditions, mercury is retained by fl y ash and is “unlikely to be leached at levels of

environmental concern.” Hassett, David J., Debra F. Pflughoeft

- Hassett, Dennis L. Laudal, and John H. Pavlish. 1999. Mercury Release from Coal
Combustion ByProducts to the Environment. However, this issue c ontinues to be a focus of risk studies, and EPA’s Office of Research and
Development is currently developing a life cycle inventory for cement production that reflects the impact of new mercury regu lations.

38 Personal Communication with Antoinette Stein, State of California Department of Health Services, June 2006.

39 Sanchez, F. et al, 2006. “Characterization of Mercury

- Enriched Coal Combustion Residues from Electric Utilities Using Enhanced Sorbents for
Mercury Control,” EPA

- 600/R

- 06/008, accessed Nov. 1 7, 2010 at http://www.epa.gov/ORD/NRMRL/pubs/600r06008/600r06008.pdf

.3

- 6

EXHIBIT 3

- 3: CCP BENEFICIAL USE M ARKETS

CCP STATE OF BENEF ICIAL USE

MARKET POTENTIAL FOR MARKET GROWTH

Fly Ash Established markets The markets for fly ash have the potential to continue to grow. Generators produce fly ash in large quantities and there are

several well

- known, high

- value uses. Currently, only 42 perccent of fly ash is beneficially used.

FGD Gypsum Established markets The FGD gypsum market has room for moderate growth. FDG gypsum wallboard is an accepted alternative to virgin gypsum

wallboard with users often directly connected to generators

. Currently, 60 percent of FDG gypsum is beneficially used. Other uses are emerging but are currently limited, and data on market opportunities are limited.

Dry FGD Material Limited market The current market for dry FDG material appears to have only

limi ted potential for growth. Uses for the material appear to be limited to relatively low

- value uses, such mine reclamation. Currently, 25 percent of this material is beneficially used. Data on the market opportunities for this material are limited.

Wet FD G Material Limited market The current market for other FDG wet material appears to have only limited potential for growth. Uses for the material appear to be limited to relatively low

- value uses, such mine reclamation. Currently, only five percent of th is material is beneficially used. Data on the market opportunities for this material are limited.

Bottom Ash Established markets The markets for bottom ash have the potential to continue to grow. Generators produce bottom ash in large quantities and

ther e are several well

- known, high

- value uses. Currently, 44
percent of bottom ash is beneficially used.

Boiler Slag Established markets The markets for boiler slag are mature and have limited opportunity for growth. Since approximately 83 percent of boi ler slag is beneficially used (primarily as blasting grit), supply is currently roughly equivalent to demand.

FBC Ash Established markets The markets for FBC ash have potential for moderate growth, although mainly for low

- value uses. Currently 93 percent of FBC

ash is used. However , a majority is us ed in mi ning applic atio ns,
which EPA may co nsi der di spos al.

Cenospheres Emerging market The markets for cenospheres have the potential for growth as information on their uses becomes more widely available. However, information regarding potential uses and the current

reuse rate is limited at this time.



### Aside from the boiler slag market and mining use of FBC ash , the markets for the various CCPs generally
have at le a st modest capacity for growth. EPA eff orts that aim to increase growth in the markets for CCPs by targeting beneficial use applications that are well

- accepted practices in the industry may have significant success in helping expand these markets by overcoming targeted technical, administrative and technical and informational hurdles. The economic viability of two economically significant beneficial3

- 7



### uses is considered individually below. Concrete and gypsum wallboard are long

- standing, widely accepted uses for CCPs.



## Concrete Certain perform ance 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. 40 

### Fly ash substitutes directly for portland cement in the concrete mixing p rocess. This beneficial use represents one of the highest value applications for CCPs, and has the potential to increase as the demand for portland
cement in the U.S begins to recover with the economy

. 41



### Industry representatives and some state agencies hav e stated that there are possible emerging issues related to regulatory programs for the control of nitrogen oxides (NOx) and mercury in power plant flue gases. These issues relate to the potential for negative impacts on coal fly ash quality and available quantities due to the potential for increased mercury contamination in the ash, or unacceptably high levels of carbon content. There are technology choices that would minimize these impacts on the beneficial use of coal fly ash. However, the selection o f equipment for control of nitrogen oxides and mercury, and corresponding technologies potentially necessary to minimize quality impacts on coal fly ash is very complex, resulting in industry solutions that would be unit

- specific. Losses of anywhere betwee n $40/ton and $80/ton of coal fly ash 42 

### are possible if industry is unable 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 di spose of a formerly

marketable material. State of Florida officials noted that installation of air emission controls at coal

- fired power plants might result in increased mercury associated with coal fly ash. Since coal fly ash is used in portland cement manufacturing, electric utilities and portland cement manufacturers have expressed concern that the Florida Department of Environmental Protection’s (FDEP) New Source Review (NSR) might limit or even eliminate the use of CCPs for this purpose. Officials a lso noted that similar impacts might occur for coal fly ash containing higher levels of unburned carbon or other components resulting from changes in operations, fuel, or emission controls. 43 

### This may have the potential of jeopardizing the recycling of man y tons of CCPs that are currently reused.

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 44 

### . Off

icials 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.

Overall, t echnology options are available to the industry, specifically for the application of NOx controls, which would minimize any impacts on the quality of fly ash. T echnology solutions are currently being

40 Personal communication with Tom Pyle, Caltrans, November 2006.

41 The USGS January 2010 USGS Cement mineral commodity summary outlines a significant downturn in demand for cement as the recession and
housing market contractions affected construction. 2009 saw closure of 14 plants (as three opened), and a decline of almost 30 percent in total
production to 70 million tons from the market’s peak in 2005 of over 99 million tons. The commo dity summary notes that while the industry is
likely to recover, it will take several years to achieve 2005 production levels.

42 Mercury

- CCP dialogue meeting summary document, Final Draft, 1/14/08.

43 Energy and Environment Research Center (EERC), April 2 006. 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.

44 Energy and Environment Research Center (EERC), January 2005 , “ Review of Texas Regul ations, Standards, and Practices Related to the Use of

Coal Combustion Products ,” 2005

- EERC

- 01

- 01

, University of North Dakota, Grand Forks, ND.3

- 8



### developed and deployed in the industry to minimize or a void any such impacts from the use of mercury
controls as well. In addition, one study conducted by EPA Office of Research and Development found through laboratory tests that mercury is highly retained in fly ash and is “unlikely to be leached at levels

o f environmental concern.” 45 

### However, research continues on the impact of changes in air pollution control technology on the ability to use fly ash in different applications.



## Gypsum Wallboard FGD gypsum is a product derived from the wet FGD process. Utiliza tion of FGD gypsum in wallboard
manufacture is a well

- established market. Because the quality of FGD gypsum produced by power plants is generally consistent, new wallboard facilities often locate adjacent to power plants to allow FGD gypsum to be delivered directly to the wallboard plants. In some cases, wet FGD gypsum is piped directly to the adjacent wallboard facility, a step that significantly reduces transport and handling costs. Given these developments, the demand for FGD gypsum will likely remain h igh, and may increase as new wallboard manufacturing facilities are being constructed to accommodate FGD gypsum in wallboard production. 46

45 Sanchez, F. et al, 2006. “Characterization of Mercury

- Enriched Coal Combustion Residues from Electric Utilit ies Using Enhanced Sorbents for
Mercury Control,” EPA

- 600/R

- 06/008, accessed Nov. 17, 2010 at http://www.epa.gov/ORD/NRMRL/pubs/600r06008/600r06008.pdf.

46 Electric Power Research Institute, “Environmental Focus: Flue Gas Desulfurization By

- Products,” 1999

.4

- 1



# CHAPTER 4: IMPACTS ASSOCIATED WITH BENE FICIAL USE OF CCP s

To evaluate EPA's efforts to improve the beneficial u se of CCPs, it is essential to quantify the important environmental and human health impacts of increased use of these materials in various beneficial use applications. An initial step in this process is describing the incremental environmental impacts ass ociated with using a specific quantity (e.g., one ton) of CCPs in different applications. These impacts can then be extrapolated in specific scenarios designed to address program

- level outcomes. This report draws on the data and methods used in life cycl e assessment (LCA) to provide a screening

- level description of the environmental impacts related to beneficial use of CCPs.

This chapter first provides a brief overview of the use of LCA in the assessment of environmental impacts of beneficial use, and al so discusses the relationship between LCA and the economic analysis of net social benefits. Next, the chapter identifies several available LCA tools that can be used to provide insights into the impacts of beneficial use of CCPs in different applications, and presents an initial life cycle inventory analysis of the potential impacts associated with the use of one ton of fly ash and FGD gypsum in concrete and wallboard manufacture, respectively. Finally, we note key limitations of this

initial assessment an d identify areas for additional research.



## LIFE CYCLE INVENTORY ANALYSIS AND EPA PROGRAM OUTCOMES Life cycle assessment (LCA) represents a proven methodology for describing the environmental impacts associated with changes in production systems. Specificall y, LCA is a technique to assess the environmental aspects and potential impacts associated with a product, process, or service, by:

 compiling an inventory of relevant energy and material inputs and environmental releases;

 evaluating the potential environme ntal impacts associated with identified inputs and releases; and

 interpreting the results to help make a more informed decision. 47



### A complete LCA typically refers to a four

- stage process that includes: 1) the definition of the goal and scope of the analysi s, 2) an analysis of the life cycle inventory data (measurement of the changes in emissions, energy, and materials use and production related to the system); 3) assessment of specific environmental impacts (e.g., human health effects or “global warming po tential”); and

, 4) interpretation

of results.

In this report , EPA focuses specifically on a life cycle inventory analysis. The aim is to identify appropriate existing life cycle inventory data to characterize the changes in use of materials and energy, and the changes in emissions, that result from beneficial use of CCPs. Because the analysis relies on general production information and existing inventories, we do not attempt to assess environmental impact endpoints such as human health risk or global warming potential.

A l ife cycle inventory depicts the production of materials as a system of complex physical outcomes, and can predict the incremental physical consequences of a change in material inputs, technology, waste management practices, or price incentives. In life cycle assessment , as in reality, one change in the physical system, such as the substitution of fly ash for virgin portland cement, leads to a corresponding cascade of economy

- wide impacts and shifts. As inputs are substituted, techn ologies, physical outputs,

47 EPA provides a general overview of LCA and introduction to a number of tools and resources on its web site: see
http://www.epa.gov/nrmrl/lcaccess/ See also, International Standard on Environmental M anagement

— Life Cycle Assessment

— Goal and scope
definition and inventory analysis (ISO 14041:1(E))

.4

- 2



### and exposure pathways change. Using a range of modeling platforms and life cycle inventories to calculate the outputs associated with each intermediate change, LCA calculates the net result of all of these interactions, capturin g the total incremental effect of a change in operations on physical environmental impacts such as air emissions, and energy and water use. Life cycle assessment can be an effective performance assessment tool, and because it is a systems approach to asses sment, it represents an improvement over less comprehensive techniques.

The SMM and other EPA programs are designed to help facilitate changes in the economics and practice of waste generation, handling, and disposal (e.g., by promoting market opportunitie s for beneficial use). The outcomes of the program, therefore, can be described as the changes in total environmental impacts that result from changes in beneficial use. Many of these impacts likely come from avoiding the production of virgin materials t hat would be used in the absence of industrial materials. In some cases, changes in materials use may also lead to (positive and negative) changes in processing, product performance, and disposal approaches. LCA can, given appropriate data and modeling s cenarios, describe the net impacts of all of these changes, and can, therefore, provide an assessment of program
results.



## Life Cycle Assessment and Economic Benefit Assessment As a tool for measuring physical impacts of system changes, LCA is a natural sta rting point in the assessment of the economic benefits of a program, but it is important to distinguish between LCA and economic benefits analysis. LCA is useful in the context of benefits analysis because it reflects a systems approach, allows measuremen t of changes to baseline conditions, identifies tradeoffs, and yields concrete, measurable metrics that can be evaluated both in isolation and comparatively, across programs and
activities.

However, while it can provide a clear assessment of beneficial ( and other) program impacts , LCA does
not itself measure the social benefits and costs of changes in practice, for two reasons. First, LCA provides a static examination of impacts based on a one

- time change to a system, and does not attempt to

measure net impacts over time, adjusting for long

- term market responses (e.g., changes in price and behavior) that can, in turn, affect the long

- term system operation. 48 

### Beneficial use of large

- volume CCP materials, such as fly ash and FGD gypsum, is already well

- esta blished. Therefore, gradual increases in use of these materials may have some impact on the large cement and gypsum markets in the U.S., but this analysis assumes that dramatic near

- term changes in the market are unlikely. Therefore, the impacts

estimate d by LCA are reasonable representations of total market impacts. However, if sudden , large

scale changes in production of raw materials occur as a result of SMM efforts, then a net economic impact analysis using methods like partial equilibrium analysis m ight be necessary.

Second, a complete assessment of the net economic benefits of a program requires the application of economic valuation techniques to the physical outputs of LCAs, in order to describe, in economic terms, what the physical outcomes impl y for human well

- being. For example, an LCA can describe changes in the quantity of water used or waste generated in a process, but is not designed to identify the specific effect of these impacts on well

- being. 49 

### While LCA impact assessment techniques ca n in some cases

48 For example, a beneficial use that has a significant impact on raw material demand (e.g., for virgin aggregate) and on electr icity demand may
ultimately affect the local prices of both energy and raw materials as demand for these commodities drops. The price changes could, in turn, result in other changes in practice (e.g., decisions on the part of other purchasers to buy more aggregate or changes in use patterns of
electricity). These impacts would likely have some impact on the net change in environmental impacts measured in the LCA.

49 LCA can incorporate impact assessments using a range of different methods that can, at a minimum, provide comparati ve descriptions of the
types of damage likely associated (or avoided by) the system change. However, valuation of specific impacts (e.g., health im pacts from air4

- 3



### provide general insights into typical impacts such as eutrophication or health risk, e conomic valuation of these changes often depends upon the specific location, timing, and quality of the water that is consumed or waste disposal that occu rs. The value of that water depends on how it would otherwise be used (e.g., for human consumption, industrial uses, habitat support, irrigation) and the “value” of the waste depends on the health risks it poses, release scenarios, and the people exposed. 50



### Ideally, LCA would be incorporated into a full

- scale analysis of net program benefits that would account for market responses and would value specific environmental impacts such as decreased releases of pollutants. Unfortunately, the translation of ph ysical changes into economic outcomes is typically costly, difficult, and often controversial when applied to human health or environmental outcomes. It frequently requires location

- specific data on releases and exposures, as well as well

- documented links between these exposures and health or environmental impacts. Assigning an economic value to even a small set of physical impacts can be a significant and expensive undertaking. 51



### Accordingly, LCA can represent not only a necessary ingredient, but also a p ractical initial alternative to a complete economic benefit assessment. While net economic benefits are often the target performance measure, it is necessary in many cases to rely on simpler proxies to facilitate management and performance assessment. As proxies, LCA outputs can represent a legitimate and defensible measure of program impacts. Therefore, we use LCA to investigate the measurable beneficial impacts associated with

SMM program achievements, using available LCA tools. A more detailed discuss ion of the role of LCA in economic benefits assessment is provided in Appendix C

.



## ASSESSMENT OF BENEFI CIAL IMPACTS OF CCP USE To fully capture the beneficial impacts of EPA’s efforts to increase beneficial use of CCPs , it would be necessary to model each beneficial use application of all CCPs targeted by the SSM . However, the time, data, and resources required to perform this task are beyond the scope of this report. For this preliminary analysis, we have selected two common CCPs, fly ash and FGD gypsum, which have well

- understood beneficial use applications and processes, and for which life cycle models and existing data are available.

We conducted a comprehensive review of available data sources and tools for assessing life cycle benefits
of beneficial use of these materials across all possible use applications. We identified four models that support specific evaluation of the environmental impacts of avoided virgin materials extraction in processes where CCPs are beneficially used in place of virgin mat erials:

 Building for Environmental and Economic Sustainability (BEES) was developed by the National Institute of Standards and Technology (NIST) with support from the U.S. EPA to allow designers, builders, and product manufacturers to compare the life cycl e environmental, and economic performance of alternative building products. 52 

### The BEES methodology measures

releases) requires modeling of specific exposure scenarios; LCA is designed specifically to a ddress systems without requiring unique location

specific information.

50 Hendrickson, Lave, and Matthews (2006) notes the limitation of LCA outputs that are not linked to specific locations and expo sures

- “A typical
[Life Cycle Inventory] of air pollutio n results in estimates of conventional, hazardous, toxic, and greenhouse gas emissions to the air. Even
focused on this small subset of environmental effects, it is unclear how to make sense of the multiple outputs and further ho w to make a
judgment as to tradeoffs or substitutions of pollutants among alternative designs.”

51 In the ecological realm, these kinds of translations are underdeveloped. The agency is aware of this ongoing limitation. Fo r example, this

conclusion has been drawn from several rece nt SAB reports, including EPA

- SAB. 2003. "Underground Storage Tanks (UST) Cleanup & Resource
Conservation & Recovery Act (RCRA) Subtitle C Program Benefits, Costs, & Impacts (BCI) Assessments: An SAB Advisory." (EPA

- SAB

- EC

- ADV

- 03

- 001)
and "Advisory on EPA' s Superfund Benefits Analysis." (EPA

- SAB

- ADV

- 06

- 002). In addition, the SAB Committee on Valuing the Protection of
Ecological Systems and Services is currently examining methods for addressing these limitations.

52 The BEES model and supporting documentatio n are accessible at http://www.bfrl.nist.gov/oae/software/bees.html.4

- 4



### environmental performance using an LCA approach, following guidance in the International Standards Organization 14040 series of standards for LCA. Th us, all stages in the life of the product are analyzed: raw material acquisition, manufacture, transportation, installation, use, and recycling and waste management. The BEES model is implemented in publicly available

decision

- support software, complete wi th actual environmental and economic performance data for a number of building products.

 SimaPro was developed by the Dutch company Pré Consultants and can be used to perform detailed lifecycle analyses of complex products and processes. SimaPro provides a high degree of modeling flexibility in that it provides data profiles representing thousands of materials production, transport, energy production, product use and waste management processes that can be combined to model very specific systems. Thus, Sim aPro relies on the user’s understanding of the various lifecycle stages and processes in the system being modeled. Results can be displayed as lifecycle inventory flows (e.g. energy use, water use and pollutant emissions (for a variety of pollutants includ ing the criteria pollutants). In addition, one of several impact assessment methods can be applied to characterize the environmental damages (e.g., global warming, eutrophication, etc.) associated with these flows.

 Pavement Life Cycle Assessment Tool for Environmental and Economic Effects (PaLATE)

is an Excel

- based tool developed by the Consortium for Green Design and Manufacturing at U.C. Berkeley for life cycle inventory 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. Based on user

- specified data on the type and quantity of initial construction materials, road construction equipment (e.g., asphalt paver), material transportation distances and modes, maintenance materials and processes, and off

- site processing equ ipment (e.g., rock crusher), PaLATE calculates twelve life cycle inventory flows including water and energy use, conventional air emissions (NOx, SO 2 

### , CO 2 

### , PM 10 

### , and CO), toxic air emissions (Pb and Hg), RCRA hazardous waste generation; and cancer and non

- cancer Human Toxicity Potentials. 53



###  The WAste Reduction Model (WARM) was created by EPA to help solid waste planners and organizations estimate greenhouse gas (GHG) emission reductions from several different waste management practices. WARM calculates GHG e missions for baseline and alternative waste management practices, including source reduction, recycling, combustion, composting, and landfilling. The user can construct various scenarios by entering data on the amount of waste handled by material type and by management practice. WARM then automatically applies

material

- specific emission factors for each management practice to calculate the GHG emissions and energy savings of each scenario. In addition, the model will convert these outputs to equivalent metr ics including the equivalent number of cars removed from the road in one year, the equivalent number of avoided barrels of oil burned, and the equivalent number of avoided gallons of gasoline consumed.

53 PaLATE does not allow for life cycle assessment of the inventory results, but in other life cycle models, impact assessment m ethods can be
applied to inventory results to estimate envir onmental damages.4

- 5



### All four models support life cycle assessment of vari ous CCPs. PaLATE, BEES and WARM all include life cycle inventory data to evaluate use of fly ash as a substitute for finished portland cement in concrete, and SimaPro supports evaluation of use of FGD gypsum in wallboard. We select BEES and SimaPro to
eval uate fly ash and FGD gypsum beneficial use because these models have been peer

- reviewed and evaluate a large suite of environmental metrics. 54 

### In contrast, PaLATE has not undergone a formal peer review process, and WARM evaluates only energy use and greenho use gas metrics. For comparative purposes, however, we present the results of a WARM analysis of the use of fly ash in concrete in Appendix D

. 55



### In addition to BEES and SimaPro, the U.S. Economic Input

- Output Life Cycle Assessment (EIO

- LCA) model provides a n alternative approach for measuring the avoided upstream impacts of recycling. EIO

LCA was developed at Carnegie Mellon University and provides the capacity to evaluate economic and environmental effects across the supply chain for any of 491 industry se ctors in the U.S. economy. EIO

LCA also can represent the supply chain use of inputs and resulting environmental outputs across the supply chain by using publicly available data sources from the U.S. government. By integrating
economic data on the existi ng flow of commerce between commodity sectors with environmental data on releases and material flows generated by each sector, it is possible to estimate the additional environmental emissions caused by an increase in production within a particular sector, accounting for changes in the supply chain. This approach can be used to provide insight into the sectors of the economy that drive the environmental impacts of a given process, and shed light on the specific impacts of particular policy efforts. While it is very helpful in examining the distribution of impacts across economic sectors, the EIO

- LCA is not optimal for a specific life cycle assessment of beneficial use of FGD gypsum in wallboard because the life cycle impacts are modeled at the sector level and do not provide the same process

- level resolution that can be estimated for various use applications using
SimaPro. EIO

- LCA is more useful for modeling use of fly ash in concrete, as it includes data for a fairly homogenous cement sector. It is also im portant to note that EIO

- LCA is a dollar

- based model and thus, is not directly comparable to the BEES/SimaPro data that is presented in tons. Appendix D describes supply chain manufacturing impacts for cement and gypsum production modeled using EIO

- LCA.



## ME THODOLOGY FOR EVALUA TING UNIT IMPACTS OF BENEFICIAL USE We conduct separate analyses to evaluate the incremental environmental impacts associated with beneficially using a specific quantity (i.e., one ton) of fly ash and FGD gypsum. We employ:

 BEES to inv estigate using one ton of fly ash as a substitute for finished portland cement in concrete; and

 SimaPro to investigate using one ton of FGD gypsum as substitute for virgin gypsum in

wallboard.

While it is not optimal to use two different models in a single analysis, in this case we employed the BEES tool to be consistent with previous analyses of beneficial use of materials in other reports; BEES does not address gypsum. This analysis is designed to examine the general magnitude of potential

54 BEES has reliable data for the use of fly ash in concrete, but it does not evaluate use of FGD gypsum in wallboard. SimaPro does allow evaluation
of both fly ash and FGD gypsum but we prefer the U.S.

- based data in BEES to conduct the f ly ash analysis. For this reason, we do not use the same
model for both analyses.

55 The PaLATE model was used to evaluate beneficial use of fly ash in previous iterations of this report, but we omit the PaLATE analysis from this

version in order to avoid c omparisons of peer reviewed model findings to non

- peer reviewed model findings for CCPs. It is important to note,
however, that PaLATE relies on much of the same LCI data as the EIO

- LCA model, which is presented in Appendix C.4

- 6



### environmental impacts, and the use of SimaPro for specific materials not addressed in BEES provides additional insights into the potential impacts of beneficial use of CCPs.

The first step in evaluating the life cycle impacts of beneficial use of fly ash and FGD gypsu m is development of environmental impact profiles for use of one ton of each material as a substitute for portland cement in concrete and for virgin gypsum in wallboard, respectively. One ton was selected as the

unit

- basis for these analyses because the im pacts can then easily be extrapolated to current use quantities, which are reported by ACAA in tons. In addition, by developing life cycle benefits profiles for use of a consistent quantity of each material, the impact profiles of specific materials can be compared with each

other.

The calculation of unit impact values for fly ash and FGD gypsum are described in greater detail below. To the extent possible, we attempt to use comparable assumptions and life cycle system boundaries in both analyses. We ex press beneficial use quantities in short tons (consistent with EPA and ACAA), but report impacts in metric units, consistent with BEES and SimaPro results.



## BEES Analysis of Use of Fly Ash in Concrete BEES includes environmental performance data for a numbe r of concrete products (e.g., concrete columns, beams, walls, and slab on grade). The user can compare the environmental performance data of each of these products using different pre

- determined concrete mix

- designs, some of which include fly

ash. The BE ES environmental performance data serve as 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 co ncrete. BEES quantifies these flows for hundreds of environmental metrics, but to capture the general spectrum of impacts, we focus on the following:

 Total primary energy use (MJ);

 Renewable energy use (MJ);

 Nonrenewable energy use (MJ);

 Water use (liters );

 Atmospheric emissions (CO 2 

### , methane, CO, NOx, SOx, particulates, Hg, Pb) (grams);

 Waterborne waste (suspended matter, biological oxygen demand, chemical oxygen demand, Hg, Pb, selenium; and

 Nonhazardous waste (kg).

As an example of the LCA approach, we assess the beneficial environmental impacts of using fly ash to offset virgin cement inputs in a concrete beam with a compressive strength of 4 KSI (4,000 psi) and a lifespan of 75 years. It is important to note that this concrete product was selected to r epresent use of fly ash in any generic concrete application; the unit impact values do not reflect any assumptions specific to the life cycle of a concrete beam in BEES. 56 

### Furthermore, any concrete building product data set could

56 All concrete building prod uct data in BEES (e.g., concrete columns, beams, walls, and slab on grade) use a 75

- year lifespan assumption.
Calculating unit impact values using data from any one of these products yields the same values. In addition to life cycle in ventory data for

conc rete building products, BEES also includes data for a concrete parking lot pavement. The concrete parking lot data, however, use a 30

- year lifespan assumption; calculating unit impact values using pavement data yields values that are approximately 2.5 time s greater than the values
calculated from building product data because the pavement data assume a 2.5 times shorter lifespan than building products.4

- 7



### have been used without cha nging the unit impact value. For further details on the life cycle inventory data used in this analysis, refer to Appendix E

. The benefits of fly ash use are measured as the difference in environmental impacts between a baseline

scenario and a beneficial u se scenario. In the baseline scenario, a one cubic yard 4 KSI concrete beam is produced using 100 percent portland cement. In the beneficial use scenario, a one cubic yard 4 KSI concrete beam is produced using 15 percent coal fly ash and 85 percent portla nd cement. 57

, 58 

### The difference in environmental impacts between the baseline and beneficial use scenarios represents the change in impacts from substituting 15 percent of the portland cement with fly ash in one cubic yard of 4
KSI concrete. We translate the se impacts from a cubic yard concrete basis to a ton fly ash basis by dividing the impacts by the absolute quantity of fly ash in one cubic yard of the concrete product. For an illustration of this methodology, refer to Appendix E

. 

## SimaPro Analysis of FGD Gypsum in Wallboard We calculate the unit impacts of using FGD gypsum in place of virgin gypsum stucco in wallboard as the difference in impacts between wallboard made with 100 percent virgin gypsum and wallboard made with

100 percent FGD gypsum. We model these impacts as one ton of avoided “stucco” manufacture in

SimaPro. 59 

### Stucco is the term used in SimaPro to describe the gypsum material used in wallboard. We
selected the EcoInvent v2.2 data set because it includes gypsum mining but also includes the pro cessing of gypsum for use in wallboard (i.e., burning of gypsum and milling of stucco for use in gypsum wallboard). Thus, this dataset includes all the processes that would be avoided if an equivalent quantity of FGD gypsum were used in place of stucco in wallboard. The production of FGD gypsum from coal combustion is not modeled, as discussed in the following section on allocation of life cycle impacts to FGD gypsum. In addition, this analysis assumes that FGD gypsum dewatering occurs via holding ponds

and that the environmental impacts of dewatering are negligible. 60 

### This analysis also does not model transport distance; we assume FGD gypsum would have the same transport distances to the construction site as virgin gypsum. 61 

### Thus, avoided gypsum mining and a voided processing of gypsum into stucco, as represented by the EcoInvent stucco manufacturing data set, are the only lifecycle stages modeled in SimaPro. Appendix E provides more information on the FGD gypsum analysis.



## Allocation of Life Cycle Impacts to C CPs As EPA programs evolve to emphasize both beneficial use of industrial materials and life cycle

assessment approaches to evaluating these programs, it is important to consider upstream impacts of the processes that create beneficial use materials, inclu ding, in this case, the impacts of the electrical power generation industry that produces CCPs for beneficial use.

57 Fly ash replaces portland cement in concrete in a one to one ratio based on mass.

58 Both the concrete beam made with and without blended cement assume a 60

- mile round trip transport distance for portland cement and fly ash

and a 50

- mile round

- trip transport distance for aggregate to the ready

- mix concrete plant.

59 We use the EcoInvent data set titled “Stu cco, at plant/CH U” for this purpose.

60 There may actually be emissions/dusting impacts associated with dewatering in a holding pond, but we have been unable to iden tify quantified
estimates of these impacts. Alternatively, dewatering may be accomplished t hrough mechanical processes but we were also unable to identify the
energy impacts of mechanical dewatering.

61 We do not model a transport differential between virgin and FGD gypsum to be consistent with the transport assumptions used i n the BEES fly ash
analysis, which helps preserve the comparability of the fly ash and FGD gypsum unit impact values. It is important to note, h owever, that an
increasing number of new gypsum wallboard plants are being constructed adjacent to coal

- fired power plants, so the transport distance of FGD
gypsum to the wallboard manufacturing facility may, in some cases, be less than the transport distance of virgin gypsum.4

- 8



### The beneficial use of CCPs has positive environmental and energy impacts relative to landfilling and virgin material production. Considerati on of the negative upstream impacts of electricity production through "allocation" does not actually reduce the beneficial impacts of beneficial use, nor does it "create" negative impacts. Instead, it represents a quantitative way of identifying the extent to which CCPs are associated with the generation of coal

- fired power and are not an environmentally “free” product.

Analysis of life cycle impacts is, in its simplest form, the calculation of all impacts associated with a single production system (e.g., t he manufacture of paper, or the production of energy using coal). 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 LCA to recognize tha t these products are associated with environmental impacts, and to allocate the total life cycle production impacts across these products. 62 

### Several methods for allocation are possible, depending on the system(s), inputs, and the quantity and value of co

- p roducts. Simple methods include allocating impacts proportionately by total mass or by market value; more complex methods may be necessary when integrated systems use different types of inputs or produce a range of products with different features and env ironmental profiles.

Waste is not considered a co

- product, and it is, therefore, generally unnecessary to allocate specific production impacts to materials that are destined for disposal (disposal impacts are allocated 100 percent to the producing industry ). However, when an industrial material becomes a beneficial use material and
ceases to be considered a waste , it reflects a market value. It is, therefore, a co

- product, though typically a very low

- value one when compared to the primary products of the industry (in this case, electricity). It is important to consider whether co

- products of electricity generation (such as fly ash and FGD gypsum) that are beneficially used should have some portion of the production impacts associated with coal

combustion (e.g., energy use, greenhouse gas equivalents, releases to air and water) attributed to them. 63



### In Appendix E , we provide an illustration of a potential approach for allocating the environmental and energy impacts from coal

- fired power generation across el ectricity generation and CCPs. The analysis considers some hypothetical macro

- level scenarios for coal

- fired power generation, as well as macro

- level flows of several key CCPs. The preliminary analysis in Appendix E is designed to assess the implications of allocating the environmental effects of power generation to both the energy product and the CCPs. Using both an economic and a mass

- based approach, we find that the only small flows would be allocated to the CCPs relative to the impacts of electricity production (i.e. less than one percent in the case of mass

based allocation).

At this time the majority of CCPs are still disposed. In addition, the small environmental impacts allocation indicated by our preliminary analysis in Appendix E , and the high uncertainty associated with fuel sources, prices of electricity generation, and CCP prices limit the use of any illustration of allocation options. Therefore , we do not currently include either an economic or mass

- based allocation of coal combustion impa cts to fly ash or FGD gypsum into this analysis. However, to fully understand the potential impacts of beneficial use on coal combustion, and to fully characterize the benefits associated with beneficial use, it may be important to assess these potential impacts under various analytical
scenarios as EPA's policies and programs evolve

.

62 A discussion of general principals for allocation is presented in the International Standard on Environme ntal Management

— Life Cycle Assessment

— Goal and scope definition and inventory analysis (ISO 14041:1(E)), pp.11

- 12, and Annex B.

63 It is important to stress that allocated impacts are not actual impacts associated with the beneficial use of the materials; in most cases use is
significantly more beneficial than disposal. Instead, allocation is a means of placing the beneficial use materials in the co ntext of their original
production and recognizing that the processes that produce these byproducts may incur environmental costs.4

- 9



### One reason to consider allocation, even hypothetically, is to consider the potential impact of policies on
both economic and environmental outcomes. Typically, as with fl y ash and FGD gypsum, the economic value of beneficial use materials is small in comparison to the value of primary products of the producing industries. However, it is conceivable that significant increases in the value of beneficial use materials
could alter the economics of the producing industries. While it is unlikely that any industry would alter production to increase production of beneficial use materials, demand for these materials could improve the cost structure of certain industrial processes. For example, increased demand for CCPs could improve
the cost structure for coal

- fired power plants and improve their competitive position in energy markets. 64


### As beneficial use and the economic value of various industrial materials increases, it becomes

in creasingly important to accurately account for the processes that produce the materials as well as the processes that use them.



## RESULTS For both the baseline and beneficial use scenarios, BEES and SimaPro generate quantitative estimates of impacts for a su ite of environmental metrics. For each metric, environmental outputs under the baseline and beneficial use scenarios represent life cycle impacts of replacing virgin materials with CCPs. Where this difference is positive, the impact is an environmental ben efit of using CCPs in place of virgin materials. Where the difference is negative, use of CCPs suggests a decline in environmental quality.

Exhibit 4

- 1 presents the results of the analyses of use of fly ash in concrete and use of FGD gypsum in
wallboard.

64 An example of a system in which dramatic changes in co

- product value have driven production changes is the recent change in demand for
ethanol, which has resulted in a significant increase in demand for agricultural by

- products and has altered production decisions to meet this new

demand.4

- 10

EXHIBIT 4

- 1: LIFECYCLE ASSESSMENT OF POTENTIAL IMPACTS OF CCP BENEFICIAL US E

AVOIDED IMPACTS PER 1 TON FLY ASH AS PORTLAND

CEMENT IN CONCRETE PER 1 TON FGD GYPSUM IN

WALLBOARD

ENERGY USE

NONRENEWABLE ENERGY (MJ) a 5,361.70 1,319.69

RENEWABLE ENERG Y (MJ) b 0 14.56

TOTAL PRIMARY ENERGY (MJ) c 5,361.70 1,334.25

TOTAL PRIMARY ENERGY (US$) d 23.59 21.67

WATER USE

TOTAL WATER USE (L) 689.36 88,973.02

TOTAL WATER USE (US$ ) e 0.44 67.39

GREENHOUSE GAS EMISS IONS

CO 2 (G) 995,744.68 78,830.56

METHANE (G) 842.55 171.71

AIR EMISSIONS

CO (G) 1,378.72 38.04

NOX (G) 2,680.85 152.43

SOX (G) 2,451.06 192.01

PARTICULATES GREATER THAN PM 10 (G) 0.00 1,209.24

PARTICULATES LESS TH AN OR EQUAL TO PM 10 (G) 7.66 472.58

PARTICULATES UNSPECI FIED (G) 2,374.47 0.00

MERCURY (G) 0.08 0.00

LEAD (G) 0 0.03

WATERBORNE WASTES

SUSPENDED MATTER (G) 490.21 12.63

BIOLOGICAL OXYGEN DE MAND (G) 22.98 23.11

CHEMICAL OXYGEN DEMA ND (G) 45.96 24.14

COPPER (G) 0.00 0.00

MERCURY (G) 0.00 0.00

LEAD (G) 0.00 0.01

SELENIUM ( G) 0.00 0.01

NONHAZARDOUS WASTE ( KG) f 0.00 0.004

- 11 AVOIDED IMPACTS PER 1 TON FLY ASH AS PORTLAND

CEMENT IN CONCRETE PER 1 TON FGD GYPSUM IN

WALLBOARD

Notes:

a. Nonrenewable energy refers to energy derived from fossil fuels such as coal, natural gas and oil.
b. Renewable energy refers to energy derived from renewable sources, but BEES does not specify wha t sources these include.

c. Total primary energy refers to the sum of nonrenewable and renewable energy.
d. We monetize energy impacts for fly ash using a price figure ($0.0044/MJ) derived from the average price of purchased energy
to the cement manufact uring sector in 2006 ($4.36/million BTU), from Table 7.2, accessed on Nov. 16, 2010 at http://www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, acc essed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html. We monetize energy impacts for FGD Gypsum using a price/MJ figure ($0.0179/MJ), derived from the average cost of diesel fuel in 2009 ($2.467/gallon), assuming 130,500 BTUs/gallon of dies el fuel. Diesel price is 2009 weekly price of on

- highway diesel accessed on April 22, 2010 at http://tonto.eia.doe.gov/dnav/pet/pet_pri_gnd_dcus_nus_a.htm; diesel energy value accessed April 22, 2010 at http://bioenergy.ornl.gov/papers/misc/energy_conv.ht ml.

e. We monetize water impacts using the average cost of water in 2008 ($2.81/KGal) converted to 2009 dollars ($2.87/KGal). The 2008 cost of water is taken from NUS Consulting Group, accessed on April 22, 2010 at http://www.marketwire.com/press

release/ Average

- US

- Water

- Costs

- Increase

- by

- 73

- 903477.htm. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html.
f. BEES reports waste as “en d of life waste.” In contrast, SimaPro reports “solid waste.” In is not clear if these waste metrics are directly comparable as SimaPro does not specify whether “solid waste” refers to manufacturing waste, end

- of

- life waste, or both.



### As shown in Exhibit 4

- 1, the results of the fly ash and FGD gypsum analyses suggest many positive environmental impacts associated with beneficial use. For most metrics, there is a significant difference between the unit impact value for fly ash and FGD gypsum. The differen ce in unit impact values reflects different avoided processes when fly ash is used to offset portland cement versus when FGD gypsum is used to offset virgin gypsum. For example, the primary driver of benefits when fly ash is used in concrete
is avoided raw materials extraction and avoided portland cement production. 65 

### In comparison, the primary driver of benefits when FGD gypsum is used in wallboard is avoided virgin gypsum extraction and the processing of virgin gypsum into stucco. Portland cement productio n generates relatively high greenhouse gas emissions. Thus, the avoided CO 2 

### and methane emissions are greater for fly ash than for FGD gypsum in this analysis. In contrast, gypsum mining requires comparatively higher quantities of water, so
the water savin gs are greater for FGD gypsum in this analysis than for portland cement.

In addition, the difference in unit impacts may reflect differences in the assumed system boundaries between the two analyses. It is unclear how the BEES system boundaries compare to SimaPro. Thus, the total life cycle impacts calculated in BEES could be large or small in comparison to the system boundaries in the SimaPro FGD gypsum analysis.



## LIMITATIONS AND ASSU MPTIONS Although the BEES analysis provides a useful example of the benef its that can be achieved through beneficial use of fly ash in concrete, it is important to recognize some of the key limitations and assumptions of the work to date:

 The BEES model may over or underestimate the national impacts of using fly ash in concrete construction projects because site

- specific environmental conditions and proximity to sources of fly ash may affect the resulting benefits and influence the net effect of choosing fly ash over portland cement.

65 It is unclear from the documentation provided for BEES what impacts (e.g. virgin materials extraction, plant infrastructure, etc.) are modeled for
portland cement production. For this reason, it is not possible to explain the differences in unit impact results between the FGD gypsum and fly
ash analysis.4

- 12



###  BEES assumes round

- trip distances for the tra nsport of concrete raw materials to the ready

- mix plant of 5 0 miles for portland cement and fly ash and 50 miles for aggregate. This analysis also assumes the minimum possible transport distances for the finished concrete products to the

construction site. This transport distance for ready

- mix concrete for a pavement application is 50

miles.

 BEES environmental results are reported in physical quantities (e.g., MJ energy, liters water, g CO, g NO, g Hg, etc.), not in monetized terms.

 In BEES, the calculatio n of each environmental impact is not fully transparent. BEES does disaggregate the total life cycle impact value for each environmental metric (e.g., energy use, CO 2 

### emissions, etc.) by lifecycle stage and by product component, but it is not possible to s ee exactly how each impact is derived. This limits the user’s ability to compare the results of the BEES
model with those of others models, such as SimaPro.

 The FGD gypsum analysis is based on a Swiss life cycle inventory data. While we substituted

Swiss electricity data with the average U.S. energy mix, it is unclear whether the average U.S. energy mix is an accurate representation of the electricity mix used in wallboard manufacturing. Given the recent trend in new wallboard facilities being constructed adjacent to coal

- fired powered plants, it is possible that these facilities use primarily coal

- based electricity. With the exception of energy mix, it is unlikely that any other differences between European and U.S. gypsum extraction and stucco processing would result in meaningful differences in environmental impacts.

 The FGD gypsum anal ysis assumes that dewatering of FGD gypsum is accomplished through evaporation in holding ponds. To the extent that the predominant practice is to use mechanical dewatering processes, the analysis should be modified to reflect this. The assumption of

dewat ering via holding ponds likely overstates the energy and energy

- related emissions impacts in this analysis, since the impacts of dewatering, which are subtracted from the avoided gypsum processing impacts, would be greater for mechanical dewatering than fo r holding pond evaporation.5

- 1



# CHAPTER 5: ESTIMATI NG PROGRAM LEVEL IMP ACTS

This chapter provides an overview of an initial, life

- cycle based approach to evaluating program level impacts associated with the SMM effort to increase beneficial use of CCPs. The chapter first outlines two critical steps necessary for a complete evaluation of specific program impacts:

 Development of defensible beneficial use scenarios that reflect likely market trends, policy efforts, and key limitations; and

 Implementation of a w ell

- supported attribution protocol for assigning beneficial use impacts to specific EPA programs.

This discussion is followed by a preliminary analysis of the total impacts associated with current (baseline) beneficial use patterns, based on an extrapola tion of the life cycle inventory impacts identified in Chapter 4. The purpose of this chapter is to present an initial estimate of the measurable impacts associated with current levels of beneficial use of CCPs, and to outline the steps necessary to provi de a refined, program

- specific analysis of EPA's efforts through the SMM to increase beneficial use of CCPs.



## DEVELOPMENT OF DEFEN SIBLE BENEFICIAL USE SCENARIOS Life cycle inventories (LCI) and LCA provide comprehensive information on the impacts associated with given quantities of materials used in specified systems. The impacts measured by LCA models are typically linear; as the quantity of CCPs used in a particular application (e.g., concrete) is increased, the environmental impacts increase proportionat ely.

While LCA can provide insights into the potential magnitude of program benefits, in some cases existing market limitations and trends suggest that a linear extrapolation of current practices would be unrealistic. An effective assessment of true progr am impacts requires the development of defensible market scenarios that accurately identify the extent to which different beneficial uses are likely to increase, given the realities of the existing and emerging markets for beneficial use and the structure of SMM programs.



## Current Market Dynamics: Factors Affecting Beneficial Use Several market factors can limit the increased beneficial use of CCPs in various products. In some cases programs can be designed to address these factors effectively. Exhibit 5

- 1 outlines several of these factors and presents hypothetical actions that might address them. It is important to note that the actions described below are intended only to illustrate possible conditions for increasing the beneficial use of CCPs; they do not represent specific policy recommendations or existing program priorities.

EXHIBIT 5

- 1: LIMITING FACTORS TO INCREASED BENEFICIAL USE OF CCP s

FACTOR TYPE FACTORS AFFECTING

INCREASED BENEFICIAL USE HYPOTHETICAL ACTIONS

TO INCREASE BENEFICIAL USE

Economic Transportation costs generally limit the shipment of

CCPs to within about a 50 to 150 mile radius of power plants. In some cases, however, the cost of transport to the end user may be prohibitively expensive. Implementation of str ategic actions to create incentives to increase beneficial use by shifting the economic drivers (i.e., cost of materials) in favor of CCPs. Potential incentives could include tax credits for the use of CCPs, increased CCP landfill disposal tipping fees, o r streamlining the permitting process for facilities that use CCPs near coal combustion plants (e.g., FGD gypsum plants). In some parts of the country and for certain use applications, the cost of virgin materials may be cheaper than CCPs.5

- 2

FACTOR TYPE FACTORS AFFECTING

INCREASED BENEFICIAL USE HYPOTHETICAL ACTIONS

TO INCREASE BENEFICIAL USE

Inexpensi ve landfill disposal can limit incentive to sell rather than dispose of CCPs.

Institutional National standards organizations have promulgated

specifications that limit or disallow the use of CCPs in some construction applications because of quality and

p erformance concerns and perceptions. State DOTs rely on consensus standards for guidance and generally accept the use of fly ash in concrete. DOT projects can be used to demonstrate the performance of CCPs in geotechnical applications.
The implementation of the U.S. Clean Air Mercury Rule (CAMR) may result in altering the chemical properties of fly ash, rendering it unmarketable for beneficial

use.

Similar impacts may also occur for fly ash containing higher levels of unburned carbon or other components resulting from installation of low

- NOx burners at coal

based power plants. Establishment of a research and development infrastructure to address the technical limiting factors to CCP use.

Provide technical and/or economic assistance to utilities using l ow

- NOx burners to identify and implement cost

- effective process modifications or new equipment to reduce the carbon content of fly ash.

Technical Lack of consistency and quality in the production of fly

ash has resulted in limited use in the high

- value re ady

mix concrete market. The priority at a coal

- fired power plant will always be on producing electricity, not ash. A change in the combustion process, such as the type of coal burned, results in a change in ash quality, making it difficult to produce a co nsistent product. Taking into account the power plant’s priority of generating electricity, the program could facilitate formal training programs to teach plant operators about the co

- product value of producing consistent

- quality fly ash.

Educational Whil e quality and consistency of fly ash are legitimate

concerns of end

- users, in some cases, negative perceptions toward CCP use are unwarranted. Negative perceptions can often be attributed to a single experience using CCPs in a project that failed, even if CCPs were not the cause of the failure. For example, at one time, the Austin, TX concrete market almost turned to an all

- cement market because of one misuse resulting from a lack of education about the material. Dissemination of objective, scientific mat erial to educate potential end users. (EPA has addressed this through C 2 P 2 and other activities).

Sources : 1. U.S. Department of Energy, National Energy Technology Laboratory, “General Summary of State Regulations,” accessed at http://www.netl.doe.gov/E&W R/cub/states/select_state.html.
2. Energy and Environmental Research Center, “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

-- 7 9, July 1999.
3. ACAA, 2008, “Frequently Asked Questions,” accessed Nov. 19, 2010 at http://acaa.affiniscape.com/displaycommon.cfm?an=1&subarticlenbr=5.
4. Schwartz, Karen D. “The Outlook for CCPs,” Electric Perspectives, July/August 2003.
5. Energy & Environmental Research Center, University of North Dakota, “ Review of Florida Regulations, Standards, and Practices Related to the Use of Coal Combustion Products: Final Report,” April 2006 , accessed at http://www.undeerc.org/carrc/Assets/TB

FLStateReviewF inal.pdf.
6. Energy & Environmental Research Center, University of North Dakota, “ Review of Texas Regulations, Standards, and Practices Related to the Use of Coal Combustion Products: Final Report,” January 2005 , accessed at http://www.undeerc.org/carrc/As sets/TXStateReviewFinalReport.pdf.



### Exhibit 5

- 1 outlines a number of economic and non

- economic factors that may limit the increased
beneficial use of CCPs . The economic factors primarily relate to transportation costs and the price of virgin materials; a critical limitation of the market for CCPs may be the regional nature of the coal

burning industry and the extent to which CCPs can find viable markets competing with virgin materials within an economically viable distance.5

- 3



### Several of the non

- economic issu es presented in Exhibit 5

- 1 may also limit the expansion of CCP beneficial use, if, for example, new uses and new markets require changes in state policies governing CCP use. In response, targeted efforts among states to harmonize policies regarding benef icial use of CCPs could result in expansion of certain uses of CCPs.

To effectively describe impacts associated with SMM programs and goals, it is important to develop scenarios that correctly identify the limits of existing markets, and calculate the quan titative impact on the use of CCPs in different applications. In addition, scenarios should incorporate SMM priorities in order to better predict which uses and markets are likely to expand. At this time, data on market limitations and on program priorit ies and goals are not refined enough to inform a detailed program analysis. However, spatial information about coal

- fired power plants and new data on emerging markets may be sufficient to support an analysis in the near future. The result could be a set of scenarios that pinpoints specific uses for CCPs that are likely to grow and notes regional and national limits for certain applications.



## Structural Changes to the Market In addition to changes related to market trends and program activities, beneficial use scenarios must, in some cases, reflect significant changes to the market, such as large

- scale technology shifts that might affect demand for or production of CCPs. In addition, for materials frequently used in construction, unexpected events such as large storms or terrorist attacks may result in sudden, regional changes in demand if, for example, large quantities of materials are needed for reconstruction or if coal

- fired power plant operations change significantly as a result of a regional event.

Since these events are by definition unpredictable, it is important to identify methods for analyzing impacts if and when they occur. In particular, analyses that clearly identify the current regional market conditions (e.g., oversupply, strong demand) wo uld provide a useful starting point for analysis of unexpected market shifts.



## ATTRIBUTION OF IMPAC TS TO EPA PROGRAMS The factors affecting increased beneficial use also link to the issue of attributing changes in beneficial use markets or behavior to speci fic EPA initiatives. The issue of attribution is complex, and in many cases the data necessary to support a clear attribution of impacts are not available. Particularly in the case of voluntary programs, it is often difficult to attribute changes in behav ior (or a proportion of the change in behavior) to specific EPA activities. For example, changes in recycling or source reduction may be due to outside forces (i.e., market dynamics), multiple government programs, or a combination of both.

One starting point in addressing the attribution of benefits to EPA activities is an examination of existing information and methods describing the performance of target EPA programs and overall trends in beneficial use. Linking program activity with market trends can , on a qualitative basis, provide an indication of whether the program is having an effect. This initial scoping exercise can then be supplemented with the development of specific program scenarios that endeavor to quantify incremental
beneficial use leve ls attributable to EPA's initiatives. In other cases, it may be necessary to start with the assumption that all costs and all benefits are related to EPA activities, and adjust that assumption as programs mature and data become available.5

- 4



### A full

- scale, d efensible approach to attribution of voluntary program impacts, however, requires a clear understanding of both the specific activities undertaken by the program and the differences between behavior of program participants and those who do not participate. This information can sometimes be obtained or identified through broadly collected data that includes both participants and non

- participants (e.g., the Biennial Report or the Toxics Release Inventory). In other cases, behavioral research can help predic t effective response rates to different types of programs. Exhibit 5

- 2 outlines the process for a full

scale assessment of attribution.

EXHIBIT 5

- 2: OUTLINE TO ATTRIBUTE VOLUNTARY PROGRAM IM PACTS

STEP 1: ASSESS THE MARKET FAILURE BEING ADDRESSED

 Identify and describe specific market failure of interest Example: material with market value being disposed as waste

 Evaluate size of market failure: evaluation of total quantity affected, current recovery and management, potential economically feasible recovery

 Identify key behavior changes necessary to address market failure

 Identify programs in place to address market failure, including Federal, State, local, and private efforts.

STEP 2: DESCRIBE IN DETAIL EACH EPA PROG RAM WORKING ON THE “ ISSUE”

 Summarize pro gram goals, structure, policy leverage points using program evaluation methodologies.

 Identify, for each relevant program, current and intended participants, key resources available, actions taken by participants, timeline for behavioral change, and link b etween activities and behavioral change.

STEP 3: IDENTIFY AV AILABLE DATA ON EPA AND OTHER EFFORTS

 Quantitative estimates of recent trends in target behavior, specific estimates of recent changes in behavior among EPA program members and non

- members, and research on response rates for similar programs, strategies.

STEP 4: ATTRIBUTION OF IMPACTS TO EPA PR OGRAM(S)

 Refine analysis of data collected in Step 3 to identify changes in behavior among EPA program participants and
among non

- members, expected lever age of EPA activities across federal, state, private programs (e.g., by expansion of recycling efforts from pilot programs or harmonization of state regulations as a result of EPA information development), and expected leverage of EPA activities over time.

 Identify and correct for independent, confounding market changes that may affect the issue, such as changes in virgin raw materials prices due to sudden shortage.



### The result of this approach should yield a quantitative estimate of the total extent of ch anges that can be attributed to EPA. Where implementation and/or tracking data are not available, approaches can potentially include theoretical estimates reflecting literature on response rates for voluntary activities. As necessary, this effort can als o provide information to effectively allocate total EPA impacts across multiple programs in cases where more than one program is focused on addressing the same market failure. In areas where the attribution of outcomes is not possible due to data and metho dological limitations, program structure and purpose can be revisited with the intent of developing metrics (e.g., for PART analysis) that are meaningful in measuring change without attempting to achieve a simplistic
success metric of “outcome/resources.”

In the absence of specific information on behavior changes among participants and non

- participants in

SMM beneficial use activities, we focus below on total impacts associated with CCP beneficial use. This forms an upper bound estimate of the impact of EP A programs related to these materials, but may understate total beneficial impacts because not all materials are considered.5

- 5



## BENEFICIAL IMPACTS A SSOCIATED WITH CURRE NT USE OF CCP s
In the absence of defensible beneficial use scenarios for CCPs or a well

- su pported allocation protocol for assigning beneficial use impacts to specific EPA programs, we present a preliminary analysis of the total impacts associated with current (baseline) beneficial use patterns. While these impacts do not strictly

reflect SMM ( RCC) program achievements, they represent the best available information on the environmental benefits of beneficially using CCPs, and reflect the impacts of all EPA, state, and industry
efforts to increase CCP use to its 2008 level.

We calculate the benef

icial impacts of current beneficial use of CCPs by extrapolating the life cycle inventory impacts identified in Chapter 4 to the current quantity of CCPs beneficially used in each application as presented in ACAA’s 200 8 CCP Survey. We also calculate the be neficial impacts of

increas ing fly ash use in concrete to 18.6 million tons , an increase of roughly half over the 2001 baseline
of 12.4 million tons

. Exhibit 5

- 3 presents the impacts of the beneficial use of fly ash and FGD gypsum extrapolated both to curr ent use quantities and the 50

- percent increase scenario for use of fly ash in

concrete.5

- 6

EXHIBIT 5

- 3: EXTRAPOLATED IMPACTS OF THE BENEFICIAL US E OF CCP s

AVOIDED IMPACTS FLY ASH IN

CONCRETE

EXTRAPOLATED

TO 18.6 MILLION

TONS a FLY ASH IN

CONCRETE

EXTRAPOLATED TO
CURRENT USE ( 12.6
MILLION TONS) b FGD GYPSUM IN

WALLBAORD

EXTAPOLATED TO
CURRENT USE (8. 5
MILLION TONS) c PARTIAL SUM OF

CURRENT USE

BENEFICIAL

IMPACTS d

ENERGY USE

NONRENEWABLE ENERGY (MJ) e 99.7 billion 67.5 billion 11.3 billion 78.8 billion

RENEWABLE ENERGY (MJ) f 0 0 124.2 million 124.2 million

TOTAL PRIMARY ENERGY (MJ) 99.7 billion 67.5 billion 11.4 billion 78.9 billion

TOTAL PRIMARY ENERGY (BTU) 95 trillion 64 trillion 12 trillion 76 trillion

TOTAL PRIMARY ENERGY (US$) g 438.8 million 297.1 millio n 184.9 million 482 million

WATER USE

TOTAL WATER USE (LIT ERS) 12.8 billion 8.7 billion 759.3 billion 768 billion

TOTAL WATER USE (US$ ) h 8.1 million 5.5 million not valued >5.5 million

GREENHOUSE GAS EMISS IONS

CO 2 (MT) 18.5 million 12.5 million 703,4 84 13.2 million

METHANE (MT) 15, 700 10,6 0 0 1, 500 12, 1 0 0

METRIC TONS CO 2 EQUIVALENT i 18.8 million 12.8 million 703,484 13.5 million

METRIC TONS CARBON E QUIVALENT (MTCE) j 5.1 million 3.5 million 191,859 3.7 million

AIR EMISSIONS

CO (MT) 25,6 00 17, 400 3 0 0 17, 700

NO x (MT) 49, 900 33, 800 1,30 0 35, 10 0

SO x (MT) 45, 600 30, 900 1,6 00 32,50 0

PARTICULATES GREATER THAN PM 10 (MT) 0 0 10,3 00 10,3 00

PARTICULATES LESS TH AN OR EQUAL TO PM 10 (MT) 1 00 100 4,0 00 4,1 00

PARTICULATES UNSPECI FIED (MT) 44, 200 29,900 0 29,90 0

MERCURY (KG) 1,4 00 1,000 8 1,000

LEAD (KG) 0 0 300 300

WATERBORNE WASTES

SUSPENDED MATTER (KG ) 9.1 million 6.2 million 0.1 million 6.3 million

BIOLOGICAL OXYGEN DE MAND (KG) 0.4 million 0.3 million 0.2 million 0.5 million

CHEMICAL OXYGEN DEMA ND (KG ) 0.9 million 0.6 million 0.2 million 0.8 million

COPPER (G) 0 0 17,000 17,000

MERCURY (G) 0 0 460 460

LEAD (G) 0 0 49,000 49,000

SELENIUM (G) 0 0 52,000 52,000

NON

- HAZARDOUS WASTE (KG) k 0 0 0 05

- 7 AVOIDED IMPACTS FLY ASH IN

CONCRETE

EXTRAPOLATED

TO 18.6 MILLION

TONS a FLY ASH IN

CONCRETE

EXTRAPOLATED TO
CURRENT USE ( 12.6
MILLION TONS) b FGD GYPSUM IN

WALLBAORD

EXTAPOLATED TO
CURRENT USE (8. 5
MILLION TONS) c PARTIAL SUM OF

CURRENT USE

BENEFICIAL

IMPACTS d

Notes:

a. We extrapolate the incremental impacts (i.e., impacts associated with use of 1 ton fly ash) to estimate impacts of increasing fly ash use in concrete to 18.6 million tons. To extrapolate, we multiply each of the incremental impacts calculated by the BEES model by 18.6 million.
b. We extrapolate the in cremental impacts (i.e., impacts associated with use of 1 ton fly ash) to estimate the impacts of current beneficial use of fly ash in concrete ( 12.6 million tons). The current quantity of fly ash that is beneficially used as a substitute for finished port land cement in concrete is reported by ACAA’s 200 8 CCP Survey. We multiply each of the incremental impacts calculated by BEES by 12.6 million tons to extrapolate these impacts to reflect current use.

c. We extrapolate the incremental impacts (i.e., impact s associated with use of 1 ton FGD gypsum) to estimate the impacts of current beneficial use of FGD gypsum in wallboard (8. 5 million tons). The current quantity of FGD gypsum that is beneficially used as a substitute for finished p ortland cement in concret e is reported by ACAA’s 200 8 CCP Survey. We multiply each of the incremental impacts calculated by SimaPro by 8. 5 million to extrapolate these impacts to reflect current use.
d. Calculated as the sum of the fly ash and FGD gypsum current use extrapolation s.

e. Nonrenewable energy refers to energy derived from fossil fuels such as coal, natural gas and oil.
f. Renewable energy refers to energy derived from renewable sources, but BEES does not specify what sources these include.

g

. We monetize energy impac ts for fly ash using a price figure ($0.0044/MJ) derived from the average price of purchased energy to the cement manufacturing sector in 2006 ($4.36/million BTU), from Table 7.2, accessed on Nov. 16, 2010 at http://www.eia.doe.gov/emeu/mecs/mecs2006/2006t ables.html. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html. We monetize energy impacts for FGD Gypsum using a price/MJ figur e ($0.0179/MJ), derived from the average cost of diesel fuel in 2009 ($2.467/gallon), assuming 130,500 BTUs/gallon of diesel fuel. Diesel price is 2009 weekly price of on

- highway diesel accessed on April 22, 2010 at http://tonto.eia.doe.gov/dnav/pet/pet_p ri_gnd_dcus_nus_a.htm; diesel energy value accessed April 22, 2010 at http://bioenergy.ornl.gov/papers/misc/energy_conv.html.
h

. We monetize water impacts using the average cost of water in 2008 ($2.81/KGal) converted to 2009 dollars ($2.87/KGal).
The 200 8 cost of water is taken from NUS Consulting Group, accessed on April 22, 2010 at http://www.marketwire.com/press

- release/Average

- US

- Water

- Costs

- Increase

- by

- 73

- 903477.htm. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, accessed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html.
i

. We converted g reenhouse gas emissions to tons of CO 2 equivalent using U.S. Climate Technology Cooperation Gateway’s Greenhouse Gas Equivalencies Calculator acc essed on Dec 3 , 2010 at http://www.epa.gov/cleanenergy/energy

resources/calculator.html . This calculation only includes CO 2 and methane. j

. Impacts in MTCE are calculated by dividing the impacts in MTCO2E by 44/12 (the ratio of the molecular weight of car bon dioxide to carbon). U.S. EPA, “A Climate Change Glossary,” accessed at http://www.globalwarming.org/node/91

. k . BEES reports waste as “end of life waste.” In contrast, SimaPro reports “solid waste.” In is not clear if these waste met rics are directl y comparable as SimaPro does not specify whether “solid waste” refers to manufacturing waste, end

- of

- life waste, or both.



### The results show that current beneficial use of fly ash in concrete and FGD gypsum in wallboard results in positive environmental i mpacts. The most significant impacts include energy savings

. Energy savings associated with the use of fly ash and FGD gypsum totals approximately 78. 8 billion megaj oules of

energy (or approximately $ 482 m illion in 2009 energy prices). Based on the averag e monthly consumption of residential electricity customers, this is enough energy to power over 2 million homes for an entire year. 66



### Avoided water use is also significant , totaling 768 billion liters. However, t he total water use for FGD gypsum in wallb oard is dominated by water used in turbines for power generation. Because turbine use is not comparable to consumptive use, we value only the 8.7 billion liters associated with cement production; this is equivalent to $5.5 million in 2009 water prices , an d is roughly equivalent to the annual

66 Based on the assumption that an average residential customer uses 908 kilowatt

- hours per month. EIA, “Table 5A. Residential Average Monthly

Bi ll by Census Division and State, 2009” accessed Dec. 3, 2010 at www

. eia .doe.gov/cneaf/electricity/esr/ table5_a .xls

.5

- 8



### water consumption of 4,400 Americans. By comparison, the total water use including turbine use is equivalent to annual water consumption of roughly 389 ,000 Americans. 67



### The extrapolated beneficial impacts also includ e key impacts such avoided greenhouse gas ( 1 3.5 m illion

tons of avoided CO 2 

### equivalent ), and avoided air emissions ( 35

, 1 00 metric tons of avoided NOx, and

32 ,50 0 m etric tons of SOx ). Note that the impacts presented in Exhibit 5

- 3 represent only a partial estimate of the total impacts of beneficially using CCPs. Beneficial use of fly ash as a substitute for

finished p ortland cement in concrete and FGD gypsum in wallboard accounts for only 35 percent ( 21.1 million tons) of all beneficially used CCPs in 200 8 (or 42 percent if excluding mining applications)

. 

## Economic Distribution of CCP Beneficial Use Impacts In addition to an estimate of overall beneficial impacts associated with use of CCPs, we developed a screening analysis using the EIO

- LCA model to pro vide insight into the distribution of impacts across economic sectors. We modeled the impacts associated with a hypothetical reduction of $1 million of demand from the cement manufacture and gypsum mining sectors. From the perspective of energy and air

emi ssions, cement manufacturing leads to large impacts, and is in general the largest source of emissions across the supply chain. Reducing the amount of cement produced by beneficially reusing products can lead to large supply chain

- wide reductions of emiss ions. Comparatively, the impact of the substitution of FGD gypsum for virgin gypsum in wallboard manufacturing is less clear, as the EIO

- LCA model was not able to adequately represent the wallboard sector.

These results and others produced by the model do not affect the total estimate of beneficial impacts associated with changes in use of CCPs. However, they indicate the specific sectors, activities, and points in the supply chain that may be most important to consider in more detailed analyses of benefi cial use
scenarios. The EIO

- LCA model may provide important insights into the success of policies and actions, because the model identifies the types of market changes that may result from specific changes in practice. EIO

- LCA may, therefore, clarify the positive and negative impacts of specific, targeted programs and actions on different economic sectors. Appendix D provides a detailed discussion of the analysis.



## CONCLUSIONS AND NEXT STEPS This report provides a preliminary assessment of the baseline imp acts associated with the beneficial use of fly ash and FGD gypsum in 2008 . The analysis uses the life cycle

- based BEES and SimaPro models, coupled with simple monetized estimates of energy and water savings, to estimate the impacts of replacing portland c ement with fly ash in concrete and virgin gypsum with FGD gypsum in wallboard. The most significant impacts include energy savings and water use reductions. Energy savings associated with the use of fly ash and FGD gypsum totals approximately 78. 8 billion megajoules of energy (or approximately $ 482 m illion in 2009 energy prices ). Based on the average monthly consumption of residential electricity customers, this is enough energy to power over two million homes for an entire

year. Avoided water use totals approximately 768 billion liters , of which at least 8.7 billion liters is consumed (equivalent to approximately $ 5 .5 million in 2009 water prices ). 68 

### This is roughly equivalent

67 Based on 2000 USGS per capita water use estimate of 1,430 gallons per day. Lumia et al., United States Department of the In terior, Unite d
States Geological Survey, Summary of Water Use in the United States, 2000.

68 Based on the assumption that an average residential customer uses 920 kilowatt

- hours per month. Department of Energy, Energy Information
Administration, “Table 5A. Residentia l Average Monthly Bill by Census Division and State, 2008” accessed Nov. 16, 2010 at

www

. eia .doe.gov/cneaf/electricity/esr/ table5_a .xls

.5

- 9



### to the annual water consumption of 4

, 4 00 Americans. 69 

### The extrapolated benefic ial impacts also include key impacts such avoided greenhouse gas ( 1 3.5 million tons of avoided CO 2 

### equivalent ), and avoided air emissions ( 35

, 100 m etric tons of avoided NOx, and 32 ,50 0 m etric tons of SOx )

. This report also presents a distributional screeni ng analysis using the EIO

- LCA model that indicates significant avoided environmental impacts from reductions in the demand for cement or virgin gypsum that are distributed across several economic sectors. From the perspective of energy and air emissions, cement manufacturing leads to large impacts, and is in general the largest source of emissions across the supply chain. Reducing the amount of cement produced by beneficially reusing products can lead to large supply chain

- wide reductions of emissions. C omparatively, the impact of the substitution of FGD gypsum for virgin gypsum in wallboard manufacturing is less clear.

The preliminary results of this initial analysis suggest that a more detailed evaluation of the beneficial use
of CCPs could build on the se results to assist the Agency in a more specific evaluation of the

achievements of the SMM program. A more detailed analysis would require:

 The development of realistic and effective beneficial use scenarios that incorporate more detailed descriptions o f markets, beneficial uses, and policies. Realistic scenarios should reflect key market dynamics and limits such as distance to markets and virgin material prices, and be able to assess the impacts of these dynamics on the growth potential for specific be neficial uses. For example, the limiting transportation distance for the beneficial use of CCPs in road construction may be far less then that of gypsum wallboard.

 The development of a methodology to attribute beneficial use impacts to specific EPA/ SMM

ef forts and programs. A phased approach may be appropriate. Such an approach could initially employ the simple operating assumption that all impacts result from Agency actions. This assumption could then be refined to reflect specific Agency strategies, p olicies, and other efforts, and link these, where possible, to specific changes in beneficial use practices and markets.

 The expansion of the assessment to include additional CCPs and beneficial use applications. This analysis only examines the benefici al impacts of substituting fly ash for finished portland cement in concrete and substituting FGD gypsum for virgin gypsum in wallboard manufacturing. These two processes represent less than 50 percent of the total beneficial use of CCPs. Additional high volume applications that may be analyzed include: the use of fly ash as a raw feed in cement clinker; the use of boiler slag as blasting grit; and the use of various CCPs in structural fill and waste stabilization. In addition, the beneficial impacts of lower volume applications may be examined in order to identify those that may have potentially high incremental impacts.

69 Based on 2000 USGS per capita water use estimate of 1,430 gallons per day. Lumia et al., United States Department o f the Interior, United
States Geological Survey, Summary of Water Use in the United States, 2000.R

- 1



# REFERENCES

ACAA ( American Coal Ash Association ), “200 8 Coal Combustion Product (CCP) Production and Use Survey,” accessed at http://a caa.affiniscape.com/associations/8003/files/2008_ACAA_CCP_ Survey_ Report_FINAL_100509.pdf

ACAA , Coal Combustion Product (CCP) Production and Use Surveys for 2005 to 2007, accessed Oct. 18,

2010 at http://acaa.affiniscape.com/displaycommon.cfm?an=1&subarti clenbr=3

. ACAA (American Coal Ash Association ), 2006a

, Dave Goss

, Personal Communicatio n, March 2006.

ACAA (American Coal Ash Association)

, 2006b

, Dave Goss

, Personal Communication

, April 2006.

ACAA (American Coal Ash Association)

, 2006c

, Dave Goss

, Person al Communication

, May 2006.

ACAA (American Coal Ash Association)

, 2006c

, Dave Goss

, Personal Communication

, November 2006.

ACAA ( American Coal Ash Association )

, 2008, “Frequently Asked Questions,” accessed Nov. 19, 2010

at http://acaa.affiniscape.com/displ aycommon.cfm?an=1&subarticlenbr=5

. American Foundry Society (AFS)

, 2007, “Foundry Industry Benchmarking Survey

. ”

Caltrans (California Department of Transportation)

, 2006

, Tom Pyle

, Personal Communication

, November 2006.

DOT (U.S. Department of Transport ation), 2006, John D’Angelo, Personal Communication, March 2006.

Edgar G. Hertwich, Sarah F. Mateles, William S. Pease, Thomas E. McKone, 2001, Environmental Toxicology and Chemistry 20(4):928

- 939.

EIA (Energy Information Administration), “Table 5A. Reside ntial Average Monthly Bill by Census Division and State, 2008” accessed Nov. 16, 2010 at

www

. eia .doe.gov/cneaf/electricity/esr/ table5_a .xls

. EIA, 2010, “Annual Energy Outlook 2010 w ith Projections to 2035: Electricity Demand,” accessed October 25, 2010 at http://www.eia.doe.gov/oiaf/aeo/electricity.html

. EIA, 2010, “Figure 3. Electric Power Sector Consumption of Coal by Census Region, 2009,” accessed Oct. 31, 2010 at http://www.eia.doe.gov/cneaf/coal/page/special/fig3.html

EIA , 2010, “Net Generation by Energy Source: Total (All Sectors),” accessed October 25, 2010 at http://www.eia.doe.gov/cneaf/electricity/epm/table1_1.html

. EIA ( Energy Information Administration )

, 2007, “U.S. Coal Consumption by End

- Use Sector,” http://www.eia.doe.gov/cneaf/coal/quarterly/html/t28p01p1.html

.
Electric Power Research Institute

, 1999

, Environmental Focus: Flue Gas Desulfurization By

- Products

, BR

- 114239.

Electric Power Research Institute

, 2006

, “Coal Combustion Product Use

, ” a ccessed at http://www.epri.com/Portfolio/product.aspx?id=2065&area=50

. Energy an d Environmental Research Center, 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

-- 79, July 1999

.R

- 2



### Energy & Environmental R esearch Center

, 2006

, University of North Dakota, “ Review of Florida Regulations, Standards, and Practices Related to the Use of Coal Combustion Products: Final Report

, ” University of North Dakota

, April 2006

, accessed at http://www.undeerc.org/carrc/Asset s/TB

- FLStateReviewFinal.pdf

. Energy & Environmental Research Center, 2005, University of North Dakota, “ Review of Texas Regulations, Standards, and Practices Related to the Use of Coal Combustion Products: Final Report,” accessed at http://www.undeerc.org/ carrc/Assets/TXStateReviewFinalReport.pdf

. EPA (U.S. Environmental Protection Agency), 2010, “Boiler Slag,” accessed at http://www.epa.gov/osw/conserve/rrr/imr/ccps/boilslag.htm.

EPA (U.S. Environmental Protection Agency)

, 2010, “Coal Combustion Residuals

– Proposed Rule,” accessed Nov. 17, 2010 at http://www.epa.gov/osw/nonhaz/industrial/special/fossil/ccr

rule/index.htm

. EPA (U.S. Environmental Protection Agency), 2010, “Hazardous and Solid Waste Management System; Identification and Listing of Special Wa stes; Disposal of Coal Combustion Residuals From
Electric Utilit ies; Proposed Rule,” 75 FR 118, June 21, 2010.

EPA (U.S. Environmental Protection Agency), 2010, “Regulatory Impact Analysis for EPA’s Proposed RCRA Regulation Of Coal Combustion Residues (CCR ) Generated by the Electric Utility Industry,” EPA

- HQ

- RCRA

- 2009

- 0640

- 0003 , April 30, 2010

. EPA (U.S. Environmental Protection Agency), 2006, “About C 2 

### P 2 

### ,” accessed at http://www.epa.gov/epaoswer/osw/conserve/c2p2/about/about.htm.

EPA (U.S. Environmental Protection Agency), 2006, "Advisory on EPA's Superfund Benefits Analysis,"

EPA

- SAB

- ADV

- 06

- 002.

EPA (U.S. Environmental Protection Agency), 2005, Using Coal Ash in Highway Construction: A Guide to Benefits and Impacts, EPA

- 530

- K

- 05

- 002, April 2005.

EPA (U.S . Environmental Protection Agency), 2003, "Underground Storage Tanks (UST) Cleanup & Resource Conservation & Recovery Act (RCRA) Subtitle C Program Benefits, Costs, & Impacts (BCI) Assessments: An SAB Advisory," EPA

- SAB

- EC

- ADV

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- 001

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, 1999

, Report to Congress: Wastes from the Combustion of

Fossil Fuels

, Vol. II

, EPA

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- 010, March 1999.

Hassett, David J., Debra F. Pflughoeft

- Hassett, Dennis L. Laudal, and John H. Pavlish, 1999, Mercury
Release from Coal Combus tion ByProducts to the Environment.

Hendrickson, Chris, Lester Lave, and H. Scott Matthews

, 2006

, Environmental Life Cycle Assessment of
Goods and Services , Resources for the Future: Washington, DC, 2006.

Lumia, Deborah, Kristin Linsey, and Nancy Barber, United States Department of the Interior, United States Geological Survey, Summary of Water use in the United States, 2000.

Miller, Cheri

, Gypsum Parameters

, Presentation at WOCA Short Course: "Strategies for Development of FGD Gypsum Resources."

Portla nd Cement Association

, 2006

, “FAQ: Cement Supply Shortage

, ” accessed at http://www.cement.org/pca/shortageQA.asp.R

- 3



### Price, Jason and Mark Ewen, Industrial Economics, Inc. Memorandum to Lyn Luben, EPA, “Impact of CAIR and CAMR on the Quantity and Quality of Coal Combustion Fly Ash Generated by
Affected Facilities

, ” December 1, 2006.

Sanchez, F. et al, 2006

, “Characterization of Mercury

- Enriched Coal Combustion Residues from Electric Utilities Using Enhanced Sorbents for Mercury Control,” EPA

- 600/R

- 06/008, accessed Nov. 17,

2010 at http://www.epa.gov/ORD/NRMRL/pubs/600r06008/600r06008.pdf

. Schwartz, Karen D

, 2003

, “The Outlook for CCPs,” Electric Perspectives , July/August 2003.

Schueck, Joseph et al, 2001, “The Use of FBC Ash for Alkaline Addiiton at Surfa ce Coal Mines,” 2002 International Ash Utilization Symposium, accessed Nov. 19, 2010 at http://www.flyash.info/2001/mining1/49schue.pdf

. Sheikholeslami, Bizhan, Wisconsin Department of Natur al Resources, 2006, P ersonal C ommunication.

Stein, Antoinette, 2006, State of California Department of Health Services, Personal Communication.

U.S. Department of Energy, National Energy Technology Laboratory, “General Summary of State Regulations,” acces sed at http://www.netl.doe.gov/E&WR/cub/sta tes/select_state.html.

US EPA , “Characterization of Building

- Related Construction and Demolition Debris in the United
States” and “Characterization of Road

- related Construction and Demolition Debris in the United States,” 2005. (Note that these documents were preliminary at the time of this Report and were undergoing review).

US EPA , “Draft National Priority Trends Report (1999

- 2003) Fall 2005,” as reported in the NPEP GPRA

2008 database of TRI data from 1998

- 2003.

USGS, 2010, “2008 Minerals Yearbook: Gypsum [Advance Release],” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/gypsum/myb1

- 2008

- gypsu.pdf.

USGS, 2010, “2008 Minerals Yearbook: Lime [Advance Release],” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/lime/myb1

- 2008

- lime.pdf.

USGS, 2010, “2008 Minerals Yearbook: Sand and Gravel, Construction [Advance Release],” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/sand_&_gravel_

const ruction/myb1

- 2008

- sandc.pdf.

USGS, 2010, “Mineral Commodity Summaries: Cement, 2010,” accessed Nov. 20, 2010 at http://minerals.usgs.gov/minerals/pubs/commodity/cement/mcs

- 2010

- cemen.pdf

We Energies

, 2007

, Tom Jason

, Personal Communication

, November 2006

. Wisconsin Department of Natural Resources

, 2006

, Bizhan Sheikholeslami

Western Region Ash Group, “Applications and Competing Materials, Coal Combustion Byproducts,”

accessed at http://www.wrashg.org/com pmat.htm

# APPENDIX A | KEY BEN EFICIAL USE APPLICAT IONS FOR CCPSA

- 1

EXHIBIT A

- 1 KEY BENEFICIAL US E APPLICATIONS FOR C CP s ( 2008 )

BENEFICIAL USE APPLI CATION

AND INDUSTRY FLY ASH BOTTOM

ASH FGD

GYPSUM FGD

MATERIAL

WET

SCRUBBERS FGD

MATERIAL

DRY

SCRUBB ERS FGD

OTHER BOILER

SLAG FBC ASH PRODUCT SUBSTITUTES

Concrete 12,592,245 720,948 675,505 0 22,577 0 0 4,341 Cement, Silica fume, Furnace slag

Cement additive 3,174,264 610,194 413,740 0 0 0 0 0 Clay, Soil, Shale, Gypsum

Flowable fill 74,794 0 0 0 18,3 38 0 0 0 Soil, Sand, Gravel, Cement

Structural fill 8,012,825 2,996,388 0 0 130,566 106,526 178,363 76,579 Sand, Gravel, Soil, Aggregate

Road base 1,027,568 767,013 0 0 0 0 0 7,444 Cement, Lime, Aggregate

Soil stabilizer 627,810 431,664 0 0 60,115 0 0 132,379 Cement, Lime, Aggregate Mineral filler in asphalt 7,781 257,806 0 0 0 0 0 0 Sand

Snow and ice control 0 699,561 0 0 0 0 1,352 0 Sand Blasting grit 84,881 66,670 0 0 0 0 1,486,316 0 Sand

Mine reclamation a 960,911 63,648 0 685,104 109,641 0 3, 021 8,643,947 Soil

Wallboard 0 0 8,533,732 0 0 0 0 0 Natural gypsum

Waste stabilization 2,923,592 84,901 744,592 0 1,221 30,240 0 0 Cement, Lime, Cement kiln dust
Agriculturalsoil amendment 35,340 3,771 278,875 0 2,877 0 0 0 Liming agents

Manufactured aggregate 154,992 727,048 0 0 0 0 19,422 0 Sand, gravel, aggregate

Miscellaneous/other 465,271 646,643 6,900 0 0 0 1,418 0 CCP Category Use Totals 30,142,274 8,076,255 10,653,344 685,104 345,335 136,766 1,689,892 8,864,690

CCP Utilization Rate 42% 44 % 60% 5% 25% 9% 83% 93%

a. EPA does not consider large fill operations such as use in mine reclamation a beneficial use. EPA, 2010, “Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule,” 75 FR 118 (June 21, 2010), p. 35148.

Sources : 1. ACAA, “200 8 Coal Combustion Product (CCP) Production and Use Survey,” accessed Oct. 18, 2010 at
h ttp://acaa.affiniscape.com/associ ations/8003/files/2008_ACAA_CCP_Survey_Report_FINAL_100509.pdf
2. Western Region Ash Group, “Applications and Competing Materials, Coal Combustion Byproducts,” accessed at http://www.wrashg.org/compmat.htm

.

# APPENDIX B | USE OF LIFE CYCLE ASSESSMENT IN AN EVALUATION OF ECONOM IC BENEFITSB

- 1



### Life cycle assessment (LCA) inventory analyses of the type presented in this report deliver incremental changes in physical inputs, outputs, and energy arising fro m management or regulatory changes to an industrial production process. This discussion addresses the following issues: how does LCA relate to economic analysis of benefits, and how are economic impacts derived from changes in “physical inventory,” such as energy use and alternative waste streams?



## RELATIONSHIP BETWEEN LCA AND ECONOMIC ANA LYSIS OF BENEFITS LCA is a performance assessment tool

– a method to depict physical outcomes that can be used to assess impacts and measure progress over time. And beca use LCA is a systems approach to assessment, it offers significant improvement over less comprehensive techniques. However, in economic terms, LCA is only one component of a true analysis of benefits

– albeit a central
component.

Consider the architect ure of an economic benefit assessment. At the “front end” lies a set of economic drivers that determine technologies and practices employed by industry. These drivers include raw material prices, other input costs (including transport), competitive facto rs, regulation, technology, and taxes. EPA programs such as SMM work to facilitate changes in the economic drivers of waste generation, handling, and disposal (e.g., a change in tipping fees, tighter permit requirements on landfills, benefits to participa tion in beneficial use programs, etc.). Changes in these economic drivers can be expected to lead to changes in the physical system of production. In other words, the physical system and its outputs are properly thought of as the end product of a set of economic incentives (prices) and constraints (technology).

LCA depicts production as a system of sometimes reinforcing, sometimes counteracting physical outcomes. In particular, it allows the analyst to predict the incremental physical consequences of

a change in disposal practices, technology, or price incentives. Any change in the physical system leads to a corresponding cascade of system changes

– as inputs are substituted, exposure pathways are changed, and technology adapts. LCA produces the net r esult of these various changes and, thus, the true, incremental effect on physical outputs. 70



### Deriving an incremental physical effect from a complex system is difficult enough. As the agency seeks performance measures to satisfy its GPRA and PART requirem ents, LCA is a natural starting point. It demands systems thinking, properly views outcomes as changes to baseline conditions, identifies tradeoffs, and yields concrete, measurable metrics. LCA can tell us
who and what will be affected by changes in indu strial practice, and even where changes are likely to occur.

However, while LCA is a fundamental building block of benefit assessment, LCA does not itself yield the social benefits and costs of industrial change. To do that, we must apply economic
valua tion techniques to the physical outputs of LCA analysis.

70 For example, the PaLATE model generates incremental effects on physical outputs arising from changes in roadway materials.B

- 2



### Economic Assessment is desirable because we don’t really care about physical outcomes, we care about what those outcomes imply for human well

- being. Another way of putting this is, how do

we comp are the “apples” of one change to the “oranges” of another? 71 

### Also, how do we compare a given “small” physical gain in one waste to a “large” reduction in another. In physical terms, we might be tempted to say that the large gain outweighs the small loss. Of course, small physical changes can have large health and environmental consequences with large economic ramifications (think of the effect of radiation or toxics on health).

To understand how energy and raw materials use and emissions of different kinds affect well

being we must make a set of additional “translations.” A physical change in lead concentrations leads, via ecological and epidemiological processes, to changes in human exposure. Changes in exposure lead to morbidity and mortality effec ts. Morbidity and mortality effects have social
benefits and costs. 72 

### Those benefits and costs are the ultimate goal of our analysis. In another example, the effect of water consumption on well

- being depends upon the location, timing, and quality of the water that is consumed. The value of that water depends on how it would
otherwise be used

– for human consumption, industrial uses, habitat support, irrigation, etc. LCA tells us little, if anything, about these relationships. Thus, LCA may tell us re latively little about the actual welfare effects of changes in industrial process.

Unfortunately, the translation of physical changes into economic outcomes is costly, difficult, and often controversial when applied to human health or environmental outco mes. As the report notes earlier, “with the exception of water and energy savings for which current price data are available, we do not calculate these benefits in dollar terms because monetizing involves complex valuation procedures.” Putting economic v alue on even a small set of physical impacts can be a significant and expensive proposition.

Accordingly, LCA should be regarded, not only as a necessary ingredient, but also as a practical
alternative to real benefit assessment. While economic benefits a re the ultimate performance measure, businesses and governments routinely rely on simpler

– though imperfect

– proxies to facilitate management and performance assessment. As proxies, LCA outputs are a legitimate and defensible compromise.



## INVENTORY CHAN GES AND WELFARE: THE TRANSLATION OF LCA OUTPUTS TO ECONOMIC IMPACTS There are two basic steps that must be employed to translate LCA

- generated inventories into social benefits. The first is the translation of LCA inventories into “final economic goods.” The second is the valuation of those final goods.



## Mapping LCA inventories into final economic goods In general, changes in LCA physical inventories will generate a set of corresponding changes in other physical conditions relevant to human well

- being . Even before economic valuation occurs,
these follow

- on physical implications must be assessed. For instance, to value changes in

71 Hendrickson, Lave, and Matt hews (2006) (“A typical [Life Cycle Inventory] of air pollution results in estimates of conventional,
hazardous, toxic, and greenhouse gas emissions to the air. Even focused on this small subset of environmental effects, it is unclear

how to make sense of the multiple outputs and further how to make a judgment as to tradeoffs or substitutions of pollutants among
alternative designs.”), 29.

72 Some in the LCA community refer to this as an LCA impact analysis, as opposed to the preceding LCA inventory analysi s. Inventory
analyses are those most commonly referred to as LCA. See Graedel and Allenby (1995).B

- 3



### mercury releases, it is important to know how increased or decreased mercury emissions interact with exposure pathways to a ffect body burdens and human health. An LCA inventory does not address this issue; an analysis of epidemiology and exposure is required. Similarly, hydrological analysis is required to determine how a reduction in water usage translates into water availa bility in different locations and at different times. Further, ecological analysis must be deployed to answer questions such as “what is the effect of greater water availability on species and habitats?” The point is that benefit assessment requires synth etic systems thinking of an order at least as great as the original LCA analysis. 73



### The goal of these biophysical and epidemiological translations is to translate LCA inventory
results to outcomes with direct human impact

– health effects or the availabi lity of water in a particular stream at a particular time.

In the human health realm, toxic wastes or air quality burdens must be evaluated in terms of fate, transport, and deposition models. Human health models then translate depositions into human

healt h impacts via epidemiological analysis (e.g., dose

- response relationships). EPA is relatively sophisticated in its use of such models, owing to decades of experience with air quality regulation and the analysis of economic effects arising from air quality

- related health assessments.

In the ecological realm, these kinds of translations are underdeveloped. The agency is aware of
this

– the conclusion has been drawn from several recent SAB reports. 74 

### The analysis of ecological benefits is clarified by draw ing distinctions between ecosystem processes and functions and the “final” outcomes of those processes (denoted here as “final ecosystem goods.” Ecosystem processes and functions are the biological, chemical, and physical interactions
associated with ecol ogical features such as surface water flows, habitat types, and species populations. These functions are the things described by biology, atmospheric science, hydrology, and so on.

Final ecosystem goods arise from these components and functions but are d ifferent: they are the aspects of the ecosystem that are directly valued by people. The benefits of nature include many forms of recreation, aesthetic enjoyment, commercial and subsistence harvests, damage avoidance, human health, and the intangible catego ries mentioned earlier. Final ecosystem goods are the aspects of nature used by society in order to enjoy those benefits.

Part of the above definition is particularly important: namely, that ecosystem services are “final.” Final goods are the things peo ple actually make choices about. For an angler, these end products include a particular lake or stream and perhaps a particular species population in that water body. The choices involved include which lake, what kind of fish, what kind of boat (if any) an d tackle to use, and how much time spent getting to and from the site. Valuation is about choices (is one thing better than another) and choices are the only thing economists can use to establish economic value. Environmental benefit assessment places valu es on the things people and households make

actual choices about

– the “final goods” of nature. It is very important to emphasize that many

73 For an example of a full social cost & benefit analysis see Krupnick and Burtraw (1997).

74 For example, this conclusion has been drawn from several rece nt SAB reports, including EPA

- SAB. 2003. "Underground Storage Tanks
(UST) Cleanup & Resource Conservation & Recovery Act (RCRA) Subtitle C Program Benefits, Costs, & Impacts (BCI) Assessments: An
SAB Advisory." (EPA

- SAB

- EC

- ADV

- 03

- 001) and "Advisory on EPA' s Superfund Benefits Analysis." (EPA

- SAB

- ADV

- 06

- 002). In addition, the
SAB Committee on Valuing the Protection of Ecological Systems and Services is currently examining methods for addressing thes e
limitations.B

- 4



### other aspects of nature are valuable, but not capable of being valued in an economic sense

– because they are not su bject to social or individual choices.

Ecosystem production functions are the relationships that translate LCA inventory changes into final ecosystem goods. One characteristic of these production functions is particularly worthy of note: ecological produc tion functions are dependent upon space and landscape. Location

- and
scale

- specificity are core characteristics of modern ecology. For example, the quality of a habitat asset can be highly dependent on the quality and spatial configuration of surrounding land uses. The ability of areas to serve as migratory pathways and forage areas typically depends on landscape conditions over an area larger than habitats relied upon directly by the migratory species. The contiguity of natural land cover patches has been shown for many species to be an indicator of habitat quality and potential species resilience. Hydrological analysis is yet another field that has long recognized the importance of relationships between landscape features. The
nature of surface water flow s, aquifer structures, and surface

- groundwater interactions are dependent upon linked physical relationships across the landscape.

For ORCR to move toward measurement of ecosystem impacts arising from beneficial use, or any other change in waste managemen t practices, the ability to translate LCA inventory changes into final ecosystem good changes requires the development of spatial ecological modeling. Space and scale are important to the valuation of final ecosystem goods, as well.



## Assigning value to c hanges in final ecological goods The value of an ecosystem good is typically location

- dependent. The value of a car is not closely related to whether it is located in California or New Jersey. This is not the case with ecological goods. The benefits of dam age mitigation, aesthetic enjoyment, and recreational and health improvements depend on where

— and when

— ecosystem services arise relative to complementary inputs and substitutes. Also, the ecological asset interactions that enhance or degrade service
flows are highly landscape

- dependent. Accordingly, it is necessary to spatially define “service areas.” An unfortunate reality is that these will be different for every identified ecosystem service. Boundaries are needed to define the likely users of a service, areas in which access to a service is possible, and the area over which services might be scarce or have substitutes. This issue is well known in environmental economics (Smith and Kopp 1996). For example, a key methodological issue in any econometric recr eational benefits study is the determination of the appropriate choice set facing recreators.

While market prices can be assumed to be largely constant within a single market, there is no arbitrage to ensure this condition for the implicit prices of enviro nmental resources. Also, many ecological services are best thought of as differentiated goods with important place

- based quality differences. As noted earlier, the biophysical characteristics of ecosystems are highly landscape

dependent. The same is true o f ecological services’ social benefits. Accordingly, willingness to pay for ecological services is best represented by a hedonic price function, not a single price.



## An intermediate step: benefit indicators as an alternative to full valuation The spatial f

actors that affect ecosystem goods’ value create a problem for analysts. Benefit estimates from one study in one location cannot be transferred to other sites. In practical terms, this means that ecosystem valuation is expensive, time

- consuming, and diff icult. Problem

specific valuation will be impractical for most regulatory applications.B

- 5



### In this context, one alternative to full

- scale valuation is the use of “benefit indicators” (Boyd 2004, Boyd and Wainger 2002). The benefits of a given ecosystem go od are affected by the following: the ecosystem feature’s scarcity, natural and built substitutes, complementary inputs, and the number of people in proximity to it. All of these can and should be measured spatially. Benefit indicators are map

- able, count able landscape features that affect the value of a particular ecosystem good. Benefit indicators are an input to a wide variety of tradeoff analysis approaches, but do not themselves make or calculate the results of such tradeoffs. First, they can be use d as ends in themselves as regulatory or planning performance measures. Second, they can be used as part of public processes designed to elicit public preferences over environmental and economic options

– as in mediated modeling exercises or more informal political derivations. Benefit indicators are a potentially powerful complement to group decision processes. Third, they can be
used as inputs to economic and econometric methods such as benefit transfer, or stated preference models. In the former, th ey can be used to calibrate the transfer function. In the latter case, they can be used to develop alternative choice scenarios.



## REFERENCES

Boyd, James, “What’s Nature Worth? Using Indicators to Open the Black Box of Ecological Valuation,” Resources , 20 04.



## Boyd, James and Lisa Wainger, “Landscape Indicators of Ecosystem Service Benefits,”
84 American Journal of Agricultural Economics , 2002.

Graedel, T.E., and B.R. Allenby, Industrial Ecology , Prentice Hall: Englewood Cliffs NJ, 1995.

Hendrickson, Chri s, Lester Lave, and H. Scott Matthews, Environmental Life Cycle Assessment of Goods and Services , Resources for the Future: Washington, DC, 2006.

Krupnick, Alan and Dallas Burtraw, “Social Costs of Electricity: Do the Numbers Add Up?” Resources and Energy 18:4, 1997, 423

- 466.

Porter, Richard, The Economics of Waste , Resources for the Future: Washington, DC, 2002.

Portney, Paul, “The Price Is Right: Making Use of Life Cycle Analyses,” Issues in Science and Technology , 10: 2 Winter, 1993, 69

- 75.

Smith, V . Kerry, and Ray Kopp, Valuing Natural Assets: The Economics of Natural Resource Damage Assessment , ( Resources for the Future: Washington, DC, 1996.

# APPENDIX C | ANALYSIS OF BENEFI TS USING ALTERNATE L IFE CYCLE MODELSC

- 1



### In the main body of this report, we present an analysis of the life cycle benefits of substituting fly

ash for finished p ortland cement in concrete using BEES. For comparative purposes, this appendix illustrates the impacts associated with beneficial use of fly ash in concrete that can b e calculated using two additional life cycle tools: the WARM and EIO

- LCA models.



## WARM MODEL ANALYSIS The Waste Reduction Model (WARM) was created by EPA to help solid waste planners and organizations estimate greenhouse gas (GHG) emission reductions from s everal different waste management practices. 75 

### WARM calculates GHG emissions for baseline and alternative waste management practices, including source reduction, recycling, combustion, composting, and landfilling. The user can construct various scenarios by entering data on the amount of waste handled by material type and by management practice. WARM then automatically applies

material

- specific emissions factors for each management practice to calculate the GHG emissions and energy savings of each scenario. The model evaluates energy use and GHG emissions in three stages of the life cycle: (1) raw material acquisition, (2) manufacturing (fossil fuel energy emissions), and (3) waste management (carbon dioxide emissions associated with compost, non

biogenic car bon dioxide and nitrous oxide emissions from combustion, and methane emissions from landfills). At each of these points, the study also considers transportation

- related energy use

and GHG emissions.

The WARM model reports avoided lifecycle GHG emissions in either metric tons CO 2 

### equivalent (MTCO 2 

### E) or metric tons CO equivalent (MTCOE), as well as energy use in BTUs. In addition, the model converts these outputs to equivalent metrics including the equivalent number of cars removed from the road in one yea r, the equivalent number of avoided barrels of oil burned, and the equivalent number of avoided gallons of gasoline consumed. Currently, the only CCP available for analysis using WARM is fly ash. WARM calculates GHG emissions and energy use

associated wit h use of fly ash in concrete as an alternative to landfill disposal. We first use WARM to estimate the incremental impacts associated with beneficial use of one ton of fly ash in concrete, in comparison to disposing of that ton of fly ash in a landfill. Then, we extrapolate the results to estimate benefits associated with beneficially using 18.6 million tons of fly ash in

concrete. 76



## Results

Exhibit C

- 1 presents the results of the WARM model analysis for the beneficial use of fly ash. 77



### The WARM model est imates that one ton of fly ash beneficially used in concrete results in

avoidance of approximately 0.91 MTCO 2 

### E of GHG emissions and 5.29 million BTUs of energy use. Extrapolating these outcomes to beneficially us e of 18.6 million tons of fly ash in concre te results in savings of approximately 17 million MTCO 2 

### E. According to the WARM model,

75 WARM can be accessed at http://yosemite.epa.gov/oar/globalwarming.nsf/WARM?openform . Version 8 of the model was used for this
analysis. Available information indicates that Version 8 was last updated in August of 2006.

76 WARM allows the user to define key modeling assumptions, such as landfill gas recovery practices and transport distance to MS W
facilities. For landfill gas (LFG) control, we select the “National Average” setting, which calculates emissions based on the an ticipated
proportion of landfills with LFG control in 2000. For transport distances, we use the default setting (20 miles).

77 It is important to note that the results reported by WARM for avoided greenhouse gas emissions and avoided energy use may not be

d irectly comparable to those reported by the BEES model or PALATE model due to differences in the methodologies (including lif e cycle system boundaries) employed by each model.C

- 2



### beneficially using 18.6 million ton s of fly ash results in 98 .5 trillion BTUs (103.8 million MJ ) of avoided energy use. This energy savings is equivalent to 17 million barrels of avoided oil consumption, 792 million gallons of avoided gasoline consumption, or a reduction in annual energy use by approximately half a million households.

EXHIBIT C

- 1: WARM RESULTS: IM PACTS OF BENEFICIAL USE OF FLY ASH IN CO NCRETE

IMPACT IN CREMENTAL IMPACT OF USING

1 TON OF FLY ASH TOTAL IMPACTS OF BENEFICIALLY

USING 18,600,000 TONS a

GHG EMISSIONS AVOIDE D (MTCO 2 E) 0.91 16.9 1 million

AVOIDED ENERGY USE ( BTU s ) b 5.29 million $ 24. 5 8 98

. 47 tr illion $ 457.12 m illion

EQUIVALENT AVOIDED O IL

CO NSUMPTION (BARRELS) 0.91 1 7 million

EQUIVALENT AVOIDED G ASOLINE CONSUMPTION (GALLONS ) 42. 59 792 million

EQUIVALENT AVOIDED H OUSEHOLDS’

ANNUAL ENERGY CONSUM PTION (HOUSEHOLDS) 0.0 49 0. 92 million

Notes:

a. The total impacts represent the difference bet ween beneficially using 18.6 million tons of fly ash in concrete in comparison to disposal in a landfill.
b. We monetize energy impacts for fly ash using a price figure ($0.0044/MJ) derived from the average price of purchased energy to the cement manufact uring sector in 2006 ($4.36/million BTU), from Table 7.2, accessed on Nov. 16, 2010 at http://www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html. The cost was converted to 2009 dollars using NASA's Gross Domestic Product Deflator Inflation Calculator, acc essed on April 22, 2010 at http://cost.jsc.nasa.gov/inflateGDP.html.
Sources : 1. US EPA, Solid Waste Management and Greenhouse Gases, A Life cycle Assessment of Emissions and Sinks , 2nd Edition, May 2002. (EPA530

- R

- 02

- 006) (WARM Model)
2. US EPA, Backg round Document for Life cycle Greenhouse Gas Emission Factors for Fly Ash Used as a Cement Replacement in Concrete, November 2003. (EPA530

- R

- 03

- 016)



## Limitations and Assumptions

Although the WARM analysis provides a useful example of the energy use and GH G emissions benefits that can be achieved through the beneficial use of fly ash in concrete, it is important to recognize some of the key limitations of the work to date:

 

### Our analysis assumes a 20

- mile transport distance from the point of collection to the landfill or concrete facility. In reality, transport distances may be greater or less than 20 miles. Adjusting transport distance would effect both GHG emissions and energy use.

 

### Emissions factors used in WARM reflect national averages. Our analysis may t herefore over or under estimate impacts for a specific region or location. In addition, we use a national average for landfill gas recovery that may also over or understate emissions for a specific landfill.

 

### WARM does not specifically calculate impacts on purchased energy. Purchased energy impacts may be incorporated into the avoided energy use metric, but this is not clear.C

- 3 

###  

### WARM reports some environmental impacts in physical quantities (e.g., BTUs energy, lbs NOx, etc.), not in monetized dollar effects.



## E IO

- LCA ANALYSIS The goal of this task was to do a preliminary assessment of what the baseline energy and air pollution effects are for existing cement production, such that any reduction of this demand in terms of beneficially used fly ash would lead to re duced impact.

To estimate baseline impacts of cement production, we used the Economic Input

- Output Life Cycle Assessment (EIO

- LCA) model. EIO

- LCA was developed at Carnegie Mellon and provides the capacity to evaluate economic and environmental effects acr oss the supply chain for any of

428 industry sectors in the U.S. economy in 2002 . EIO

- LCA also can represent the supply chain use of inputs and resulting environmental outputs across the supply chain by using publicly
available data sources from the U.S. government. By integrating economic data on the existing flow of commerce between commodity sectors with environmental data on releases and material flows generated by each sector, it is possible to estimate the additional environmental emissions

caused b y an increase in production within a particular sector, accounting for the supply chain. This approach can be used to avoid some of the system boundary limitations of process LCA by drawing upon data for the entire economy. The EIO

- LCA model includes a va riety of such impacts for the entire US economy. For a closer look at the model, visit http://www.eiolca.net

. Currently, the EIO

- LCA model is in active use. Since 2000, the model has registered over 900,000 uses (or over 15,000 per month). Of identifiable access sites, educational users are most common, but there is substantial use by government agencies, non

- profit organizations and companies. A surprising number of foreign users exist, suggesting that internationa l comparisons

are of considerable interest.



## Cement Analysis Specifically within EIO

- LCA, industry “Sector #327310: Cement Manufacturing” was selected for analysis in the model. This industry comprises establishments primarily engaged in manufacturing p ort land , natural, masonry, pozzolanic, and other hydraulic cements. Cement manufacturing establishments may calcine earths or mine, quarry, manufacture, or purchase lime. Examples of activities in this sector include the following :

 Cement (e.g., hydraulic, m asonry, portland, pozzolana) manufacturing

 Cement clinker manufacturing

 Natural (i.e., calcined earth) cement manufacturing

We ran the EIO

- LCA selecting US 2002 as the model, cement manufacturing as the sector

, and one million dollars of economic activity. Exhibit C

- 2 displays the resulting summary estimate s of supply

- chain wide economic impacts. EIO

- LCA is a linear model, thus the estimates scale in a constant fashion ($2 million of production would lead to double the results listed below). T he main poi nt of EIO

- LCA is for screening purposes, thus the specific dollar values are less relevant than the broad, economy

- wide implications that show where less obvious supply chain impacts might exist.C

- 4 EXHIBIT C

- 2: TOP SECTORS THAT SUP PORT CEMENT MANUFACT URIN G IN THE US IN 2002

(ECONOMIC)

SECTOR TOTAL

ECONOMIC
$ MILLIONS VALUE

ADDED
$ MILLIONS DIRECT

ECONOMIC

%

Total for all sectors 1.98 0.986 76.8

327310 Cement manufacturing 1.02 0.487 99.8

221100 Power generation and supply 0.092 0.063 86.5

550000 Management of companies and enterprises 0.056 0.035 54.0

221200 Natural gas distribution 0.055 0.018 88.1

420000 Wholesale trade 0.044 0.030 54.0

211000 Oil and gas extraction 0.042 0.021 1.5 4

327992 Ground or treated minerals and earths manufactur ing 0.029 0.016 90.2

484000 Truck transportation 0.023 0.010 55.6

230301 Nonresidential maintenance and repair 0.021 0.012 53.0

52A000 Monetary authorities and depository credit intermediation 0.018 0.012 28.2



### As shown in the “Total Economic” colu mn of Exhibit C

- 2, there are significant purchases of electricity, oil and gas, etc. across the supply chain. This is due to the recognized significant fuel and energy inputs needed to produce cement. Also visible in the top 10 economic purchases are

pur chases from minerals, stone, and coal.

Exhibit C

- 2 also summarizes which of the purchases are “direct

, ” meaning those made directly by the cement manufacturer. For example

, EIO

- LCA estimates that 86.5 percent of the electricity purchases across the entire supply chain are direct. That means that only 1 3.5 percent of total electricity purchases of cement manufacturing in the supply chain come from all other sectors’ purchases of electricity. This would include electricity bought by oil and gas production and distribution, stone and coal mining, etc. T his amount of direct purchases is a very large amount compared to the usual electricity direct purchases that come from other sectors.

EIO

- LCA also displays estimates of emissions and energy use across the su pply chain, as shown
in Exhibits C

- 3 and C

- 4. Exhibit C

- 3 summarizes emissions of conventional air pollutants, and is sorted by SO 2 

### emissions ; t hese results are from running the US 1997 model, because conventional air pollutant figures are not available f or the US 2002 model. Most SO 2 

### comes from cement manufacturing (and about 15 percent from power generation). A bout 90 percent of NOx and VOC emissions from cement manufacturing come from the cement manufacturing itself, 70
percent of CO from the supply c hain production of cement comes from cement manufacturing, followed by truck transportation. Ninety percent of PM 10 

### emissions come from cement. In short, cement manufacturing itself is a very polluting process, and avoiding emissions from its

manufacture can have large social benefits.C

- 5 EXHIBIT C

- 3: AIR EMISSIONS OF TOP 10 EMITTING SECTORS THAT SUPPORT CEMENT

MANUFACTURING IN THE US IN 1997 (SORTED BY SO 2 )

SECTOR SO 2

MT CO

MT NOX

MT VOC

MT LEAD

MT PM 10

MT

Total for all sectors 27.3 20.4 31.7 23.6 0.005 3.96

327310 Cement manufacturing 22.4 14.6 28.6 22.4 0.005 3.48

221100 Power generation and supply 4.44 0.219 2.01 0.019 0.000 0.094

212310 Stone mining and quarrying 0.209 0.391 0.147 0.074 0 0.043

211000 Oil and gas extraction 0.040 0.068 0.03 0 0.046 0 0.001

221200 Natural gas distribution 0.027 0.001 0.052 0.183 0 0.001

483000 Water transportation 0.024 0.017 0.129 0.124 0 0.012

324110 Petroleum refineries 0.018 0.010 0.004 0.014 0 0.002

213112 Support activities for oil and gas operations 0.016 0.013 0.010 0.004 0 0.002

482000 Rail transportation 0.015 0.032 0.272 0.013 0 0.006

484000 Truck transportation 0.011 3.58 0.258 0.266 0.000 0.006



### Exhibit C

- 4 summarizes supply chain wide use of energy and electricity for producing cement.
The cement sector consumes about 80 percent of total supply chain primary energy use (and
almost 90 percent of electricity, as noted above). Other sectors consuming top but less significant amounts of energy (in the form of fuels) are power generation and su pply and lime and gypsum product manufacturing

.

EXHIBIT C

- 4: TOP 10 SECTORS USING ENER GY THAT SUPPORT CEMENT MANUFACTURING

IN 2002 (SORTED BY TOTAL ENE RGY USE)

SECTOR TOTAL

TJ NON

- FOSSIL

ELECTRICITY

TJ

Total for all sectors 74.4 6.41

327310 Cement manu facturing 59.7 5.54

221100 Power generation and supply 9.98 0.233

3274A0 Lime and gypsum product manufacturing 0.427 0.036

211000 Oil and gas extraction 0.397 0.039

486000 Pipeline transportation 0.354 0.085

327992 Ground or treated minerals and earths manufacturing 0.352 0.050

484000 Truck transportation 0.295 0.003

324110 Petroleum refineries 0.289 0.010

322130 Paperboard Mills 0.239 0.016

482000 Rail transportation 0.233 0.004C

- 6



### In summary, from the perspective of energy and air emissi ons, cement manufacturing leads to large impacts, and is in general the largest source of emissions across the supply chain. Reducing the amount of cement produced through beneficial use of fly ash can lead to large supply chain

wide reductions of emissio ns.



## Gypsum Analysis

Within EIO

- LCA, the industry “Sector #212390: Other Nonmetallic Mineral Mining” was selected for analysis. This industry is aggregated to include many products and processes (and thus is less representative of a specific industry like wallboard manufacture than the sector representing cement manufacturing above). This U.S. industry comprises establishments primarily engaged in developing the mine site, mining and/or milling, or otherwise beneficiating (i.e., preparing) natural potassiu m, sodium, or boron compounds, phosphate rock, fertilizer raw materials, or nonmetallic minerals. There are many products of this industry, a few of which are

summarized below:

 Borate, natural, mining and/or beneficiating

 Phosphate rock mining and/or bene ficiating

 Gypsum mining and/or beneficiating

 Peat grinding

We ran the EIO

- LCA selecting the following conditions: US 2002 as the model, other nonmetallic mineral mining as the sector, one million dollars of economic activity, and displaying
results in term s of economic activity. Exhibit C

- 5 displays the resulting summary estimate of supply

- chain wide economic impacts. As shown in the “Total Economic” column of Exhibit C

- 5, there are significant purchases of electricity, oil and gas, and construction machi nery, etc. across the supply chain. This is due to the recognized significant fuel and energy inputs needed to produce nonmetallic minerals like gypsum.C

- 7 EXHIBIT C

- 5: TOP SECTORS THAT SUP PORT NONMETALLIC MIN ERAL MINING

– - AS A

PROXY FOR GYPSUM MANUFACT URING

- - IN THE US IN 2002 (ECONOMIC)

SECTOR TOTAL

ECONOMIC
$ MILLIONS VALUE

ADDED
$ MILLIONS DIRECT

ECONOMIC

%

Total for all sectors 1.92 0.991 77.6

212390 Other nonmetallic mineral mining 0.928 0.473 99.9

211000 Oil and gas extraction 0.096 0.049 68.0

550000 Management of companies and enterprises 0.071 0.044 69.3

221100 Power generation and supply 0.069 0.047 87.5

484000 Truck transportation 0.056 0.025 83.3

541300 Architectural and engineering services 0.038 0.023 65.1

21311A Support act ivities for other mining 0.037 0.011 91.1

327992 Ground or treated minerals and earths

manufacturing 0.033 0.018 99.2

221200 Natural gas distribution 0.031 0.010 87.5

420000 Wholesale trade 0.030 0.021 40.7



### Exhibit C

- 5 also summarizes which of the purchases are “direct,” (i.e., those made directly by the nonmetallic mineral company). For example EIO

- LCA estimates that 77.6 percent of the electricity purchases across the entire supply chain of nonmetallic minerals mining are direct.
That means tha t only 12.4 percent of total electricity purchases in the supply chain come from all other sectors’ purchases of electricity, including well

- known electricity intensive sectors like manufacturing. This would include electricity purchased by oil and gas pr oduction and distribution, machinery manufacturing, etc. Note that this level of direct purchases is very large compared to the usual electricity direct purchases that come from other sectors.

EIO

- LCA also displays estimates of emissions and energy use ac ross the supply chain, as shown
in Exhibits C

- 6 and C

- 7. Exhibit C

- 6 summarizes emissions of conventional air pollutants, and is sorted by SO 2 

### emissions ; these results are from running the US 1997 model, because conventional air pollutant figures are not available for the US 2002 model. Most (85 percent) of

SO 2 

### emitted across the supply chain of nonmetallic minerals comes from power generation ; less than five percent is from the mining of the nonmetallic minerals. Almost half of NOx emissions come from p ower generation, followed by truck and rail transport ; less than ten percent is from nonmetallic mineral mining. About 80 percent of CO emissions result from truck transportation

, while less than one percent results from nonmetallic mineral mining. About 40 percent of PM 10 

### emissions come from nonmetallic mineral mining , followed by about 15 percent from power generation. In short, nonmetallic mineral mining itself is a very polluting process, and avoiding emissions from its manufacture can have large soc ial benefits, but emissions from energy production and transportation are higher in some cases

.C

- 8 EXHIBIT C

- 6: AIR EMISSIONS OF TOP 10 EMITTING SECTORS THAT SUPPORT

NONMETALLIC MINERAL MINING IN TH E US IN 1997 (SORTED BY SO 2 )

SECTOR SO 2

MT CO

MT NOX

MT V OC

MT LEAD

MT PM 10

MT

Total for all sectors 3.47 9.41 2.85 1.72 0.000 0.421

221100 Power generation and supply 2.94 0.145 1.33 0.013 0.000 0.062

212390 Other nonmetallic mineral mining 0.151 0.051 0.241 0.656 0 0.169

211000 Oil and gas extraction 0.05 3 0.089 0.039 0.060 0 0.002

212310 Stone mining and quarrying 0.043 0.080 0.030 0.015 0 0.009

324110 Petroleum refineries 0.040 0.023 0.009 0.032 0 0.004

325180 Other basic inorganic chemical

manufacturing 0.033 0.004 0.002 0.002 0 0.002

484000 Truck t ransportation 0.022 7.39 0.533 0.550 0.000 0.013

213112 Support activities for oil and gas

operations 0.021 0.018 0.013 0.006 0 0.003

331111 Iron and steel mills 0.021 0.176 0.016 0.010 0.000 0.015

482000 Rail transportation 0.016 0.034 0.297 0.014 0 0. 007



### Exhibit C

- 7 summarizes supply chain wide use of energy and electricity for producing nonmetallic minerals. The nonmetallic mineral mining sector consumes about 70 percent of total supply chain primary energy (and almost 80 percent of electricity, as noted above). Other sectors consuming high but less significant amounts of energy (in the form of fuels) are power generation, truck and pipeline transportation sectors, and petroleum refining.

EXHIBIT C

- 7: TOP 10 SECTORS USING ENERGY THAT SUPPORT NONMET ALLIC MINERAL

MINING IN 2002 (SORTED BY TOTAL ENE RGY USE)

SECTOR

TOTAL

TJ NON

- FOSSIL

ELECTRICITY

TJ

Total for all sectors 31.3 4.64

212390 Other nonmetallic mineral mining 18.8 3.88

221100 Power generation and supply 7.542 0.176

211000 Oil and gas extraction 0.899 0.088

484000 Truck transportation 0.726 0.007

331110 Iron and steel mills 0.513 0.062

327992 Ground or treated minerals and earths manufacturing 0.396 0.056

324110 Petroleum refineries 0.305 0.011

3274A0 Lime and gypsum product man ufacturing 0.275 0.023

486000 Pipeline transportation 0.241 0.058

482000 Rail transportation 0.208 0.003C

- 9



## Context: Concrete production and wallboard manufacturing While the beneficial use studies focus on the substitution of waste products for virgin p roducts, and the estimates above identify the avoided energy, cost, and emissions of these substitutions, it is important to put into context the effects of the beneficial use. In this section we briefly show

EIO

- LCA results for the broader picture of con crete manufacturing (where fly ash is used in place of some cement) and wallboard manufacturing (where FGD gypsum is used in place of virgin gypsum). We do this to see how important these raw materials (cement and gypsum) are in the supply chain of produc ing these final products.

Exhibit C

- 8 shows the top ten sectors that contribute to air emissions, and Exhibit C

- 9 the top ten sectors that consume energy, in the production of concrete . Both outputs were attained by running the model using the ready

- mix c oncrete sector and $1 million economic activity; though air emissions was run with the 1997 model since 2002 figures are not available, and energy consumption was run with the 2002 model. Exhibit C

- 8 (sorted by SO 2 

### emissions) demonstrates

that in the manu facture of concrete, the emissions from cement manufacturing account for the majority of SO 2 

### , NOx, VOC, and PM 10 

### emissions. CO emissions are dominated by truck transportation. Similarly Exhibit C

- 9 shows that cement manufacture represents 40 percent of

e nergy use, and almost 50 percent of electricity use. This implies that any reduction in the amount of cement needed has a large benefit in the life cycle emissions and energy use of concrete. Thus, fly ash substitution even at 20 percent substitution rate s is quite beneficial.

EXHIBIT C

- 8: AIR EMISSIONS OF TOP 10 EMITTING SECTORS THAT SUPPORT CONCRETE

MANUFACTURING IN THE US IN 1997 (SORTED BY SO 2 )

SECTOR SO 2

MT CO

MT NOX

MT VOC

MT LEAD

MT PM 10

MT

Total for all sectors 6.29 16.9 7.90 5.64 0.001 1.03

327310 Cement manufacturing 3.74 2.43 4.78 3.74 0.000 0.582

221100 Power generation and supply 1.61 0.080 0.728 0.007 0.000 0.034

212310 Stone mining and quarrying 0.570 1.07 0.401 0.202 0 0.118

483000 Water transportation 0.072 0.050 0.382 0.367 0 0.0 35

325180 Other basic inorganic chemical

manufacturing 0.055 0.006 0.004 0.003 0 0.003

484000 Truck transportation 0.034 11.3 0.814 0.840 0.000 0.020

482000 Rail transportation 0.025 0.055 0.475 0.022 0 0.011

211000 Oil and gas extraction 0.024 0.041 0 .018 0.027 0 0.000

324110 Petroleum refineries 0.021 0.012 0.005 0.017 0 0.002

325998 Other miscellaneous chemical product

manufacturing 0.013 0.000 0.015 0.003 0 0.001C

- 10 EXHIBIT C

- 9: TOP 10 SECTORS USING ENERGY THAT SUPPORT CONCRETE

M ANUFACTURING IN TH E US IN 2002 (SORTED BY TOTAL ENE RGY USE)

SECTOR TOTAL

TJ NON

- FOSSIL

ELECTRICITY

TJ

Total for all sectors 23.5 2.08

327310 Cement manufacturing 10.7 0.991

221100 Power generation and supply 3.67 0.086

327320 Ready

- mix concrete manufacturing 2.55 0 .216

484000 Truck transportation 1.42 0.013

212320 Sand, gravel, clay, and refractory mining 0.977 0.173

325190 Other basic organic chemical manufacturing 0.549 0.03

212310 Stone mining and quarrying 0.392 0.082

324110 Petroleum refineries 0.351 0.013

211000 Oil and gas extraction 0.251 0.025

482000 Rail transportation 0.239 0.004



### For gypsum in wallboard manufacturing, a similar method is used, but the sector used to model wallboard (Sector #327420: Gypsum Product Manufacturing) is more aggr egated than that used to model concrete. This industry comprises establishments primarily engaged in manufacturing gypsum products such as wallboard, plaster, plasterboard, molding, ornamental moldings, statuary, and architectural plaster work. Gypsum pr oduct manufacturing establishments may mine, quarry, or purchase gypsum. Examples of activities in this sector include:

 Board, gypsum, manufacturing

 Gypsum building products manufacturing

 Gypsum products (e.g., block, board, plaster, lath, rock, tile ) manufacturing

 Joint compounds, gypsum based, manufacturing

 Wallboard, gypsum, manufacturing

Despite the limitations in modeling wallboard as an exclusive product, Exhibits C

- 10 and C

- 11 show the results of the supply chain air emissions and energy use fr om the gypsum product manufacturing sector in EIO

- LCA (as a proxy for gypsum wallboard manufacturing). Both models are run for 1997, because the 2002 model does not separately distinguish gypsum product manufacturing as a sector.C

- 11 EXHIBIT C

- 10: AIR EMISS IONS OF TOP 10 EMITT ING SECTORS THAT SUP PORT GYPSUM

PRODUCT MANUFACTURIN G IN THE US IN 1997 (SORTED BY SO 2 )

SECTOR SO 2

MT CO

MT NOX

MT VOC

MT LEAD

MT PM 10

MT

221100 Total for all sectors 3.44 18.1 3.94 5.23 0.000 1.02

212310 Power generation and supply 2.22 0.109 1.00 0.010 0.000 0.047

327310 Stone mining and quarrying 0.508 0.951 0.358 0.180 0 0.105

483000 Cement manufacturing 0.284 0.185 0.363 0.284 0.000 0.044

3221A0 Water transportation 0.071 0.049 0.374 0.360 0 0.035

484000 Paper and paperboard mills 0.060 0.406 0.085 0.033 0 0.045

211000 Truck transportation 0.039 12.7 0.918 0.947 0.000 0.022

324110 Oil and gas extraction 0.036 0.061 0.027 0.041 0 0.001

482000 Petroleum refineries 0.025 0.014 0.006 0.020 0 0.003

221200 Rail transportation 0 .019 0.041 0.354 0.017 0 0.008

221100 Natural gas distribution 0.019 0.000 0.036 0.129 0 0.001



### Exhibit C

- 10 summarizes the air emissions across the manufacturing supply chain for gypsum products (sorted by SO 2 

### emissions). Recall that gypsum was modeled by production of the nonmetallic mineral mining sector (and this is the virgin product we would be replacing). Nonmetallic mineral mining is not in the top ten emissions sources in any of the tracked conventional air emissions for gypsum product manufact uring. Exhibit C

- 11 shows that the nonmetallic mineral mining sector represents about five percent of total energy use of gypsum products.

EXHIBIT C

- 11: TOP 10 SECTORS USING ENERGY THAT SUPPORT GYPSUM PRODUCT

MANUFACTURING IN THE US IN 1997 (SORTED BY TOT AL ENERGY USE)

SECTOR TOTAL

TJ

Total for all sectors 24

327420 Gypsum product manufacturing 9.5

221100 Power generation and supply 4.84

3221A0 Paper and paperboard mills 2.16

484000 Truck transportation 1.29

212390 Other nonmetallic mineral m ining 1.25

327310 Cement manufacturing 0.698

483000 Water transportation 0.476

327992 Ground or treated minerals and earths manufacturing 0.377

324110 Petroleum refineries 0.28C

- 12



### Compared to the results for concrete manufacturing sector above, this wallboard example is less clear. The wallboard sector was approximated by a highly aggregated sector and is not an accurate representation of wallboard manufacturing in our attempt to model gypsum substitution. This sector seems to more generally de pend on stone sectors for its inputs.

# APPENDIX D | DETAILS OF FLY ASH AND FGD GYPSUM LIFE

CYCLE INVENTORY ANALYSIS METHODOLOGI ESD

- 1



## BEES ANALYSIS OF FLY ASH IN CONCRETE We calculate the unit impacts of using fly ash as a substitute for finished portla nd cement in concrete as the difference in impacts between concrete made with 100 percent portland cement
and concrete made with 15 percent fly ash and 85 percent portland cement. Exhibits D

- 1 and D

- 2 show the lifecycle stages modeled by BEES in the produc tion of concrete with and without blended cement. These diagrams represent the baseline and beneficial use scenarios evaluated in the fly ash analysis.

EXHIBIT D

- 1: CONCRETE WITHOUT BLENDED CEMENT FLOW

- CHART (BASELINE SCEN ARIO)

EXHIBIT D

- 2: CONCRETE WI TH BLENDED CEMENT FL OW

- CHART (BENEFICIAL US E

SCENARIO)D

- 2



### It is important to note that in Exhibit D

- 2, BEES does not actually model the impacts of fly ash “production” from coal combustion (i.e. BEES does not allocate electricity production impacts to fly ash).



## BEES Life Cycle inventory Data

Exhibit s D

- 3 and D

- 4 present the complete BEES lifecycle inventory data for a one cubic foot generic
concrete beam made with out and with blended cement (i.e. fly ash). The data fields in the Exhibit s are defined as fol lows:

 XPORT DIST: Transport distance of concrete beam to construction site.

 FLOW: The environmental impact being reported.

 UNIT: The unit in which the environmental flow is reported.

 TOTAL: The total impact across all life cycle stages for all three compon ents (i.e., the sum of
fields COMP1 and COMP2).

 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.

 COMP2: The total impact across all life cycle stages for Compone nt 2. Component 2 refers to the first installation component associated with the concrete beam, but BEES does not provide a specific definition.

 RAW1: Impacts associated with raw materials extraction for Component 1.

 RAW2: Impacts associated with raw mater ials extraction for Component 2.

 MFG1: Impacts associated with manufacturing of Component 1.

 MFG2: Impacts associated with manufacturing of Component 2.

 XPORT1: Impacts associated with transport of Component 1.

 XPORT2: Impacts associated with transport of Component 2.

 USE1: Impacts associated with use of the total product (all components).

 WASTE1: Impacts associated with disposal of the total product (all components).D

- 3

EXHIBIT D

- 3: BEES LIFE CYCLE INVE NTORY DATA FOR GENERIC CONCRETE BEAM WITHOU T BLENDED CEM ENT

BEES Data File B1011A

- Generic 100% Portland Cement 4KSI

- 50 miles

XPORT DIST FLOW UNITS TOTAL COMP1 COMP2 RAW1 RAW2 MFG1 MFG2 XPORT2 XPORT1 USE1 WASTE1

50 Product cubic ft 1 0 0 0 0 0 0 0 0 0 0

50 Main component kg 67.3329 67.3329 0 0 0 0 0 0 0 0 0

50 Total Primary Energy MJ 154 70.58 82.99 64.1 82.6 0 0 6.48 0.39 0 0

50 Non Renewable Energy MJ 115 70.58 44.59 64.1 44.2 0 0 6.48 0.39 0 0

50 Renewable Energy MJ 38.3 0 38.3 0 38.3 0 0 0 0 0 0

50 Water Used (total) l 19.2 10.6 8.62 10.6 8.62 0 0 0 0 0 0

50 (a) Carbon Dioxide (CO2, biomass) g 674 0 674 0 674 0 0 0 0 0 0

50 (a) Carbon Dioxide (CO2, fossil) g 13100 10177 2899.3 9690 2870 0 0 487 29.3 0 0

50 (a) Carbon Monoxide (CO) g 37.9 21.07 16.849 18.6 16.7 0 0 2.47 0.149 0 0

50 (a) Lead (Pb) g 0.0091 0.0001 0.009 0.0001 0.009 0 0 0 0 0 0

50 (a) Mercury (Hg) g 0.0008 0.0005 0.0002 0.0005 0.0002 0 0 0 0 0 0

50 (a) Methane (CH4) g 13.7 9.765 3.917 9.15 3.88 0 0 0.615 0.037 0 0

50 (a) Nitrogen Oxides (NOx as NO2) g 49.9 43.41 6.52 40.1 6. 32 0 0 3.31 0.2 0 0

50 (a) Particulates (PM 10) g 1.41 0.5329 0.8815 0.475 0.878 0 0 0.0579 0.0035 0 0

50 (a) Particulates (greater than PM10) g 0 0 0 0 0 0 0 0 0 0 0

50 (a) Particulates (unspecified) g 68.5 65.9415 2.5525 65.9 2.55 0 0 0.0415 0.0025 0 0

50 (a) Sulfur Oxides (SOx as SO2) g 35.5 25.288 10.2414 24.6 10.2 0 0 0.688 0.0414 0 0

50 (w) BOD5 (Biochemical Oxygen Demand) g 3.83 0.5316 3.2956 0.439 3.29 0 0 0.0926 0.0056 0 0

50 (w) COD (Chemical Oxygen Demand) g 1.24 0.991 0.2496 0.815 0.239 0 0 0.176 0.0106 0 0

50 (w) Copper (Cu+, Cu++) g 0.0009 0.0008 0.0001 0.0006 0.0001 0 0 0.0001 0 0 0

50 (w) Lead (Pb++, Pb4+) g 0.0025 0.0016 0.001 0.0013 0.001 0 0 0.0003 0 0 0

50 (w) Mercury (Hg+, Hg++) g 0 0 0 0 0 0 0 0 0 0 0

50 (w) Suspended Matter ( unspecified) g 10 8.8 1.21 7.47 1.13 0 0 1.33 0.08 0 0

50 (w) Selenium (Se II, Se IV, Se VI) g 0.0001 0.0001 0 0.0001 0 0 0 0 0 0 0

50 Waste (end

- of

- Life) kg 70.8 0 0 0 0 0 0 0 0 0 70.8D

- 4

EXHIBIT D

- 4: BEES LIFE CYCLE INVE NTORY DATA FOR GENERIC CONCRETE BE AM WITH BLENDED CEME NT

BEES Data File B1011B

- Generic 15% Fly Ash Cement 4KSI

- 50 miles

XPORT DIST FLOW UNITS TOTAL COMP1 COMP2 RAW1 RAW2 MFG1 MFG2 XPORT2 XPORT1 USE1 WASTE1

50 Product cubic ft 1 0 0 0 0 0 0 0 0 0 0

50 Main component kg 67.3445 67. 3445 0 0 0 0 0 0 0 0 0

50 Total Primary Energy MJ 147 63.78 82.99 57.3 82.6 0 0 6.48 0.39 0 0

50 Non Renewable Energy MJ 108 63.78 44.59 57.3 44.2 0 0 6.48 0.39 0 0

50 Renewable Energy MJ 38.3 0 38.3 0 38.3 0 0 0 0 0 0

50 Water Used (total) l 18.3 9.63 8.62 9.63 8.62 0 0 0 0 0 0

50 (a) Carbon Dioxide (CO2, biomass) g 674 0 674 0 674 0 0 0 0 0 0

50 (a) Carbon Dioxide (CO2, fossil) g 11800 8927 2899.3 8440 2870 0 0 487 29.3 0 0

50 (a) Carbon Monoxide (CO) g 36.1 19.27 16.849 16.8 16.7 0 0 2.47 0.149 0 0

50 (a) Lead (Pb) g 0.0091 0.0001 0.009 0.0001 0.009 0 0 0 0 0 0

50 (a) Mercury (Hg) g 0.0007 0.0004 0.0002 0.0004 0.0002 0 0 0 0 0 0

50 (a) Methane (CH4) g 12.6 8.705 3.917 8.09 3.88 0 0 0.615 0.037 0 0

50 (a) Nitrogen Oxides (NOx as NO2) g 46.4 39.9 2 6.52 36.6 6.32 0 0 3.32 0.2 0 0

50 (a) Particulates (PM 10) g 1.4 0.5229 0.8815 0.465 0.878 0 0 0.0579 0.0035 0 0

50 (a) Particulates (greater than PM10) g 0 0 0 0 0 0 0 0 0 0 0

50 (a) Particulates (unspecified) g 65.4 62.8415 2.5525 62.8 2.55 0 0 0.0 415 0.0025 0 0

50 (a) Sulfur Oxides (SOx as SO2) g 32.3 22.088 10.2414 21.4 10.2 0 0 0.688 0.0414 0 0

50 (w) BOD5 (Biochemical Oxygen Demand) g 3.8 0.4996 3.2956 0.407 3.29 0 0 0.0926 0.0056 0 0

50 (w) COD (Chemical Oxygen Demand) g 1.18 0.933 0.2496 0. 757 0.239 0 0 0.176 0.0106 0 0

50 (w) Copper (Cu+, Cu++) g 0.0009 0.0007 0.0001 0.0006 0.0001 0 0 0.0001 0 0 0

50 (w) Lead (Pb++, Pb4+) g 0.0025 0.0015 0.001 0.0012 0.001 0 0 0.0003 0 0 0

50 (w) Mercury (Hg+, Hg++) g 0 0 0 0 0 0 0 0 0 0 0

50 (w) Suspen ded Matter (unspecified) g 9.36 8.14 1.21 6.81 1.13 0 0 1.33 0.08 0 0

50 (w) Selenium (Se II, Se IV, Se VI) g 0.0001 0.0001 0 0.0001 0 0 0 0 0 0 0

50 Waste (end

- of

- Life) kg 70.8 0 0 0 0 0 0 0 0 0 70.8D

- 5 D

- 5 

## Calculation of Unit Impacts

To illustrate the metho dology used to calculate the unit impact values from the BEES life cycle inventory data, we present a sample calculation of CO 2 

### reductions resulting from the substitution of one ton of fly ash for finished p ortland cement in concrete (see Exhibit D

- 5 ).

E XHIBIT D

- 5: EXAMPLE CALCULATION OF IMPACT METRIC FOR CO 2 RELATED TO FLY ASH

SUBSTITUTION IN CONC RETE

CALCULATION 4 KSI CONCRETE

BEAM NOTE/SOURCES

IMPACTS PER CUBIC YA RD CONCRETE

100% portland cement [a] 353,700 grams per cubic yard of concrete Values represent impacts related to a 4 KSI

concrete beam as characterized in BEES data file B1011A. BEES Version 4 .0 Performance Data.

15% coal fly ash [b] 318,600 grams per cubic yard of concrete Values represent impacts related to building

products and pave ment as characterized in BEES data file B1011B. BEES Version 4 .0 Performance Data.

Incremental benefit [c]=[a]

- [b] 35,100 grams per cubic yard of concrete Represents avoided CO 2 , in grams per cubic yard

of concrete product substituting 15% coal fly ash f or p ortland cement.

IMPACTS PER U.S. SHO RT TON FLY ASH

lbs cement/yd 3 concrete [d] 470 lbs cement/cubic yard of concrete Represents proportion of one cubic yard of

concrete made up of cementitious material, given a mix

- design or constituent density (Lip iatt, 2002, p. 40). Percent coal fly ash substitution [e] 15% Fifteen percent of cementitious material is replaced with coal fly ash.

lbs/U.S. short ton [f] 2000 lbs/ton Conversion factor for pounds to tons.

tons fly ash/yd 3 concrete [g]=[d]*[e]/[f] 0.0 352 tons coal fly ash/cubic yard of concrete Conversion of quantity of coal fly ash in one

cubic yard of concrete from pounds to tons.

unit impact [h]=[c]/[g] 995,744 grams per ton of coal fly ash substituted for
cement Represent unit impact values for CO 2 (in grams),

based on substitution of one ton of coal fly ash for 1 ton portland cement in concrete.



### The process outlined in Exhibit D

- 5 is repeated for each of the environmental metrics evaluated in this analysis using the environmental performance dat a reported in BEES. For each environmental metric, this yields an estimate of the benefit of one ton of fly ash replacing finished portland cement in concrete.D

- 6 D

- 6 

## SIMAPRO ANALYSIS OF FGD GYPSUM IN WALLBO ARD We calculate the unit impacts of using FGD gypsum in place of virgin gypsum stucco in wallboard as the difference in impacts between wallboard made with 100 percent virgin gypsum
and wallboard made with 100 percent FGD gypsum. Exhibits D

- 6 and D

- 7 show the lifecycle stages in the production of wallboard w ith 100 percent virgin gypsum and 100 percent FGD gypsum, respectively. The boxes with dashed lines represent life cycle stages that are unique to virgin or FGD gypsum.

EXHIBIT D

- 6: VIRGIN GYPSUM WALLBO ARD MANUFACTURE

EXHIBIT D

- 7: FGD G YPSUM WALLBOARD MANU FACTURE 

### Gypsum Mining Stucco Manufacture

Wallboard
Manufacture

Material Transport

Paper

Production

Dewatering Wallboard

Manufacture

Material Transport

Paper

Production Flu Gas

D esulphurizationD

- 7 D

- 7 

### As shown in Exhibits D

- 6 and D

- 7, by replacing virgin gypsum stucco with FGD gypsum, gypsum mining and stucco manufacture can be avoided but a dewatering step is added to the lifecycle. We model these impacts as one to n of avoided “stucco” manufacture in SimaPro. 78 

### Stucco is the term used in SimaPro to describe the gypsum material used in wallboard. We selected the EcoInvent data set because it includes gypsum mining but also includes the processing of gypsum for use in wallboard (i.e., burning of gypsum and milling of stucco for use in gypsum wallboard). Thus, this dataset includes all the processes that would be avoided if an equivalent quantity of FGD gypsum were used in place of stucco in wallboard. The production of FGD gypsum through the coal combustion process is not modeled, as discussed in Chapter 4. In addition, this analysis assumes that FGD gypsum dewatering occurs via holding ponds and that the environmental impacts are negligible. 79 

### This analysis also does not model transport distance; we assume FGD gypsum would have the same transport distances to the construction site as virgin gypsum. 80 

### Thus avoided gypsum mining and avoided processing of gypsum into stucco, as represented by the EcoInvent stucco manufacturi ng data set, are the only lifecycle stages modeled
in SimaPro.

Exhibit D

- 8 presents the assumed life cycle system boundaries for the EcoInvent stucco manufacturing data set. The cut

- off node for the process flow tree depicted in Exhibit D

- 8 is set to

0.5 p ercent so that the entire tree could be viewed. Thus, this process tree lists the flows
associated with 99.5 percent of the total life cycle impacts for one ton of stucco manufacture. 81 

### The numbers that appear in the bottom left

- hand corner of each box in t he tree are partition factors used by SimaPro and are not central to this analysis.

The EcoInvent dataset for stucco manufacture is the only stucco dataset available in SimaPro, but because it reflects Swiss manufacturing processes and electricity mix, we modified the data for stucco manufacture to reflect the average U.S. electricity mix. We made this modification by substituting the electricity used to make stucco from gypsum, as well as the electricity used further down the production chain in gypsum min ing, with the EcoInvent data set for average U.S. electricity mix titled “Electricity, medium voltage, at grid/US U”. The EcoInvent data set includes the fuel consumption associated with the generation and delivery of an average kilowatt

hour in the USA us ing average USA technology in the mid 2000's. While we did not substitute the U.S. electricity mix at points further down the stucco production chain, the stucco manufacturing and gypsum mining processes account for the majority of electricity use in this analysis.

78 We use the EcoInvent data set titled “Stucco, at plant/CH U” for this purpose.

79 There may actually be emissions/dusting impacts associated with dewatering in a holding pond, but we have been unable to iden tify
quantified estimates of these impacts. Alternatively, dewatering may be accomplished through mechanical processes but we we re also
unable to identify the energy impacts of mechanical dewatering.

80 We do not model a transport differential between virgin and FGD gypsum to be consistent with the transport assumptions used i n the
BEES fly ash analysis, which helps preserve the c omparability of the fly ash and FGD gypsum unit impact values. It is important to note,
however, that an increasing number of new gypsum wallboard plants are being constructed adjacent to coal

- fired power plants, so
transport distance of FGD gypsum to the wallboard manufacturing facility may, in some cases, be less than the transport distance of
virgin gypsum.

81 The tree is presented for the “single score” of all life cycle impacts, calculated using the Eco

- Indicator 99

- H, v2.04 impact assessment

method.D

- 8

EXHIBIT D

- 8: LIFE CYCLE SYSTEM BO UNDARIES FOR STUCCO MANUFACTURE, 0.5% CU T

- OFFD

- 9



## SimaPro Life Cycle Inventory Data

Exhibit D

- 9 presents the SimaPro lifecycle inventory data for stucco manufacture for the same metrics evaluated in the BEES analysi s.
In order to easily compare the results of the FGD gypsum analysis with those of the fly ash analysis, it was necessary to convert the environmental metrics reported by SimaPro into the same units that are reported by BEES. For most metrics, this require d only a simple conversion between different units of mass. In the case of energy use, however, SimaPro reports quantities of various fossil fuels consumed whereas BEES reports energy consumed in megajoules. To convert the fossil fuel quantities reported b y SimaPro into equivalent energy content in megajoules, we relied on the Energy Information Administration’s Coal, Natural Gas, and Crude Oil Conversion Calculators. 82



### In addition, SimaPro does not report a single “water use” metric, as is done in BEES, bu t breaks out fresh water use by origin (e.g., lake, river, well, etc.) and application (cooling, turbine, etc). We sum the following metrics (converted to liters) to obtain the water use figure in the FGD gypsum analysis: 1) Water, cooling, unspecified nat ural origin/m 3 

### , 2) Water, lake, 3) Water, river, 4) Water, turbine use, unspecified natural origin, 5) Water, unspecified natural origin/m 3 

### , and 6) Water, well, in ground.

82 Accessed at http://www.eia.doe.gov/kids/energyfacts/science/energy_calculator.html#coalcalc

.D

- 10

EXHIBIT D

- 9: SIMAPRO LCI DATA FOR ONE TON STUCCO, AT PLANT

SUBSTANCE COMPARTMENT UN IT STUCCO, AT
PLANT/CH U (U.S.
ENERGY MIX) CONVERTED TO BEES

UNITS NOTES

Gypsum, in ground Raw kg 1172.49

Total Energy MJ 1,470.76

Non

- Renewable Energy MJ 1,454.71

Coal, brown, in ground Raw kg 1.37 MJ 32.07 *converted using the E IA's Energy Calculator a

Coal, hard, unspecified, in ground Raw kg 9.03 MJ 211.86 *converted using the EIA's Energy Calculator a

Gas, mine, off

- gas, process, coal
mining/m3 Raw m3 0.06 MJ 2.34 *converted using the EIA's Energy Calculator a

Gas, natural, in ground Raw m3 24.70 MJ 946.06 *converted using the EIA's Energy Calculator a

Oil, crude, in ground Raw kg 5.85 MJ 262.38 *converted using the EIA's Energy Calculator a

Renewable Energy MJ 16.046
Energy, gross calorific value, in

biomass Raw MJ 4. 39 MJ 4.386
Energy, gross calorific value, in
biomass, primary forest Raw MJ 1.77E

- 03 MJ 0.002
Energy, potential (in hydropower
reservoir), converted Raw MJ 11.05 MJ 11.049

Energy, kinetic (in wind), converted Raw MJ 0.59 MJ 0.589

Energy, solar , converted Raw MJ 0.02 MJ 0.020

Fresh Water Use liter 98,075.97
Water, cooling, unspecified natural
origin/m3 Raw m3 0.77 liter 765.70D

- 11 SUBSTANCE COMPARTMENT UN IT STUCCO, AT
PLANT/CH U (U.S.
ENERGY MIX) CONVERTED TO BEES

UNITS NOTES

Water, lake Raw m3 6.66E

- 04 liter 0.67

Water, river Raw m3 0.06 liter 60.60

Water, turbine use, uns pecified
natural origin Raw m3 97.21 liter 97209.90
Water, unspecified natural
origin/m3 Raw m3 0.03 liter 28.40

Water, well, in ground Raw m3 0.01 liter 10.70

Carbon dioxide g 86895.82

Carbon dioxide, biogenic Air kg 0.40

Carbon d ioxide, fossil Air kg 86.49

Carbon dioxide, land transformation Air kg 1.87E

- 03

Carbon Monoxide g 41.93

Carbon monoxide, biogenic Air kg 5.86E

- 05

Carbon monoxide, fossil Air kg 0.04

Lead Air kg 3.42E

- 05 g 3.42E

- 02

Me rcury Air kg 1.04E

- 06 g 1.04E

- 03

Methane g 189.28

Methane, biogenic Air kg 5.63E

- 04

Methane, fossil Air kg 0.19

Nitrogen oxides Air kg 0.15 g 168.02

Ozone Air kg 1.44E

- 04 g 0.011

Particulates < PM10 g 520.93

Particu lates, < 2.5 um Air kg 0.10D

- 12 SUBSTANCE COMPARTMENT UN IT STUCCO, AT
PLANT/CH U (U.S.
ENERGY MIX) CONVERTED TO BEES

UNITS NOTES

Particulates, > 2.5 um, and < 10um Air kg 0.47

Particulates, > 10 um Air kg 1.33 g 1,332.96

Sulfur oxides Air kg 0.21 g 211.65

BOD5, Biological Oxygen Demand Water kg 0.03 g 25.47

COD, Chemical Oxygen Dema nd Water kg 0.03 g 26.61

Copper, ion Water kg 2.25E

- 06 g 0.002

Lead Water kg 6.37E

- 06 g 6.37E

- 03

Mercury Water kg 5.99E

- 08 g 5.99E

- 05

Suspended solids, unspecified Water kg 0.01 g 13.92

Selenium Water kg 6.72E

- 06 g 6.72E

- 03

Waste, solid W aste kg 0 kg 0 Value n ot measured in SimaPro record

Notes:

a. Accessed at http://www.eia.doe.gov/kids/energyfacts/science/energy_calculator.html#coalcalc.

# APPENDIX E | POTENTIAL IMPACTS OF ALLOCATION OF LCI RESULTS TO CCP sE

- 1



### While the backgrou nd literature (ISO framework, etc.) are relatively consistent in their discussion that only co

- products should share allocation of input and output system flows, this rule leaves out the
consideration of current and future “waste streams” that have benefic ial use potential, or market value that suggests that they may be usefully treated as co

- products , either because their markets are already evolving or because policies under consideration could encourage the evolution of markets

. This observation is insp ired by the need to consider the net impacts of CCPs in electricity generation when looking at the life cycle impacts associated with beneficial use. While there are beneficial substitutions possible of fly ash for cement, FGD gypsum for virgin gypsum, et c., it is possible that if the
CCPs were in fact treated as co

- products instead of as wastes, that there would be non

- negligible inputs and outputs from coal

- fired electricity generation that merited attention when estimating net impacts. In

this section we consider some hypothetical macro

- level scenarios for coal

- fired power generation, as well

as macro

- level flows of several key CCPs. These scenarios are then applied in an assessment of implications of allocating the environmental effects of power gener ation to both the energy product and

the CCPs.

Traditional LCA allocation rules suggest that product and co

- product allocation by economic value, mass, energy, etc., are all legitimate methods

– there is no single approach to allocating that is correct. F or the first illustration, we show an approximate economic value based allocation and the resulting effects for CCPs, followed by a prospective mass

- based method.



## ECONOMIC ALLOCATION The electricity industry has about $300 billion per year in gross revenu es. Roughly 50 percent of generation is coal

- fired at the national level. Even though the costs and revenues per kilowatt hour vary across generation types, and the total value includes generation, transmission, and distribution, for simplicity we assume that there is 50 percent, or $150 billion of revenues from coal

- fired power generation. If we were to adjust for the variations in price per kilowatt hour, this value would likely be closer to $100 billion from coal

- fired generation, as coal represents a lower

- cost form of energy production.

From ACAA ( 200 8 ) and USGS ( 2010 ), we consider the upper bound economic value of various CCPs, using both the high end of estimated market value for the CCPs, as well as the high end estimate of CCPs produced, and not the quantity used. Table E

- 1 summarizes these results for the top three CCPs in terms of market value and production.

TABLE E

- 1: OPTIMISTIC SCENA RIO OF CCP MARKET VA LUES (ACAA 200 8 , USGS 2006)

CCP 2009 MARKET VALUE

(PER TON) CCP PRODUCTION

(MILLION TONS ) TOTAL MARKET VALUE

(ABSOLUTE UPPER BOUN D)

Fly Ash $ 49.53 72.5 $3. 59 billion FGD Gypsum $ 8.81 1 7.8 $0. 16 billion

Bottom Ash $8 .81 1 8.4 $0. 16 billion

Total

-- ------- 10 8.6 $3. 91 billion



### Summing the total value of these three products yields $3 .5 billion. Even this upper

- bound estimate is only 2 to 3 percent of the value of the electricity produced, if considered as shares of the total economicE

- 2



### value of the product (electricity) and co

- products (CCPs) created by coal

- fired power plants. Of cou rse, the values in Table E

- 1 are highly optimistic, and ACAA estimates that fly ash market value ranges from $ 20

- 45/ton in 2003 , and bottom ash from $4

- 8 per ton in 2003 . Thus, the actual economic value allocation would likely be significantly smaller

– p robably less than one percent . As these were the “best case” allocation results, it seems that allocating by economic value would lead to negligible results.



## MASS

- BASED ALLOCATION The example above is straightforward in demonstrating that economic alloca tion is possible and feasible, but leads to negligible results. Another alternative in LCA is to use mass

- based allocation of impacts from products and co

- products of a process. In the case of CCPs from coal

- fired power generation, the product is electri city, which has no mass, which means it is impossible to purely allocate by mass. However, as an illustration, we consider the allocation results assuming that the electricity generated is completely tied to the combustion of coal, which has known mass. This is a simplifying but fair assumption since there are few other significantly large mass based inputs into coal combustion processes (process water is generally reused and returned).

If the mass

- based allocation were considered as such, and thinking ag ain at the macro

- level of all coal

fired power plants, there are about one billion tons of coal used as input. As summarized in Table E

- 1,
there are about 10 9 million tons of the top three market value CCPs, and about 136 million tons total CCPs, generate d per year by the power plants. Thus, CCPs represent about 1 4 percent of the mass, with
individual mass allocations of about 7 percent for fly ash, two percent for gypsum, and two percent for

bottom ash . Thus, in this hypothetical example, the mass

- based allocations would, in fact be much larger than the economic value allocations, but still generally a small percentage of total "mass" production. Further, considering the other major mass flows in the plant, these numbers may, in fact, be smaller.

Anoth er caveat is that not all CCPs produced are beneficially used. Thus, the mass allocations may converge back to the shares estimated above for economic allocation.



## SAMPLE CALCULATIONS Given the substitution of CCPs for virgin materials production, and the potential effects of allocating some of the environmental flows of electric power generation to CCPs, we investigated what the comparative net effects would be if the estimated low range of mass or dollar based allocations for CCPs (of coal

- fired generatio n) were compared to the avoided emissions from coal fly ash and FGD gypsum beneficial use. For simplicity we consider CO 2 

### and SO 2 

### emissions only.

In 2008, coal

- fired generation in the electric power sector resulted in 1.9 b illion metric tons of CO 2 

### emissi ons. 83 

### From our overview of potential allocation values for CCPs from coal

- fired generation, we estimated that the percent allocations would be, in sum, on the order of about one percent. If we allocated one percent of CO 2 

### emissions from coal

- fired electr icity generation to the CCPs, then about 21 million
short tons of CO 2 

### would be allocated to their "production." In comparing this one percent allocated value
to the CO 2 

### benefits estimated separately by BEES and Simapro, we see that the avoided portland ce ment and virgin gypsum use accounts for about 11.5 million short tons of CO 2 

### emission benefits. Similarly, for
SO 2 

### , coal

- fired generation leads to most electricity generation emissions, which total about 10 million metric tons per year. 84 

### One percent of t his number is about 100,000 metric tons SO 2 

### , though this includes
emissions from all Conventional Power Plants and Combined

- Heat

- and

- Power Plants and therefore

83 EIA, 2010, “Table 12.2 Carbon Dioxide Emissions From Energy Con sumption: Total (All Sectors) and Electric Power Sector, 1949

- 2009,” accessed
Nov. 20, 2010 at http://www.eia.doe.gov/aer/txt/ptb1202.html

.

84 EIA, 2010, “Table 12.7b Emissions From Energy Consumption for Electricity Generation and Useful Thermal Output: El ectric Power Sector, 1989

- 2008. Accessed Nov. 20, 2010 at http://www.eia.doe.gov/aer/txt/ptb1207b.html

.E

- 3



### overstates the impact of coal combustion. However, Exhibit 5

- 3 in Chapter 5 of this report esti mates avoided cement and gypsum manufacturing SO 2 

### emissions to be 26,000 short tons (23.9 million metric tons or 23.9 billion grams), suggesting that SO 2 

### emissions reductions associated with beneficial reuse are small when compared with the allocated emiss ions impacts associated with energy production from coal. As indicated in our high

- end CO 2 

### and SO 2 

### examples presented above, allocated emissions from primary production (i.e., coal combustion) may occasionally be greater than the documented benefits of ben eficial use for some metrics. However, it is important to note that this allocation procedure reflects an accounting procedure designed only to more accurately apportion emission impacts across co

- products. It can be correctly interpreted as an indication that the beneficial use of CCPs may not be an efficient method for reducing overall emissions of CO 2 

### and SO 2 

### to the environment. However, t he actual CO 2 

### and

SO 2 

### emissions avoided from the beneficial use of coal fly ash and FGD gypsum remain positive, as reported.

While this analysis has focused only on CO 2 

### and SO 2 

### (there are similar emissions from coal

- fired generation of NOx, PM 10 

### , etc.), it demonstrates the type of framework that could be in place to help assess the efficiency of beneficial use. It i s likely that within such a framework that life cycle inventory data would be greater for one effect and lower for others, rather than a vector dominance situation. Thus, appropriate weighting methods should be identified to help balance the overall perce ived benefit of such substitutions. EPA's TRACI model and the BEES model itself could serve to normalize and weight preferences of environmental flows against each other to lead to singular assessments of results.



## SUMMARY

LCA allows for the allocation of input and output flows across the life cycle to the various products and

co

- products of processes and systems. However CCPs are generally considered waste, and not co

products of power generation. Even if they were considered co

- products, the allocated i nput and output
flows from coal

- fired generation would associate only very small flows to the CCPs relative to the electricity produced. For this reason, and because our assessment here represents a high

- end screening analysis, we do not include either an economic or mass

- based allocation of coal combustion impacts to fly ash or FGD gypsum in our presentation of extrapolated findings in chapter 5.