Analysis - The Institute for Southern Studies

Hypothetical expansion of CCR customer delivery area:
Baseline customer area @125 miles radial transport distance = (3.1415 x (125 miles)^2) =
Expanded customer area @225 miles radial transport distance = (3.1415 x (225 miles)^2) =
Incremental increase in customer area = (159,000 – 49,100 sq. miles) / (49,100 sq.miles) =
49,100 square miles
159,000 square miles
124% increase in delivery area
Step 5: Estimate Hypothetical “Stigma” Decrease in Future CCR Beneficial Use (Scenario #2)
A number of industry and state government stakeholders have asserted to the EPA, that designating CCR as a hazardous waste (even if the
designation is only applicable to those CCR that are disposed of) would create a “stigma” that would reduce or curtail or eliminate the
beneficial use of CCR. This RIA presents an alternative stigma effect scenario in an effort to evaluate what countervailing impact that
“stigma” may have on the increased beneficial use of CCR estimated in this RIA above. This potential reduction scenario assumes different
potential impacts in three categories of beneficial CCR usage (uses covered in the CPGs, consolidated uses, and unconsolidated uses). For
documentation of the calculations discussed in this section, see Appendix K13.
“Stigma” on CCR in Consolidated Uses Specified in Comprehensive Procurement Guidelines
First, some uses for CCR involve the production of specific products that are expressly covered by the federal Comprehensive Procurement
Guidelines (CPGs), which require procuring agencies that spend more than $10,000 a year on an item to buy products containing recovered
materials. Procuring agencies are federal, state, and local agencies, and their contractors, that use appropriated federal funds. For example, if a
county agency spends more than $10,000 a year on an EPA-designated item and part of that money is from appropriated federal funds, then the
agency must purchase that item made from recovered materials. 156 As such, if there were any impacts due to stigma, EPA believes that the
markets for these uses are less likely to be affected by a hazardous waste label for CCR. CCR categories currently covered under the CPGs
include concrete/concrete products/grout, flowable fill, and blasting grit/roofing granules.
According to U.S. Census data, the public portion of total construction spending equaled 20.7% in 2005, 21.4% in 2006, 24.6% in 2007, and
had swelled to 35.4% by Nov. 2009 (likely in direct relationship to the current state of the economy and current federal stimulus spending).
Similarly, U.S. EPA (2008d) estimates that for concrete projects, the cement demand attributable to federal concrete projects reflects
approximately 20% of the annual total demand. EPA then apportioned the amounts of CCR usage into a public construction vs. a private
construction split. Based on the Census Bureau and EPA data, 157 EPA established a 25% / 75% split of the totals for these products, such that
25% of the total usage is recognized as accruing to public construction and 75 % to private construction.
156 Agencies may elect not to purchase designated items when the cost is unreasonable; inadequate competition exists; items are not available within a reasonable period of
time; or items do not meet the agency's reasonable performance specifications.
157 Source: EPA “Report to Congress: Study on Increasing the Usage of Recovered Mineral Components in Federal Funded Projects Involving Procurement of Cement or
Concrete to Address the Safe, Accountable, Flexible, Efficient Transportation, Equity Act: A Legacy for Uses by the EPA, the Department of Transportation (DOT) and the
Department of Energy (DOE),” EPA530-R-08-007, June 3, 2008 at: http://www.epa.gov/waste/conserve/tools/cpg/products/cement2.htm
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