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agency is not required to purchase the product.
(3) Competition with coal fly ash. Several state agencies commented that coal fly ash
is generated and used in their state. They stated that a designation of GGBF slag could result
in reduced markets for coal fly ash because GGBF slag would compete with coal fly ash.
EPA's designation of GGBF slag does not require procuring agencies to favor this
item over coal fly ash. Because it is an expansion of the existing cement and concrete
designation, the GGBF slag designation simply requires that procuring agencies consider
cement and concrete containing either recovered material (i.e., coal fly ash or GGBF slag).
Which type of cement or concrete a procuring agency purchases will depend on a number of
factors, including the performance requirements for the construction project, product
availability, competition, and product price.
(4) Administrative burden FHWA and several states argued that cement and concrete
containing GGBF slag should not be designated because the designation could create a
tremendous administrative burden and might not create additional markets for nor
significantly increase the usage of GGBF slag.
EPA disagrees that the designation might not create additional markets. EPA believes
that there will be additional opportunities to use GGBF slag as more of it is made available
and procuring agencies not currently using the item consider its use. We are also aware that
procuring agencies incur costs as a result of item designation, and as explained elsewhere in
this document, we have expended a great deal of effort to estimate these costs. Our
estimates, based in part on FHWA's own estimates, are discussed in Section XIX of this
document. While these costs are not inconsequential, they are necessary to ensure that
appropriate procuring agency personnel understand the requirements of Section 6002 of
RCRA and, among other things, revise specifications to favor the purchase of designated
items containing recovered materials when they meet the agencies' price and performance
objectives. FHWA, as a specification-writing agency, bears a larger share of these costs for.
cement and concrete products containing GGBF than do other agencies. As explained above,
there is sufficient interest in the beneficial use of GGBF slag in cement and concrete that
FHWA is developing guidance on its use. As this information becomes available, EPA
believes that many more procuring agencies will begin using or increasing their current usage
of GGBF slag in cement and concrete products to take advantage of its beneficial properties.
Thus, we believe the designation and the attendant costs are justified.
3. Rationale for Designation
EPA believes that cement and concrete containing GGBF slag satisfy the statutory
criteria for selecting items for designation.
a. Use of materials in solid waste. As discussed above in section II.A, approximately
90 percent of iron blast furnace slag is air-cooled, with granulated and expanded slag making

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