If concrete is made using coal ash, is the concrete a hazardous waste, when disposed at the end of its useful life?
Under the subtitle C proposal, coal ash destined for beneficial use would retain the current Bevill exemption, and so would not be subject to regulation under RCRA Subtitle C. Thus, coal ash used in concrete and other products would not fall within the scope of EPA’s proposal to “list” coal ash, either during or after the useful life of the concrete product. When the concrete product is discarded at the end of its useful life, it would be treated the same as any other solid waste.
