1 Materials Characterization Paper In Support of the Final Rulemaking: Identification of Nonhazardous Secondary Materials That Are Solid Waste

Construction and Demolition Materials – Disaster Debris

February 3, 2011

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1. Definition of Di saster Debris

Each year, natural disasters, su ch as wildfires, fl oods, earthquakes, hurricanes, tornadoes, and winter storms, generate large amounts of debris . This poses a challenge for public officials who must manage this debris in a manner that is as efficient and cost-effective as possible. The debris resulting from natural disasters often includes bu ilding materials, sediments, vegetative debris, personal property, and other materials (EPA 2008, p. 11). Generally, this ma terial has not been discarded. Rather, it is the product of a natural disaster.

2. Annual Quantities of Disaster Debris Generated and Used

(1) Sectors that generate Disaster Debris:

• Disaster debris may be generated by any s ector affected by a na tural disaster (e.g., households, businesses, government, etc.).

(2) Quantities and prices of Disaster Debris generated:

• While each natural disaster is unique, the top two natural disasters that created the greatest recorded amounts of disaster-rel ated debris in the United States were Hurricane Andrew in 1992 (43 million cubic yards (CY) of debris) and Hurricane Katrina in 2005 (over 100 million CY of debris) (Luther 2006, p. 2).

• The annual generation of disaster debris depends on the frequency and severity of the natural disasters that occur during a ny given year and the location where these

disasters occur.

• The market price of disaster debris varies by constituent. Based on the U.S. price of woody biomass, however, vegetation debris could generate revenues of approximately $5 to $15 per ton (Yepsen 2008, p. 51).

(3) Trends in generation of Disaster Debris:

• The generation of disaster debris is episodic. Info rmation on disaster debris trends is not readily available.

3. Uses of Disaster Debris

(1) Fuel uses of Disaster Debris:

• A large percentage of disaster debris is vegetative debris , which is commonly used as boiler fuel. The reported heating valu es for this material vary considerably and depend on the moisture content of the material. Wood with a moisture content of 50 percent generally has a heating value between 9 and 10 million btu/tonConstruction and Demolition Materials – Disaster Debris

2 (4,500 to 4,980 btu/lb) (EPA 2003, EIA 2008c). The heating value for dry (0 percent moisture) woody materials 1 is typically between 15.5 and 16.4 million Btu/ton (7,750 to 8,200 btu/lb) (Wright et al. 2006). If oven-dried, however, wood may produce about 9,000 Btu/lb when bu rned, and it can be converted to liquid or gaseous fuel. Mixed wood debr is with some green wood has a thermal value typically near 7,300 Btu/lb, and debr is with higher percentages of green

wood would have lower Btu values. In a ddition, it is possible to produce different forms of solid fuel, such as charcoal , from wood debris (SWANA 2002a, pp 4, 18). With respect to treated wood pr oducts, public comments submitted to EPA in response to the Advanced Notice of Proposed Rulemaking (ANPRM) indicate

that creosote-treated wood has a hea ting value of 6,000 Btu/lb (Komorowski 2009).

• The combustor survey database devel oped by EPA for the 2009 proposal of the

Commercial and Industrial Solid Waste Incinerator (CISWI) standards and the

Industrial Boilers Maximum Achievable Control Technology (MACT) standards indicates that the sources surveyed for these rules annually combust approximately 9.5 million tons of sec ondary wood material that may be construction and demolition disaster debris (EPA 2009). 2,3

• Wood debris associated with disasters is heterogeneous, and can include treated wood, such as wooden utility poles, railroad ties, and some lumber from decks, fences, landscaping materials, and w ood bridges. Treated wood contains chemical preservatives that can cont aminate recycled wood products. These

woods can be combusted in certain ener gy recovery faciliti es, provided the facilities comply with existing federal, state and local requirements, but they should not be “open burned” in piles or combusted in air curtain incinerators (ACIs). In general, trea ted wood should be handled separately from vegetative debris being recycled (EPA 2008, pp 24, 30).

• Similarly, other materials in disaster debr is such as plastics and paper may also

have fuel value and be able to be com busted in some energy recovery facilities, but the heterogeneity of these material s in the debris stream may present a technical limitation to this application (EPA 2008).

• A notable trend in the use of disaster debr is as a fuel is th e increased export of U.S. disaster debris to Europe. Due to European greenhouse gas regulations, woody biomass sent from North America to Europe is comm anding a price of $100 to $125 per ton. However, despite th e financial incentive provided by

1 Also called the gross or higher heating value.

2 Although we report wood quantities from the combustion database as tonnages, the database includes material quantities expressed in terms of heating values (Btu). To express this information as a tonnage, we assumed that wood has a heating value of 7,975 Btu per pound, which is the midpoint of the 7,750 to 8,200 Btu/lb range for wood reported by Wright (Wright 2006).

3 The categories of wood material in the combustion database that may contain C&D disaster debris include (1) adulterated wood; (2) painted or varnished wood; (3) plywood, particleboard (containing glues or resins); (4) treated wood; (5) treated wood and cardboard; (6) unadulterated wood; (7) unadulterated lumber; and (8) unadulterated timber. Also note that some of these categories could be building debris, land clearing debris, or biomass (as defined in the three materials characterization papers) rather than construction and demolition disaster

debris.Construction and Demolition Materials – Disaster Debris

3 foreign markets, the exportation of disast er debris is often limited by several practical considerations. For example, communities affected by disasters are usually focused on clearing disaster de bris as quickly and conveniently as possible, and often lack the local infrastruc ture to store, process, and ship high quantities of debris produced in such situations (Yepsen 2008, p. 51). In addition, it is sometimes necessary to quarantine de bris from a region to address potential issues with pests. For example, parts of Louisiana have Formosan termites and this debris was therefore difficult to ship to potential users after Hurricane Katrina (EPA, 2008, p. A-2).

• Asphalt shingles can be used as fuel in cement kilns, and the mineral components remaining after combustion can serve as raw material for the cement (EPA 2008, p. 23). However, while the use of asphalt shingles as fuel is a well-established market in Europe, this use is limited in th e United States because of air pollution concerns and concerns about the previous use of asbestos in older shingles (Shingle Recycling.org 2007).

(2) Non-combustion uses of Disaster Debris:

• Non-combustion beneficial us e applications of vegetativ e disaster debris include composting, land spreading (i.e., spreading debris across empty land to facilitate biodegradation), and agricultural ap plications (Alexander 2008, p. 13).

• Asphalt roofing shingles can be reused in hot-mix asphalt (NAPA 1997, p. 1).

• Metal in disaster debris can be recycl ed into other metal products (EPA 2008, p.23). In addition, other types of debris, such as household white goods, electronics, concrete, and as phalt pavement, can in some cases be recovered for recycling. (EPA 2008, p. 22).

(3) Quantities of Disaster Debris landfilled:

• While the precise quantity of disaster debris disposed in landfills depends on the natural disaster and the community affecte d, the majority of di saster debris is landfilled or open burned (Yepsen 2008, p. 51). This occurs partly out of necessity and convenience, as the focus of most communities is to clear material as quickly as possible after a disaster.

(4) Quantities of Disaster Debris stockpiled/stored:

• In many cases, the lack of storage capacity prevents disaster debris from being stockpiled (Yepsen 2008, p. 51).

4. Management and Combustion pr ocesses for Disaster Debris

(1) Types of units using Disaster Debris:

• Vegetative disaster debris can be ground into chips and used by wood-fired

industrial boilers and burners. In addi tion, municipal energy re covery facilities can in some cases manage mixed debris as well as vegetative debris (EPA 2008).Construction and Demolition Materials – Disaster Debris

4 (2) Sourcing of Disaster Debris:

• Communities affected by natural disaster s, or state or Federal governments, typically hire private cont ractors to remove and dis pose of disaster debris.

(3) Processing of Disaster Debris:

• To process vegetative disaster debris, cont ractors typically use grinders to reduce debris into chips. With respect to the be neficial use of vegetative debris as a fuel source, the challenge with grinding is that it is better suited to volume reduction than the production of the uniform chips needed by biomass fuel plants. However, if communities hire a processor accustomed to producing biomass fuel, the debris can be ground into chips that meet co mbustor specifications (Yepsen 2008, p. 51).

• The economics of utilizing biomass are challenging: the expense of shipping woody biomass, which has a high volume to weight ratio, has traditionally limited

use to a 50 or 100-mile radius aroun d disaster sites (Yepsen 2008, p. 51).

• Processing disaster debris is complicated by several factors: the effects of the disaster on transportation infrastructure , the large quantities of debris produced, the unpredictability of the quantity and loca tion of generation, the need for quick removal, and the tendency of disaster de bris to be composed of a mixture of materials (potentially including contaminants) (Yepsen 2008, p. 51). In addition, debris from certain regions may require quarantine due to pests (EPA 2008, p. 6).

(4) State status of Disaster Debris use as fuel:

• According to state respons es to a 2006 survey by the Association of State and Territorial Solid Waste Management Offi cials (ASTSWMO), the state of Florida has approved the use of vegetative hurrica ne debris as fuel on at least one

occasion. Both New York and North Carolina have approved the use of

recovered wood materials as a fuel source on at leas t one occasion, but it is unclear whether these approvals apply to vege tative debris or the beneficial use of finished wood product. In a ll three states, these uses do not appear to have preapproved status, suggesting that a case -by-case approval process for designation of beneficial use is in place in th ese states (ASTSWMO 2007, p.B-41-42).

5. Disaster Debris Composition and Impacts

(1) Composition of Disaster Debris:

• Hurricane-related disaster debris is generally 76 percent vegetative, 17 percent mixed, 7 percent construction and demolition, and 1 percent white goods (Alexander 2008, p. 8). Other types of disaster debris will have varying composition, and may include components such as ash (e.g., from wildfires) or sediment (e.g., from floods).

• Exhibit 1 presents the chemical compositi on of various types of wood that may be

included in C&D disaster debris as well as the composition of gypsum drywall. Based on the available data, constituent va lues for C&D disaster debris generally fall within the range of traditional fuels, with a few exceptions. The lead content in C&D wood ranges from 131 to 259 ppm, which is higher than any of theConstruction and Demolition Materials – Disaster Debris

5 traditional fuels by at least 50 ppm. In addition, the available data suggest that the sulfur content of drywall is orders of magnitude greate r than that of traditional

fuels.

(2) Impacts of Disaster Debris use:

• Cost Impacts: Natural disasters impose significant costs on affected communities. The disposal of disaster debris represen ts just one of the costs of a natural disaster, but the beneficial us e of this debris ca n, in some cases, lessen these costs. Overall, however, the net cost impacts associated with the beneficial use of disaster debris depend on the circumstances of the disaster and are uncertain. For example, while disaster debris may be va luable as a fuel source, transportation costs and time-sensitivity can make landfill disposal the most cost-effective management option (EPA 2008, p. 22).

While the net cost impacts associated with the beneficial use of disaster debris are uncertain, the fuel cost savings of fuel-rel ated beneficial use applications can be

measured based on the value of the fuel th at the debris would replace. The recent prices of conventional fossil fuels that may be replaced by this material are as

follows:

o Natural Gas (Industrial): $7.35 / MMBtu (EIA 2008a, Table 20)

o No. 2 Distillate (Industrial): $16.80 / MMBtu (EIA 2008b, Table 36)

o Residual Fuel Oil Average: $9.19 / MMBtu (EIA 2008b, Table 38)

o Coal – Average Delivered Price in 2006: $2.23 / MMBtu (EIA 2007, Table ES1)

• Emissions Impacts of Combustion: Emissions associated with the use of disaster debris are likely to depend on the specific material used as a fuel. As indicated above, however, vegetative debris (e.g., w ood) can represent approximately 76 percent of disaster debris. Thus, as an illustrative example, Exhibit 2 compares

the emission factors for wood with th e corresponding values for conventional fuels that disaster debris may displace. The estimates in the exhibit suggest that the combustion of wood results in highe r PM emissions than natural gas or distillate oil, but lower PM emissions than coal or residual oil systems. The data in Exhibit 2 also suggest that wood results in lower SO 2 emissions than most

conventional fuels. The estimated NO

x emissions associated with wood

combustion are similar to those associated with distillate and lower than the NO

x emissions for other conventional fuels. 4

4 We note that the emission factors for wood presented in Exhibit 1 represent averages for wood-burning

boilers.6ConstituentCategories of WoodGypsum Drywall5Plywood/PressureBoard1CreosoteTreatedWood1VirginWood2C&D Wood (priortodecontamination)3Bark(drybasis)4UnadulteratedTimber (drybasis)4---values in parts per million (ppm)---Aluminum (Al)294.60Antimony (Sb)0.03 0.67Arsenic (As)0.14 1.97 0.00 18.31 36.956.58 32.79 0.98 < 27.90Barium (Ba)28.15 24.95 185.97Boron (B)0.27 0.40 42.45Cadmium (Cd)0.14 1.40 0.13 0.92 0.650.80 5.12 < 0.48 3.08Calcium (Ca)219,000 160,360Chlorine (Cl)86.5 132 193.50Chromium (Cr)3.33 4.21 0.13 28.59 55 40.40 495 1.09 11.61Cobalt (Co)17.17 0.91 < 0.48 9.17Copper (Cu)7.27 7.65 0.01 33.53 3220 0.95 7.06-11.62Iron (Fe)44.00857.9-941.8Lead (Pb)12.1 64.13 0.33 130.90 2593.08 113.72 0.70 15.60Lithium (Li)< 2.49Magnesium (Mg)2,200 8,475Manganese (Mn)5024.182,497 9.1044.50-45.64Mercury (Hg)0.13 0.09 0.20 0.12 0.13 1.88 1.52 < 0.26Molybdenum (Mo)< 0.24 2.65Nickel (Ni)0.18 24.98 284 0.83 20.10Nitrogen (N)9000 40003355.56280Phosphorus (P)266.12 135 7.50 < 21.70Potassium (K)< 62.10Selenium (Se)0 5 0.00008 0 BDL 348.07 88Silver (Ag)0.06 0.51 0.07Sodium (Na)Sulfur (S)2000 2000 154.94 181,000 133,821Titanium (Ti)0.97 52.89 230.50Zinc (Zn)22.83 101.69 145.74 3.0811.49-16.63Construction and Demolition Materials – Disaster Debris7Notes: Blank cells indicate no data available1. Holzman and Atkins (2009).2. Jambeck, et al (2007).3. Values in the left-hand column are from Holzman and Atkins (2009). Values in the right-hand column and for virginwood are from Jambeck, et al (2007). These values reflect contaminant levels in unprocessed C&D wood, which shouldnot be confused with “clean” C&D wood that is listed as a traditional fuel in the “Preliminary Characterization Study:Traditional Fuels and KeyDerivatives” (EPA 2010).4. EPA/OAQPS (2010a and 2010b).5.Values in the left-hand column are from Dontsova, et al(2005). Values in the right-hand column are from Marvin(2000).BDL=Below Detection LimitConstruction and Demolition Materials – Disaster Debris8Exhibit 2: Comparative Impacts of WoodCombustion versus Alternative Primary FuelsPollutantWoodCoalDistillate Fuel Oil Residual Fuel Oil Natural GasCombustionaCombustionCombustionplusUpstream CombustionCombustionplusUpstream CombustionCombustionplusUpstream CombustionCombustionplusUpstream------------------------------------------- lb./MMBtu ---------------------------------------Criteria PollutantsPM2.5 -- - - - - - - -PM10 0.0190.054 0.054 0.011 0.0110.093 0.093 0.009 0.009PM, unspecified -- 0.246 - 0.012 - 0.012 - 0.004NOx 0.1670.482 0.504 0.173 0.2340.367 0.428 0.301 0.417VOCs - 0.034b0.006 0.014 0.001 0.3630.002 0.367 0.009 0.524SOx 0.008 0.025c1.446 1.469 0.209 0.3941.593 1.781 0.073 1.985CO 1.511 0.6d0.068 0.085 0.036 0.0820.033 0.079 0.058 0.282Pb 1.33x10-44.8x10-5 e8.93x10-69.19x10-64.60x10-65.61x10-65.80x10-55.90x10-5- 2.72x10-7Hg - 1.0x10-62.05x10-62.14x10-61.58x10-61.77x10-68.67x10-68.85x10-6- 7.18x10-8Greenhouse GasesCO2233.3210.7 214.7 161.2 180.1 173.3 192.5 114.6 129.8CH4-0.007 0.458 3.74x10-40.03 0.007 0.036 0.003 0.372N2O -0.003 0.003 - 2.01x10-5- 2.07x10-5- 1.17x10-5MTCO2E/MMBtu0.1060.0960.1020.0730.0820.0790.0880.0520.062Source:Franklin Associates 1998, unless otherwise noted.Note:“-” signifies data not available; may equal zero.a.Values in the right column from Hunt (2009).b.Emission factor applies to stoker units only. Values for FuelCell/Dutch Oven and FluidizedBed Combustor are 0.016 and 0.001respectively.c.Emission factor for sulfur dioxide not specificto an individual type of combustion unit..d.Emission factor applies to for stokers & Dutch ovens/fuel cells. Valuefor fluid bed combustors is 0.17.e.Emission factor from U.S. EPA AP-42,as cited in Hunt (2009).The emission information presented in this table is derived fromLife Cycle Inventory (LCI) data, as compiled by Franklin Associates. LCI data identifiesand quantifies resource inputs,energy requirements, and releases to the air, water, and landfor each step in the manufacture of a product or process, from the extraction of the raw materials to ultimate disposal. The LCIcan be used to identify those system components or life cycle steps thatare the main contributors to environmental burdens such as energy use, solid waste, and atmospheric andwaterborne emissions. Uncertainty in an LCI is due to the cumulative effects of input uncertainties and data variability.There are several life cycle inventory databases available in the U.S. and Europe. For this paper, we applied the most readilyavailable LCI database that was most consistent with thematerials and uses examined. These LCI data rely on system boundaries as defined by Franklin Associates, as described in the documentation for this database, available at:http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf.Construction and Demolition Materials – Disaster Debris

9 Exhibit 2 also includes greenhouse gas em ission factors associated with the combustion of wood. It is unclear, however, whether the combustion of wood

disaster debris would lead to increase d greenhouse gas emissions. Vegetative disaster debris, by definition, has alre ady been removed from the ground and therefore has initiated decay. Combustion of this material merely accelerates the

release of the stored carb on into the atmosphere.

The emissions profile of treated woods or wood with lead paint may differ from the values presented in Exhibit 2. Fo r example, concerning the combustion of railroad ties, creosote in the ties incr eases the combustion temperature, resulting in a more complete combustion of some organics such as benzene, formaldehyde,

and dioxins. Public comments received in response to the ANPRM indicate that, with the exception of 2-methylnaphthalene , emissions of organic compounds from

creosote treated wood were less than untreated wood. Total emissions of polycyclic aromatic hydrocarbons (PAHs), of which 2-methylna phthalene is one, were greater for untreated wood th an treated wood. Emissions of NO

x and SO 2 were essentially equivalent. Emissions of CO were lower for creosote treated wood (Hunt 2009). We note, however, the cr eosote itself contains 200 to 300 chemicals (Reid 2002). In addition, wood treated with chromium copper arsenate (CCA-treated wood) contains arsenic, c opper, and chromium that may be emitted when this wood is combusted (Iida et al. 2004). Similarly, lead may be emitted during the combustion of lead-painted wood. Information on the magnitudes of these emissions is not readily available.

• Lifecycle Emissions Impacts: Use of disaster debris as a replacement for traditional primary fuels may eliminate the environmental impacts associated with extraction and processing of traditional fuels. In addition to the emissions impacts of combustion described above, Exhi bit 2 lists the quant ities of the total cradle-to-gate emissions for these fuels based on typical pro cesses in the United States in the late 1990s, with wood scrap combustion presented as a proxy for disaster debris. Note that there may be impacts associated with the processing of

disaster debris into useable fuel that ar e not accounted for in the values presented in Exhibit 2. In addition, there may be alternative uses (e.g., composting) that are environmentally preferable to combustion.Construction and Demolition Materials – Disaster Debris

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