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 

=================================================================== 

1. Definition of Disaster Debris 

Each year, natural disasters, such as wildfires, floods, 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 building materials, sediments, vegetative debris, 

personal property, and other materials (EPA 2008, p. 11). Generally, this material 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 sector affected by a natural 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-related 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 any 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. Information 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 values 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/ton 
Construction and Demolition Materials – Disaster Debris 

 

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(4,500 to 4,980 btu/lb) (EPA 2003, EIA 2008c). The heating value for dry (0 

percent moisture) woody materials1

 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 burned, and it can be converted to 

liquid or gaseous fuel. Mixed wood debris with some green wood has a thermal 

value typically near 7,300 Btu/lb, and debris with higher percentages of green 

wood would have lower Btu values. In addition, 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 products, public comments submitted to EPA 

in response to the Advanced Notice of Proposed Rulemaking (ANPRM) indicate 

that creosote-treated wood has a heating value of 6,000 Btu/lb (Komorowski 

2009). 

• The combustor survey database developed 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 secondary 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 wood bridges. Treated wood contains 

chemical preservatives that can contaminate recycled wood products. These 

woods can be combusted in certain energy recovery facilities, 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, treated wood should be handled separately from vegetative 

debris being recycled (EPA 2008, pp 24, 30). 

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

have fuel value and be able to be combusted in some energy recovery facilities, 

but the heterogeneity of these materials in the debris stream may present a 

technical limitation to this application (EPA 2008). 

• A notable trend in the use of disaster debris as a fuel is the increased export of 

U.S. disaster debris to Europe. Due to European greenhouse gas regulations, 

woody biomass sent from North America to Europe is commanding a price of 

$100 to $125 per ton. However, despite the 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 

 

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foreign markets, the exportation of disaster debris is often limited by several 

practical considerations. For example, communities affected by disasters are 

usually focused on clearing disaster debris as quickly and conveniently as 

possible, and often lack the local infrastructure 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 debris 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 the 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 use applications of vegetative disaster debris include 

composting, land spreading (i.e., spreading debris across empty land to facilitate 

biodegradation), and agricultural applications (Alexander 2008, p. 13). 

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

• Metal in disaster debris can be recycled into other metal products (EPA 2008, 

p.23). In addition, other types of debris, such as household white goods, 

electronics, concrete, and asphalt 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 affected, the majority of disaster 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 processes 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 addition, municipal energy recovery facilities 

can in some cases manage mixed debris as well as vegetative debris (EPA 2008). 
Construction and Demolition Materials – Disaster Debris 

 

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(2) Sourcing of Disaster Debris:

• Communities affected by natural disasters, or state or Federal governments, 

typically hire private contractors to remove and dispose of disaster debris. 

(3) Processing of Disaster Debris: 

• To process vegetative disaster debris, contractors typically use grinders to reduce 

debris into chips. With respect to the beneficial 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 combustor 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 around 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 location of generation, the need for quick 

removal, and the tendency of disaster debris 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 responses to a 2006 survey by the Association of State and 

Territorial Solid Waste Management Officials (ASTSWMO), the state of Florida 

has approved the use of vegetative hurricane 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 least one occasion, but it is 

unclear whether these approvals apply to vegetative debris or the beneficial use of 

finished wood product. In all 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 these 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 composition 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 values 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 the 
Construction and Demolition Materials – Disaster Debris 

 

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traditional fuels by at least 50 ppm. In addition, the available data suggest that the 

sulfur content of drywall is orders of magnitude greater 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 represents just one of the costs of a natural 

disaster, but the beneficial use of this debris can, 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 valuable 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-related beneficial use applications can be 

measured based on the value of the fuel that 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., wood) can represent approximately 76 

percent of disaster debris. Thus, as an illustrative example, Exhibit 2 compares 

the emission factors for wood with the corresponding values for conventional 

fuels that disaster debris may displace. The estimates in the exhibit suggest that 

the combustion of wood results in higher 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 SO2 emissions than most 

conventional fuels. The estimated NOx emissions associated with wood 

combustion are similar to those associated with distillate and lower than the NOx

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. 
6 

Constituent 

Categories of Wood

Gypsum Drywall5 

Plywood/ 

Pressure 

Board1 

Creosote 

Treated 

Wood1 

Virgin 

Wood2 

C&D Wood (prior 

to 

decontamination)3 

Bark 

(dry 

basis)4 

Unadulterated 

Timber (dry 

basis)4 

---values in parts per million (ppm)--- 

Aluminum (Al) 294.60 Antimony (Sb) 0.03 0.67 Arsenic (As) 0.14 1.97 0.00 18.31 36.95 6.58 32.79 0.98 < 27.90 Barium (Ba) 28.15 24.95 185.97 Boron (B) 0.27 0.40 42.45 Cadmium (Cd) 0.14 1.40 0.13 0.92 0.65 0.80 5.12 < 0.48 3.08 Calcium (Ca) 219,000 160,360 Chlorine (Cl) 86.5 132 193.50 Chromium (Cr) 3.33 4.21 0.13 28.59 55 40.40 495 1.09 11.61 Cobalt (Co) 17.17 0.91 < 0.48 9.17 Copper (Cu) 7.27 7.65 0.01 33.53 3220 0.95 7.06-11.62 Iron (Fe) 44.00 857.9- 941.8 Lead (Pb) 12.1 64.13 0.33 130.90 259 3.08 113.72 0.70 15.60 Lithium (Li) < 2.49 Magnesium (Mg) 2,200 8,475 Manganese (Mn) 5024.18 2,497 9.10 44.50- 45.64 Mercury (Hg) 0.13 0.09 0.20 0.12 0.13 1.88 1.52 < 0.26 Molybdenum (Mo) < 0.24 2.65 Nickel (Ni) 0.18 24.98 284 0.83 20.10 Nitrogen (N) 9000 4000 3355.56 280 Phosphorus (P) 266.12 135 7.50 < 21.70 Potassium (K) < 62.10 Selenium (Se) 0 5 0.00008 0 BDL 348.07 88 Silver (Ag) 0.06 0.51 0.07 Sodium (Na) Sulfur (S) 2000 2000 154.94 181,000 133,821 Titanium (Ti) 0.97 52.89 230.50 Zinc (Zn) 22.83 101.69 145.74 3.08 11.49- 16.63 
Construction and Demolition M

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Notes: Blank cells indicate no data available 1. 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 virgin wood are from Jambeck, et al (2007). These values reflect contaminant levels in unprocessed C&D wood, which should not be confused with “clean” C&D wood that is listed as a traditional fuel in the “Preliminary Characterization Study: Traditional Fuels and Key Derivatives” (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 Limit 
Construction and Demolition M

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Exhibit 2: Comparative Impacts of Wood Combustion versus Alternative Primary Fuels

Pollutant 

Wood Coal Distillate Fuel Oil Residual Fuel Oil 

Combustiona Combustion 

Combustion 

plus 

Upstream Combustion 

Combustion 

plus 

Upstream Combustion 

Combustio

plus 

Upstream 

------------------------------------------- lb./MMBtu --------------------------------------- 

Criteria Pollutants PM2.5 - - - - - - PM10 0.019 0.054 0.054 0.011 0.011 0.093 0.0PM, unspecified - - 0.246 - 0.012 - 0.0NOx 0.167 0.482 0.504 0.173 0.234 0.367 0.4VOCs - 0.034b 0.006 0.014 0.001 0.363 0.002 0.3SOx 0.008 0.025c 1.446 1.469 0.209 0.394 1.593 1.7CO 1.511 0.6d 0.068 0.085 0.036 0.082 0.033 0.0Pb 1.33x10-4 4.8x10-5 e 8.93x10-6 9.19x10-6 4.60x10-6 5.61x10-6 5.80x10-5 5.90x1Hg - 1.0x10-6 2.05x10-6 2.14x10-6 1.58x10-6 1.77x10-6 8.67x10-6 8.85x1Greenhouse Gases CO2 233.3 210.7 214.7 161.2 180.1 173.3 19CH4 - 0.007 0.458 3.74x10-4 0.03 0.007 0.0N2O - 0.003 0.003 - 2.01x10-5 - 2.07x1MTCO2E/MMBtu 0.106 0.096 0.102 0.073 0.082 0.079 0.0Source: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 Fuel Cell/Dutch Oven and Fluidized Bed Combustor are 0.016 and 0.001 respectively. c.Emission factor for sulfur dioxide not specific to an individual type of combustion unit.. 

d.Emission factor applies to for stokers & Dutch ovens/fuel cells. Value for 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 from Life Cycle Inventory (LCI) data, as compiled by Franklin Associates. LCI data ident

energy requirements, and releases to the air, water, and land for each step in the manufacture of a product or process, from the extraction of the raw mcan be used to identify those system components or life cycle steps that are the main contributors to environmental burdens such as energy use, solid wwaterborne 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 readily available LCI database tmaterials and uses examined. These LCI data rely on system boundaries as defined by Franklin Associates, as described in the documentation for this http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf. 
Construction and Demolition Materials – Disaster Debris 

 

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Exhibit 2 also includes greenhouse gas emission factors associated with the 

combustion of wood. It is unclear, however, whether the combustion of wood 

disaster debris would lead to increased greenhouse gas emissions. Vegetative 

disaster debris, by definition, has already been removed from the ground and 

therefore has initiated decay. Combustion of this material merely accelerates the 

release of the stored carbon into the atmosphere. 

The emissions profile of treated woods or wood with lead paint may differ from 

the values presented in Exhibit 2. For example, concerning the combustion of 

railroad ties, creosote in the ties increases 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-methylnaphthalene is one, 

were greater for untreated wood than treated wood. Emissions of NOx and SO2

were essentially equivalent. Emissions of CO were lower for creosote treated 

wood (Hunt 2009). We note, however, the creosote itself contains 200 to 300 

chemicals (Reid 2002). In addition, wood treated with chromium copper arsenate 

(CCA-treated wood) contains arsenic, copper, 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, Exhibit 2 lists the quantities of the total 

cradle-to-gate emissions for these fuels based on typical processes 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 are 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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