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

Construction and Demolition Material s – Building-Related C&D Materials

February 3, 2011

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

1. Definition of Building-Related Construction and Demolition Materials

Building-related construction debris and demo lition (C&D) materials are commonly grouped as a single type of material, despite the fact that these two material streams come from different

processes. 1 Construction materials originate from c onstruction, repair or remodeling activities. This materials stream typically consists of a variety of building products (such as concrete, roofing, gypsum wallboard, wood products, plastics, insulation, tile, and me tal) as well as the packaging materials that building materials a rrive in (such as cardboard and plastics). Construction materials are usually generated as a resu lt of cutting a material down to size for installation or purchasing materi als in excess of what is need ed. Wood materials consists of wood scraps from dimensional lumber, siding, laminates, flooring ( potentially stained), laminated beams, and moldings (potentially pa inted). Demolition materials are generated from the dismantling of buildings or the removal phase of remodeling. Typical constituents include concrete, wood, metal, insulation, gl ass, carpet, and other building materials. Debris from this process is often painted or chemi cally treated or is fastened to other materials, making separation difficult (NESCAUM 2006). For the purposes of th is summary, wooden ra ilroad crossties and wooden utility poles are also char acterized as demolition materials.

This summary of C&D debris focuses largely on the scrap wood generated from construction and demolition activities, as this is the main C&D constituent beneficially used as a fuel. EPA has also expressed interest in obtaining informa tion on the beneficial us e of C&D plastics and rubber, particularly fuel applications of these materials. The major plastic components of C&D materials (vinyl siding and PVC piping), however, can contain 57 percent chlorine (Commission of the European Communities, 2000). Informati on on the quantities of vinyl siding and PVC piping combusted in energy recovery facilities is not readily available. In addition, rubber does not appear to be a major component of C&D debris. This C&D summ ary does not include a

detailed examination of eith er C&D plastic or rubber.

1 Building-related C&D debris does not include debris generated from the construction and demolition of roads. The available data suggest that most road-related debris is not useable as a fuel; therefore, we exclude these

materials from this document.Construction and Demolition Materials – Building-related C&D Materials

2 2. Annual Quantities of C&D Materials Generated and Used

(1) Sectors that generate C&D Materials:

• Construction Materials ar e produced by NAICS 236: Construction of Buildings (U.S. Department of Labor 2008). Demo lition Materials are produced by NAICS 238910: Site Preparation Contractor s (U.S. Census Bureau 2007).

(2) Quantities and prices of C&D Materials generated:

• EPA estimates that 164 million tons 2 of building-related C&D debris were produced in 2003. Approximately 47 per cent of this was generated through construction and renovation activities, and 52 percent was generated through demolition activities (Franklin 2005).

• Of the 164 million tons of building-re lated C&D materials generated in 2003,

EPA estimates that between 33 and 49 million tons 2 was C&D wood (Franklin 2005).

• As corroboration for EPA’s 2003 estimate of C&D wood debris generation, a USDA source estimates that approx imately 39.35 million tons of C&D wood were generated in the U.S. in 2002. Of this, approximately 30 percent originated in construction activities and 70 percent in demolition activities (McKeever 2002).

• Approximately 50 percent of C&D wood de bris (20.28 million s hort tons) is of acceptable size, quality, and condition to be considered available for recovery. Factors limiting “availability” include c ontamination and the commingling of

wood with other nonwood buildi ng products (McKeever 2002).

• The quantity data presented above do not re flect the generation of scrap railroad ties or utility poles. A 1995 analysis in dicates that 13 m illion wooden crossties

are removed from railroad service each year (WasteAge 1995). A 2000 analysis reports that 1 to 2 million wooden utility poles are replaced each year (Choong et. al. 2000, pg 1).

• The available data on the market price of ground wood includes a range of values. Data for 2000 show a range of $11.16 to $12.50 per ton, while 2006 data suggest a range of $15 to $20 per ton (Krause 2000, Goldstein 2006). These prices vary by region, with prices in th e Northeast lower than in the West (Krause 2000).

(3) Trends in generation of C&D Materials:

• Information on the trend in C&D wood debris generation is not readily available; however, between 1998 and 2003 the generation of all building-related C&D rose by approximately 17 percent, from 136 m illion tons in 1998 to 164 million tons in 2003 (EPA 1998, Franklin 2005). Assuming th at this growth rate applies to building-related C&D wood debris, the genera tion of this debris grew from 28 to

42 million tons in 1998 to 33 to 49 million tons in 2003.

• Trends in the generation of C&D debris tend to mirror th e trend in economic activity (McKeever 2002). That is, a str ong economy generally results in more

2 Data currently under revision

.Construction and Demolition Materials – Building-related C&D Materials

3 construction and demolition activity. For example, the annual percentage change in U.S. Gross Domestic Product (GDP) in 2006 decreased from 2.8 to 2.0 in 2007. During the same time period, total U.S. new housing starts decreased from 1,800 to 1,355 (thousands) (U.S. Census Bureau 2008, U.S. Department of Commerce 2008).

• On a more local scale, the rate of C&D debris generation is heavily influenced by a number of area-specific factors in cluding the age of the building stock (SWANA 2002b). 3

3. Uses of C&D Materials

(1) Fuel uses of C&D Materials:

• C&D wood residues are commonly used for bo iler fuel. The biomass can either be combusted directly to heat a conventional type of boiler and produce steam for power production, or it can be conve rted into gaseous components (carbon monoxide, hydrogen, methane, and other in ert gases) through gasification. In contrast to incineration, which fully conve rts the input debris into energy and ash, gasification deliberately limits the conversio n so the biomass is converted into the intermediate products of gas and charcoal, which can be used for further energy recovery (NRI).

• The reported heating values for wood vary considerably. The heating value for dry (0 percent moisture) woody materials 4 is typically between 15.5 and 16.4 million btu/ton (7,750 to 8,200 btu/lb) (Wright et al. 2006). In addition, oven-dry wood produces approximately 9,000 Btu/lb when burned (SWANA 2002a).

Public comments submitted to EPA in response to the Advanced Notice of Proposed Rulemaking (ANPRM) indicate that creosote-tr eated wood has a heating value of 6,000 Btu /lb (Komorowski 2009).

• Comprehensive information on the quantity of C&D materials combusted for energy recovery is unavailable. Howe ver, 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) st andards indicates that the sources surveyed for these rules annually co mbust 4.7 million tons of material

characterized as construction and demolition debris. 5 Surveyed combustion units

3 Although disaster debris is not considered C&D material, the construction of new structures following a natural disaster increases the generation of construction debris.

4 Also called the gross or higher heating value.

5 Although we report C&D quantities from the combustion database as tonnages, the database includes material quantities expressed in terms of heating values (B tu). To express this information as a tonnage, we assumed that C&D 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). We note, however, that the C&D material included in the combustion database may include materials other than wood.Construction and Demolition Materials – Building-related C&D Materials

4 also reported burning approximately 6.5 m illion tons of secondary wood material per year that may be construction and demolition debris 6 (EPA 2009).

• Railroad ties are in demand for combustion due to their low moisture content. In addition, because most crossties are creoso te-treated, the chip s reportedly allow boilers to burn at a higher temperature than they would w ith untreated wood chips. Furthermore, treated wood chips from railroad ties reportedly leave less combustion residue behind than untreated chips (WasteAge 1995).

• Public comments on the ANPRM indicate that many facilities that use creosote to treat wood or produce th e wood products to be treated by creosote possess permits

to burn creosote-treated w ood as a fuel (Gauntt 2009).

• 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 shi ngles as fuel is an 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 C&D Materials:

• EPA estimates that 48 percent (65.6 million tons) of C&D materials were recovered for beneficial use (including recycling and use as a fuel) in 2003 (Franklin 2005). A corresponding estimate specific to wood C&D is not readily

available.

• Approximately 3,500 C&D recycling facilitie s are operating in the U.S. (Franklin 2005).

• Additional markets for C&D wood include flooring, feedstock for engineered woods, landscape mulch, soil conditioner, animal bedding, compost additive, and sewage sludge bulking medium. Reusing wood as lumber ca n potentially yield revenues 20 to 32 times higher than thos e from selling wood for fuel or mulch. Similarly, recycling wood to the manufactur ing of engineered wood products can potentially generate revenues four times greater than the revenues generated from selling the same amount of wood for fuel or mulch. However, processing and handling costs associated w ith the reuse of lumber and engineered wood product feedstock options are also much greater th an those associated with using debris wood for fuel or mulch. Therefore, some of the revenues associated with more “high-end” applications are offset by greater processing and handling costs (SWANA 2002a).

• More than half of scrap railroad ti es are reused in landscaping, fencing, construction, retaining walls and as fuel for utilities and other plants (WasteAge 1995).

6 The categories of wood material in the combustion database that may contain C&D building 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; and (7) unadulterated lumber. Also note that some of these categories could be disaster debris, land clearing debris, or biomass (as defined in the three biomass materials characterization papers) rather than construction and demolition building debris.Construction and Demolition Materials – Building-related C&D Materials

5 (3) Quantities of C&D Materials landfilled:

• Most C&D materials are non-hazardous a nd are frequently accepted at C&D and municipal solid waste (MSW) landfills, depending on the state and local laws governing disposal (EPA 2004). 7

• As indicated in Exhibit 1, EPA estimat es that 98.4 million tons, approximately 60%, of building-related C&D debris were disposed in 2003 (Franklin 2005). A corresponding estimate specific to w ood C&D is not readily available.

• A 1994 EPA survey identified approximately 1,900 active C&D landfills in the United States. (EPA 1998).

• In 1998, EPA estimated that 45-60 million t ons of C&D debris were disposed of in permitted C&D landfills. This amount is equal to about 35-45 percent of the estimated 136 million tons of building re lated C&D debris produced that year (EPA 1998).

• Less than half of scrap railroad ties are landfilled (WasteAge 1995).

(4) Quantities of C&D Materials stockpiled/stored:

• Construction and demolition debris is not believed to be stockpiled in significant quantities. The data sources consulted for the de velopment of this document provided no indication that large quantities of C&D ma terials are stockpiled.

Exhibit 1: C&D Material Quan tities Generated and Managed in 2003

Material Quantity

Generated ( million short tons) Quantity Recycled or

used as Fuel

(million short tons) Percent Recycled or

used as Fuel Quantity Disposed

(million short tons) Percent Disposed

Building

Related C&D

Materials 164 million 65.6 40% 98.4 60%

Sources : Franklin 2005

4. Management and Combustion processes using C&D Materials

(1) Types of units using C&D Materials:

• C&D wood is used by wood-fired industrial boilers and burners.

(2) Sourcing of C&D Materials:

• Wood from C&D activities becomes ava ilable as combustion fuel through a variety of methods, but it is typically se nt to a processing fa cility by municipal haulers, private haulers, construction co mpanies, or individual households. After the wood is processed according to combus tor specifications, it is delivered to combustion facilities (NESCAUM 2006).

7 The primary exception to this is wood treat ed with chromated copper arsenate (CCA).Construction and Demolition Materials – Building-related C&D Materials

6 (3) Processing of C&D Materials:

• Prior to use as fuel, scrap wood typica lly requires removal of non-wood materials and processing into chips. Fuel specifi cations for combusto rs usually include minimum and maximum chip sizes, amount of C&D fines, maximum moisture content, and maximum contaminan t levels (NESCAUM 2006).

• A “hog” (also called a shredder or tub grinde r) is used to pro cess construction and demolition wood materials. The hog uses ro tating hammers and stationary anvils to smash, crush and tear large wood into smaller fragments. The maximum output particle dimension of hogged fuel is ty pically less than 3 inches. Hogged fuel often has a high moisture content and a significant ash content (from 2 to 20 percent) (Natural Res ources Canada 2000).

• Public comments submitted by the Treat ed Wood Council in response to the ANPRM indicate that treated wood products may or may not require processing, such as sorting, cleaning, cutti ng, de-nailing, etc. (Miller 2009).

(4) State status of C&D Materials use as fuel:

• According to state respons es to a 2006 survey by the Association of State and Territorial Solid Waste Management O fficials (ASTSWMO), two states—Maine and Michigan—have approved the use of wood C&D (exclu ding railroad ties) as

fuel on at least one occasion. In addition, the followi ng states have approved the

use of railroad ties as fuel on at l east one occasion: Maryland, Pennsylvania, Iowa, Michigan, and North Dakota. 8

5. C&D Materials Composition and Impacts

(1) Composition of C&D Materials:

• As indicated in Exhibit 2, EPA estimates th at concrete rubble makes up 40 to 50 percent of building-relate d C&D materials and that wood makes up 20 to 30 percent of this material.

8 The ASTSWMO survey also indicat es that New York and North Carolina have approved the use of

recovered wood materials as a fuel on at least one occasion but does not speci fy whether these approvals apply to the beneficial use of finished wood products or vegetative debris generated through land-clearing or natural disasters (ASTSWMO 2007, p.B-42).Construction and Demolition Materials – Building-related C&D Materials

7 Exhibit 2: Average Composition of Building-related C&D Materials

Building-Related C&D

Material Quantity Generated (million tons) Percent of C&D Debris Stream

Concrete Rubble 66 to 83 40-50%

Wood 33 to 49 20-30% Gypsum Drywall 8 to 25 5-15% Asphalt Roofing 2 to 16 1-10%

Metals 2 to 8 1-5%

Bricks 2 to 8 1-5%

Plastics 2 to 8 1-5%

Total 164 100%

Source:

Sandler 2003

• According to data submitted to EPA as public comments in response to the ANPRM, sample construction and demolition (C&D) debris in New Hampshire suggest that New Hampshire C&D de bris is 40 percen t wood, 15 percent aggregate, 14 percent drywall, 10 per cent roofing, 6 percent metals, 3 percent plastic, 2 percent cardboard, and 10 percen t other materials (Turley 2009). These data are reasonably consiste nt with the nationwide data presented above in

Exhibit 2.

• Data provided through pub lic comments on the ANPRM also indicate that C&D wood product is 12.4 percent moistu re, 43.3 percent carbon, 4.75 percent hydrogen, 0.4 percent nitrogen, 0.2 percent su lfur, 6.9 percent ash, and 32 percent oxygen (Turley 2009).

• A 2004 analysis of the composition of C& D wood chips used as fuel conducted by the Maine Department of Environmental Protection found that approximately 60 percent were untreated wood, 20 to 26 percent were C&D fines, and less than 10 percent were painted w ood, pressure-treated wood, non-burnables, and plastic (NESCAUM 2006).

• The rapid growth in the use of CCA-tre ated wood into the 1990s may translate into future growth of this material as a component of C&D. While information on national generation rates is not readily av ailable, some states do have data. For example, approximately 450 tons of CCA -treated wood was disposed of in Florida in 1996, and this figure was expected to quadruple by 2006. Recovered wood from C&D processing facilities in Fl orida was found to contain, on average, six percent CCA-treated wood in 1996. It should be noted that Florida’s

utilization of treated wood may be greater than utilizat ion in many states due to

the extensive use of treated wood fo r marine applications (Iida 2004).

• Public comments submitted from the Railway Tie Association on the ANPRM

state that creosote-treated wood doe s not contain contaminants that are significantly higher in concentration than those in traditional fuels (Gauntt 2009).Construction and Demolition Materials – Building-related C&D Materials

8 • Exhibit 3 presents detailed materials composition information for two general components of C&D building debris: secondary wood material and gypsum drywall. Based on the available data, c onstituent values for C&D building-related materials 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 traditional fu els by at least 50 ppm. In addition, the

available data indicate that the sulfur c ontent of drywall is orders of magnitude greater than that of traditional fuels.

(2) Impacts of C&D Materials use:

• Cost Impacts: The net cost impacts associated w ith beneficial use applications for construction and demolition materials depend on the avoided input or fuel costs

for facilities that use these materials and the cost of beneficial use itself. Both of these vary by C&D material and applicati on, as fees charged at the processing site

for delivered loads of recovered wood are based in part on local competitive disposal market rates. Construction wood and chemically treated wood often incur higher tipping fees, whereas a number of operations will pay for sawmill residue. The unit fuel savings for C&D used as a fuel (e.g., C&D wood burned in a boiler) would equal the savings from the fuel re placed net of the cost of the C&D wood and processing costs. Estimates of the average price of processed wood used as fuel in 2000 ranged from $11.16 to $12.50 pe r ton net of transportation (Krause 2000). The going rates of fossil fuels that could be readily replaced by C&D wood

are as follows: 9

o Natural Gas (Industrial): $7.35 / m illion Btu (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)

9 To express these values as dollars per Million Btu (MMBtu), the following thermal conversion factors were used: 1,031 Btu per 1,000 cubic foot of natural gas, 138,690 Btu per gallon of Number 2 distillate, 149,690 Btu per gallon of residual fuel oil, and 22,473,000 Btu per short ton of coal (EIA 2005, Tables A1, A4, and A5).9ConstituentsBuilding Related C&D DebrisCategories of WoodGypsum Drywall3Plywood/PressureBoard1CreosoteTreatedWood1VirginWood2C&D Wood (priortodecontamination)2---values in parts per million (ppm)---Aluminum (Al)294.6Antimony (Sb)0.03435 NAArsenic (As)0.14 1.97 0.001585 18.31 36.95 0.98 < 27.9Barium (Ba)28.15 24.95 185.97Boron (B)0.2725 NA 0.4 42.45Cadmium (Cd)0.14 1.4 0.134 0.92 0.645 < 0.48 3.08Calcium (Ca)219000 160360Chlorine (Cl)193.5Chromium (Cr)3.33 4.21 0.1305 28.59 55 1.09 11.61Cobalt (Co)< 0.48 9.17Copper (Cu)7.27 7.65 0.00965 33.53 3220 0.95 7.06-11.62Iron (Fe)44 857.9-941.8Lead (Pb)12.1 64.13 0.3255 130.9 258.5 0.7 15.6Lithium (Li)< 2.49Magnesium (Mg)2200 8475Manganese (Mn)9.1 44.5-45.64Mercury (Hg)0.13 0.09 0.197 0.12 0.1305 < 0.26Molybdenum (Mo)< 0.24 2.65Nickel (Ni)0.183 NA 0.83 20.1Nitrogen (N)9000 4000 280Phosphorus (P)7.5 < 21.7Potassium (K)< 62.1Selenium (Se)0 5 0.000075 0 BDLSilver (Ag)0.06 0.51 0.07Sodium (Na)Sulfur (S)2000 2000 181000 133821Titanium (Ti)0.97 52.89 230.5Zinc (Zn)22.83 101.69 145.74 3.08 11.49-16.63Notes:Blank cells indicate no data available.1.Holzman and Atkins (2009)2.Values in the left-hand column from Holzman and Atkins (2009).Values for Virgin Wood and values in the right-hand C&D Wood columnare from Jambeck, et al. (2007). These values reflect contaminant levels in unprocessed C&D wood,which should not be confusedwith“clean” C&D wood that is listed as a traditional fuel in the “Preliminary Characterization Study: Traditional Fuels and Key Derivatives” (EPA2010).3.Values in the left-hand column from Dontsova et al. (2005). Values in the right-hand column from Marvin (2000).BDL=Below Detection Limit10 • Emissions Impacts of Using C&D Wood Debris as a Fuel: To evaluate the environmental impacts of burning C&D w ood debris, we examined the emissions associated with burning wood debris in a boiler and compared these values to the

emissions associated with the combus tion of conventional fossil fuels, as summarized in Exhibit 4. The estimates in the exhibit suggest that the combustion of wood results in higher PM em issions than natural gas or distillate oil, but lower PM emissions than coal or residual oil systems. The data in Exhibit 4 also suggest that w ood 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. 10

Exhibit 4 also includes greenhouse gas em ission factors associated with the

combustion of wood. The Biomass Ener gy Resource Center suggests, however, that the net long-term effect of burning wood fuel is that no new CO 2 is added to the atmosphere (as long as the forests fr om which the wood came are sustainably managed). This is due to th e fact that when wood is burned, it recycles carbon that was already in the natural carbon cycle, as opposed to fossil fuels, which take carbon from the ground and through combustion release it to the atmosphere (Biomass Energy Resource Center).

The emissions profile of treated woods or wood with lead paint may differ from the values presented in Exhibit 4. Fo r example, concerning the combustion of railroad ties, the creosote in the tie s increases the combustion temperature, resulting in a more complete combustion of some organics such as benzene, formaldehyde, and dioxins. However, the creosote itself cont ains 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.

10 We note that the emission factors for wood presented in Exhibit 4 represent averages for wood-burning boilers. In addition, the wood reflected in the emissions data may include wood other than C&D wood debris. Emission factors for conventional fuels are based on typical boilers in use in North America in the late 1990s.Construction and Demolition Materials – Building-related C&D Materials11Exhibit 4: 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 – Building-related C&D Materials

12 Public comments received by EPA in response to the ANPRM include

information on emissions associated with the combustion of creosote-treated wood. More specifically, comments from the Railway Tie Association suggest that normal combustion practices for creoso te wood result in emissions similar to those resulting from the combustion of w ood and coal tar oil (Gauntt 2009). In addition, comments from the American Forest & Paper Association (AF&PA) suggest that, with the exception of 2-me thylnaphthalene, emissions of organic compounds from creosote treated wood we re 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 NO

x and SO 2 were essentially equivalent. Emissions of CO were lower for creosote treated wood (Hunt 2009).

• Lifecycle Emissions Impacts: Use of C&D wood 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, E xhibit 4 lists the quantities of the total cradle-to-gate emissions (“Combustion plus Upstream” ) for these fuels based on typical processes in the United States in the late 1990s, with wood scrap combustion presented as an indicator of the emissions likely from the combustion

of C&D wood debris. Note that there may be impacts associated with the processing of C&D wood debris into useable fuel that are not accounted for in the values presented in the exhibit. In ad dition, there may be alternative uses (e.g., composting) that are environmentally preferable to combustion.Construction and Demolition Materials – Building-related C&D Materials

13 References

Association of State and Territorial Solid Waste Management Officials (ASTSWMO). November 2007, 2006 Beneficial Use Study Report

.

Biomass Energy Resource Center, "Emissions and Air Quality," Available at: http://www.biomasscenter.org/information/emissions.html

Choong, Elvin et. Al. 1 November 2 000, “Decay Resistance of Out-of-Servi ce Utility Poles as Related to the

Distribution of Residual Creosote Content.” Forest Products Journal, Available at: http://www.allbusiness.com/agriculture-forestry/fo restry-logging-forest-nurseries/710440-1.html

Commission of the European Communities, “Green Paper: Environmental issues of PVC,” July 26, 2000.

Dontsova, Katerina, et al. "Gypsum for Agricultural Use in Ohio Sources and Quality of Available Products." Ohio State University School of Natural Resources. 2005. Available at: http://ohioline.osu.edu/anrfact/0020.html

Franklin Associates. 1998, “Franklin US LCI 98 Library”.

Franklin Associates. “Characterization of Building-Re lated Construction and Demolition Debris in the United States,” Prepared for the Environmental Protection Agency, Contract No. 68W02-036, Work Assignment 3-06, 2005, p3-7.

Gauntt, James, public comment in response to EPA’s Advanced Notice of Proposed Rulemaking for Identification

of Non-Hazardous Material s That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008-0 329, submitted on behalf of the Railway Tie Association, February 2, 2009.

Goldstein, Nora. October 2006, "Wood Re cycler Taps Biomass Energy Markets." Biocycle Vol. 47.

Holzman, Michael, Atkins, Richard, public comment in response to EPA's Advanced Notice of Proposed Rulemaking for Identification of Non-Hazardous Mate rials That Are Solid Waste, EPA docket EPA-HQRCRA-2008-0335.2, submitted on behalf of The Treated Wood Council, February 1st, 2009.

Hunt, Timothy, public comment in response to EPA’s A dvanced Notice of Proposed Rulemaking for Identification

of Non-Hazardous Material s That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008-0 329, submitted on behalf of the American Forest & Paper Association (“AF&PA”), February 2, 2009.

Iida, Kenjiro, John Pierman, Thabet Tolaymat, Timothy Townsend, Chang-Yu Wu. 2004, “Control of Chromated Copper Arsenate Wood Incineration Air Emissions and Ash Leaching Using Sorbent Technology,” Journal of Environmental Engineering , February 2004.

Jambeck, Jenna, Carpenter, Alberta, Gardner, Kevin. "University of New Hampshire Life-Cycle Assessment of C&D Derived Biosmass/Wood Waste Management" Environmental Research Group. UNH, Durham, NH. December 5, 2007

Komorowski, Kenneth, public comment in response to EPA’s Advanced Notice of Proposed Rulemaking for

Identification of Non-Hazardous Materials That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008- 0329, submitted on behalf of Koppers Inc., February 2, 2009.

Krause, Timothy. 2000, “Recovered Wood Processing: An Industry Update.” Resource Recycling, p. 12-20.

Marvin, Emma. "Gypsum Wallboard Recycling and Reuse O pportunity in the State of Vermont." Vermont Agency of Natural Resources: Waste Management Division. August 4, 2000.Construction and Demolition Materials – Building-related C&D Materials

14 McKeever, David B. 2002, "Inventories of Woody Residues and Solid Wood Waste in the United States, 2002,"

USDA Forest Service.

Miller, Jeffrey, public comment in response to EPA’s Advanced Notice of Proposed Rulemaking for Identification

of Non-Hazardous Material s That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008-0 329, submitted on behalf of the Treated Wood Council, February 2, 2009.

Natural Resources Canada. “Buyer’s Guide to Sma ll Commercial Biomass Systems.” 2000. Available at: http://www.canren.gc.ca/prod_ser v/index.asp?CaId=130&PgId=729

Natural Resources Institute (NRI). “What do we mean by Gasification?” Undated. Available at: http://www.nri.org/projects/biomass/conf erence_papers/gasification_process.pdf

Northeast States for Coordinated Air Use Management (NESCAUM). May 2006, "Emissions from Burning Wood

Fuels Derived from Construction and Demolition Debris".

Reid, Magny. 17 February 2002, “Toxic Ties?” La Crosse Tribune, Available at: http://findarticles.com/p/articles/mi_qa3652/i s_200202/ai_n9039015/pg_1?tag=artBody;col1

Sandler, Ken. "Analyzing What 's Recyclable in C&D Debris" BioCycle , November 2003, Vol. 44, Iss.11; p. 51.

Shingle Recycling.org. 2007, “Marke ts for Recycling Asphalt Shingles.” Accessed 26 September 2008. Last updated 15 January 2007. Available at: http://www.shinglerecycling.org/index.php?optio n=com_content&task=view&id=51&Itemid=147

Solid Waste Association of North Amer ica (SWANA). 2002a "Successful ap proaches to recy cling urban wood waste," Madison, WI: U.S. Department of Agricultu re, Forest Service, Forest Products Laboratory.

Solid Waste Association of North Amer ica (SWANA). 2002b "Cost-Effectiven ess of Processing C&D Wastes and Markets for Recovered C&D Materials," Prepared for SWANA Applied Research Foundation Disposal Group Subscribers.

Turley, William, public comment in response to EPA’s A dvanced Notice of Proposed Rulemaking for Identification

of Non-Hazardous Material s That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008-0 329, submitted on behalf of the Construction Materials Recycling Association, February 2, 2009.

United States Census Bureau. Last updated 2 August 2007, "2007 NAICS Definition: 238910 Site Preparation Contractors," Available at: http://www.cens us.gov/eos/www/naics/htmls/2/238910.htm

United States Census Bureau. Last updated 12 September 2008, “New Privately Owned Housing Units Started: Annual Data,” Available at: http://www.census.gov/const/startsan.pdf

United States Department of Commerce, Bureau of Economic Analysis. 30 October 2008, “Gross Domestic Product: Third Quarter 2008 (Advance Notice).” Ava ilable at: http://www.economicindicators.gov/

United States Department of Labor, Bureau of Labor Statistics. Last updated 19 August 2008, "Industries at a Glance: Construction of Buildings: NAICS 236," Available at: http://www.bls.gov/iag/tgs/iag236.htm#workplace_trends

United States Energy Informati on Administration (EIA). 2007, Annual Coal Report 2006

.

United States Energy Informati on Administration (EIA). 2005, Annual Energy Review 2004.

United States Energy Information Administration (EIA). 2008a, “Natural Gas Monthly: July 2008”.

United States Energy Inform ation Administration (EIA). 2008b, “Preliminary Petroleum Marketing Annual 2007”.Construction and Demolition Materials – Building-related C&D Materials

15 United States Environmental Protectio n Agency (EPA). June 1998, “Characterization of Building-Related

Construction and Demolition Debris in the United States,” prepared by Franklin Associates.

United States Environmental Protection Agency (EPA ), "RCRA In Focus: Construction, Demolition and Renovation," EPA-530-K-04-005, September 2004.

United States Environmental Protection Agency (EPA), 2010. Preliminary Ch aracterization Study Traditional Fuels and Key Derivatives Prepared in Support of the Proposed Rulemaki ng –Identification of Nonhazardous Secondary Materials That Are Solid Waste, March 18, 2010.

United States Environmental Protection Agency (EPA). 2009, Combustor survey database in support of the 2009 proposal of the Commercial and Industrial Solid Wa ste Incinerator (CISWI) standards and the Industrial Boilers Maximum Achievable Control Technology (MACT) standards, April 2009.

United States Green Building Council (USGBC). Last updated 25 June 2005, “PVC Task Group Resources: Disposal Outreach Forum.” Accesse d 27 August 2008. Available at: http://tsac-pvc.obiki.org/disposal.html

WasteAge. 1995, “Recycling Keeps Railroad Ties off the Landfill Track.” Available at: http://wasteage.com/mag/waste_recycling_keeps_railroad/

.

Wright L, Boundy B, Perlack B, Davis S, Saulsbury B. 2006, Biomass Energy Data Book: Edition 1 (ORNL/TM2006/571, Oak Ridge National Laboratory, Oak Ridge, TN).