1 

Materials Characterization Paper 

In Support of the 

Final Rulemaking: 

Identification of Nonhazardous Secondary Materials That Are Solid Waste

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

February 3, 2011 

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

1. Definition of Building-Related Construction and Demolition Materials 

Building-related construction debris and demolition (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 construction, 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 metal) as well as the 

packaging materials that building materials arrive in (such as cardboard and plastics). 

Construction materials are usually generated as a result of cutting a material down to size for 

installation or purchasing materials in excess of what is needed. Wood materials consists of 

wood scraps from dimensional lumber, siding, laminates, flooring (potentially stained), 

laminated beams, and moldings (potentially painted). Demolition materials are generated from 

the dismantling of buildings or the removal phase of remodeling. Typical constituents include 

concrete, wood, metal, insulation, glass, carpet, and other building materials. Debris from this 

process is often painted or chemically treated or is fastened to other materials, making separation 

difficult (NESCAUM 2006). For the purposes of this summary, wooden railroad crossties and 

wooden utility poles are also characterized 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 information on the beneficial use 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). Information 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 summary does not include a 

detailed examination of either 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 are produced by NAICS 236: Construction of Buildings 

(U.S. Department of Labor 2008). Demolition Materials are produced by NAICS 

238910: Site Preparation Contractors (U.S. Census Bureau 2007). 

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

• EPA estimates that 164 million tons2

 of building-related C&D debris were 

produced in 2003. Approximately 47 percent 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-related C&D materials generated in 2003, 

EPA estimates that between 33 and 49 million tons2

 was C&D wood (Franklin 

2005). 

• As corroboration for EPA’s 2003 estimate of C&D wood debris generation, a 

USDA source estimates that approximately 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 debris (20.28 million short tons) is of 

acceptable size, quality, and condition to be considered available for recovery. 

Factors limiting “availability” include contamination and the commingling of 

wood with other nonwood building products (McKeever 2002). 

• The quantity data presented above do not reflect the generation of scrap railroad 

ties or utility poles. A 1995 analysis indicates that 13 million 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 the 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 million tons in 1998 to 164 million tons in 

2003 (EPA 1998, Franklin 2005). Assuming that this growth rate applies to 

building-related C&D wood debris, the generation 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 the trend in economic 

activity (McKeever 2002). That is, a strong 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 including 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 boiler 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 converted into gaseous components (carbon 

monoxide, hydrogen, methane, and other inert gases) through gasification. In 

contrast to incineration, which fully converts the input debris into energy and ash, 

gasification deliberately limits the conversion 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 materials4

 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-treated 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. However, 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 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 (Btu). 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 million tons of secondary wood material 

per year that may be construction and demolition debris6

 (EPA 2009). 

• Railroad ties are in demand for combustion due to their low moisture content. In 

addition, because most crossties are creosote-treated, the chips reportedly allow 

boilers to burn at a higher temperature than they would with 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 the wood products to be treated by creosote possess permits 

to burn creosote-treated wood 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 shingles 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 facilities 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 can potentially yield 

revenues 20 to 32 times higher than those from selling wood for fuel or mulch. 

Similarly, recycling wood to the manufacturing 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 with the reuse of lumber and engineered wood product 

feedstock options are also much greater than 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 ties 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 and 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 estimates that 98.4 million tons, approximately 

60%, of building-related C&D debris were disposed in 2003 (Franklin 2005). A 

corresponding estimate specific to wood 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 tons 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 related 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 development of this document 

provided no indication that large quantities of C&D materials are stockpiled. 

 Exhibit 1: C&D Material Quantities 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 available as combustion fuel through a 

variety of methods, but it is typically sent to a processing facility by municipal 

haulers, private haulers, construction companies, or individual households. After 

the wood is processed according to combustor specifications, it is delivered to 

combustion facilities (NESCAUM 2006). 

 7

 The primary exception to this is wood treated 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 typically requires removal of non-wood materials 

and processing into chips. Fuel specifications for combustors usually include 

minimum and maximum chip sizes, amount of C&D fines, maximum moisture 

content, and maximum contaminant levels (NESCAUM 2006). 

• A “hog” (also called a shredder or tub grinder) is used to process construction and 

demolition wood materials. The hog uses rotating hammers and stationary anvils 

to smash, crush and tear large wood into smaller fragments. The maximum output 

particle dimension of hogged fuel is typically less than 3 inches. Hogged fuel 

often has a high moisture content and a significant ash content (from 2 to 20 

percent) (Natural Resources Canada 2000). 

• Public comments submitted by the Treated Wood Council in response to the 

ANPRM indicate that treated wood products may or may not require processing, 

such as sorting, cleaning, cutting, de-nailing, etc. (Miller 2009). 

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

• According to state responses to a 2006 survey by the Association of State and 

Territorial Solid Waste Management Officials (ASTSWMO), two states—Maine 

and Michigan—have approved the use of wood C&D (excluding railroad ties) as 

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

use of railroad ties as fuel on at least 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 that concrete rubble makes up 40 to 50 

percent of building-related C&D materials and that wood makes up 20 to 30 

percent of this material.

 8

 The ASTSWMO survey also indicates 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 specify 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 debris is 40 percent wood, 15 percent 

aggregate, 14 percent drywall, 10 percent roofing, 6 percent metals, 3 percent 

plastic, 2 percent cardboard, and 10 percent other materials (Turley 2009). These 

data are reasonably consistent with the nationwide data presented above in 

Exhibit 2. 

• Data provided through public comments on the ANPRM also indicate that C&D 

wood product is 12.4 percent moisture, 43.3 percent carbon, 4.75 percent 

hydrogen, 0.4 percent nitrogen, 0.2 percent sulfur, 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 wood, pressure-treated wood, non-burnables, and plastic 

(NESCAUM 2006). 

• The rapid growth in the use of CCA-treated 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 available, 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 Florida 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 utilization in many states due to 

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

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

state that creosote-treated wood does 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, constituent 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 fuels by at least 50 ppm. In addition, the 

available data indicate that the sulfur content 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 with 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 application, 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 replaced 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 per 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 / million 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). 
9 

Constituents 

Building Related C&D Debris 

Categories of Wood 

Gypsum Drywall3

Plywood/ 

Pressure 

Board1 

Creosote 

Treated 

Wood1 

Virgin 

Wood2 

C&D Wood (prior 

to 

decontamination)2 

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

Aluminum (Al) 294.6 Antimony (Sb) 0.03435 NA Arsenic (As) 0.14 1.97 0.001585 18.31 36.95 0.98 < 27.9 Barium (Ba) 28.15 24.95 185.97 Boron (B) 0.2725 NA 0.4 42.45 Cadmium (Cd) 0.14 1.4 0.134 0.92 0.645 < 0.48 3.08 Calcium (Ca) 219000 160360 Chlorine (Cl) 193.5 Chromium (Cr) 3.33 4.21 0.1305 28.59 55 1.09 11.61 Cobalt (Co) < 0.48 9.17 Copper (Cu) 7.27 7.65 0.00965 33.53 3220 0.95 7.06-11.62 Iron (Fe) 44 857.9-941.8 Lead (Pb) 12.1 64.13 0.3255 130.9 258.5 0.7 15.6 Lithium (Li) < 2.49 Magnesium (Mg) 2200 8475 Manganese (Mn) 9.1 44.5-45.64 Mercury (Hg) 0.13 0.09 0.197 0.12 0.1305 < 0.26 Molybdenum (Mo) < 0.24 2.65 Nickel (Ni) 0.183 NA 0.83 20.1 Nitrogen (N) 9000 4000 280 Phosphorus (P) 7.5 < 21.7 Potassium (K) < 62.1 Selenium (Se) 0 5 0.000075 0 BDL Silver (Ag) 0.06 0.51 0.07 Sodium (Na) Sulfur (S) 2000 2000 181000 133821 Titanium (Ti) 0.97 52.89 230.5 Zinc (Zn) 22.83 101.69 145.74 3.08 11.49-16.63 Notes: 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 column 

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). 

3. Values in the left-hand column from Dontsova et al. (2005). Values in the right-hand column from Marvin (2000). 

BDL=Below Detection Limit
10 

• Emissions Impacts of Using C&D Wood Debris as a Fuel: To evaluate the 

environmental impacts of burning C&D wood debris, we examined the emissions 

associated with burning wood debris in a boiler and compared these values to the 

emissions associated with the combustion of conventional fossil fuels, as 

summarized in Exhibit 4. 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 

4 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.10 

Exhibit 4 also includes greenhouse gas emission factors associated with the 

combustion of wood. The Biomass Energy Resource Center suggests, however, 

that the net long-term effect of burning wood fuel is that no new CO2 is added to 

the atmosphere (as long as the forests from which the wood came are sustainably 

managed). This is due to the 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. For example, concerning the combustion of 

railroad ties, the creosote in the ties increases the combustion temperature, 

resulting in a more complete combustion of some organics such as benzene, 

formaldehyde, and dioxins. 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. 

 

 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 – Buildi

11

Exhibit 4: 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 – 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 creosote wood result in emissions similar to 

those resulting from the combustion of wood and coal tar oil (Gauntt 2009). In 

addition, comments from the American Forest & Paper Association (AF&PA) 

suggest 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). 

• 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, Exhibit 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 addition, 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 2000, “Decay Resistance of Out-of-Service Utility Poles as Related to the 

Distribution of Residual Creosote Content.” Forest Products Journal, Available at: 

http://www.allbusiness.com/agriculture-forestry/forestry-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-Related 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 Materials That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008-0329, submitted on 

behalf of the Railway Tie Association, February 2, 2009. 

Goldstein, Nora. October 2006, "Wood Recycler 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 Materials 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 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 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 Opportunity 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 Materials That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008-0329, submitted on 

behalf of the Treated Wood Council, February 2, 2009. 

Natural Resources Canada. “Buyer’s Guide to Small Commercial Biomass Systems.” 2000. Available at: 

http://www.canren.gc.ca/prod_serv/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/conference_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/is_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, “Markets for Recycling Asphalt Shingles.” Accessed 26 September 2008. Last 

updated 15 January 2007. Available at: 

http://www.shinglerecycling.org/index.php?option=com_content&task=view&id=51&Itemid=147

Solid Waste Association of North America (SWANA). 2002a "Successful approaches to recycling urban wood 

waste," Madison, WI: U.S. Department of Agriculture, Forest Service, Forest Products Laboratory. 

Solid Waste Association of North America (SWANA). 2002b "Cost-Effectiveness 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 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 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.census.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).” Available 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 Information Administration (EIA). 2007, Annual Coal Report 2006. 

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

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

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

15

United States Environmental Protection 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 Characterization Study Traditional Fuels 

and Key Derivatives Prepared in Support of the Proposed Rulemaking –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 Waste 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.” Accessed 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).