Hammering Out a C&D Standard

Most readers of this magazine have a wealth of knowledge about “traditional” recyclables such as paper, glass, metals and plastics. Over the last two decades we have seen tremendous gains in recycling these materials. So much so, that regulators are giving increased attention to the concrete, wood, bricks and other materials that are generated at construction and demolition sites.

For decades, many of these “C&D” materials have been collected and processed for recycling. Nonetheless, this industry does not have the public profile of “traditional” recycling. Yes, C&D processing facilities face the usual NIMBY opposition, just like facilities that process municipal recyclables. But the contributions of these recycling operations are not as widely known as they could be.

Even the most basic C&D data is hard to come by. Unlike its yearly censuses of garbage and recycling, EPA has estimated C&D generation and recycling only twice. The most recent survey took place more than five years ago. Given the impact of the “Great Recession” on the construction industry, that data has little relevance now. Nonetheless , we probably generate about than half as much C&D as municipal solid waste. Recycling is thoroughly entrenched in C&D, just as it is in its municipal counterpart.

I recently became more involved in C&D issues, co-managing a project to write specifications for C&D-derived wood fuel. I had the good fortune to work with Bill Turley of the Construction Materials Recycling Association (CMRA). Our task force included industry members with a wealth of experience in processing C&D material, including wood. Our goal was to improve its marketability. We knew that paper and metal recyclables enjoy the benefit of widely known and accepted specifications that describe a multiplicity of grades. We believed that C&D wood would benefit from similar specifications.

I never thought this would be an easy task. For once, I was right. I lost track of the number of drafts, conference calls and analyses we went through. Then, just as we were ready to finalize the specification, EPA issued a set of three boiler regulations and a new rule defining, among other things, when C&D wood could be burned as a fuel in a boiler and when it would be burned as a waste.

We thought the answer was a no-brainer. The preamble to EPA’s rule said many positive things about the use of C&D wood as a fuel. EPA acknowledged the extent of processing undertaken by C&D recyclers to ensure their wood product could be burned safely. Yet the agency created a regulatory roadblock that forces this fuel product to traverse a cumbersome route to approval before it can be burned as a fuel. We felt as though EPA had given us a free ride to the one-yard line and then said, “Oh, by the way, that last yard is mined. Good luck getting into the end zone.” At this point, that issue is up to the lawyers. I am sure they will enjoy it.

In addition to the specification project, CMRA has introduced a certification process for verifying C&D recycling rates. That process should aid projects seeking LEED certification in incorporating C&D recycling. All of these efforts should pay off handsomely when the economy recovers and C&D projects start generating more recyclable materials. And who knows, maybe by then, EPA will have removed its roadblock.