Hi All,
I would like to hear your opinion about co-processing as an acceptable waste diversion to meet the intent of this credit. Our project is managing waste by submitting those that can no longer be recycled to co-processing. Co-processing is defined as a secure form of waste management that fully recovers the energy and mineral components from waste for use as fuel. Solid wastes are shredded to uniform size to yield maximum energy creation. The waste is then used as a fuel source in cement kilns. The ash left in the kiln is then used as fly ash component in the cement mix.
I am confused on USGBC and GBCI’s take this. Our project is similar to the inquiry in LI 2141 (dated 24 March 2004) where their unrecyclable waste will be transported to a Waste to Energy facility where its byproduct will be used to produce a low grade cementitious material. However, the ruling states the following: “The CIR is inquiring if the diversion of non-recyclable materials to an EPA approved Waste to Energy facility qualifies as construction waste diversion for the purpose of this credit. The intent states ” Divert construction & demolition debris from disposal in landfills & incinerators.” Based on the credit intent, incineration of construction waste materials cannot be used as an alternative for diverting waste from the landfill. Applicable internationally” So it seems that it’s not acceptable. However, I read an article in EDC-The USGBC recognized magazine for LEED professionals (http://www.lafarge-na.com/EDC_Reprint_0713_WasteIntoGold_Final.pdf), that a project in Kansas certified in 2012 was able to document waste diversion by repurposing the construction waste as fuel for the cement kiln and as a raw material component in the Portland cement produced.
Am I wrong in thinking that the LI 2141 inquiry is the same as the approach done by the LEED certified project in Kansas? Do you think I can submit a similar approach to the one prepared by the project in Kansas and get approval from GBCI? Your thoughts on this will be greatly appreciated.
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RETIRED
LEEDuser Expert
623 thumbs up
June 1, 2017 - 11:01 am
Hi Carla - I wanted to note a couple of things: First, LI ID #2141 relates to LEED v2 and although there were very few changes in the credit requirements between v2 and 2009 (v3), that LI is not applicable to anything but v2 projects. That said, the LI is saying that you can't just send materials to an incinerator where they are burned and count it as diversion. This philosophy carries into 2009 (v3).
Second, the EDC Magazine is not an official USGBC publication.
Third, from what I read in the article, they were not just incinerating waste material. The waste material was reprocessed into a fuel for a cement kiln as well as a raw material component in cement. (The waste material was directed back to the manufacturing process and reprocessed into new materials, which had value on the open market.)
I think you're saying that your material is incinerated and the resulting by-product will be used to produce a material. This is not the same as sending materials to be made into another product (fuel for cement kiln) that is then incinerated. Do you see the difference?
You might want to look at LI ID #2256 - http://www.usgbc.org/content/li-2256, which while dealing with ADC states: "Any construction debris processed into a recycled content commodity which has an open market value - e.g. alternative daily cover material, etc. - may be applied to the construction waste calculation."
Katherine Ann Resurreccion
Arcadis Philippines, Inc.159 thumbs up
June 5, 2017 - 5:10 am
Thank you, Michelle, for the detailed response! Noted on the first response. We also concur with the second response. EDC is not an official USGBC publication. To clear confusion for others, USGBC only named EDC as “The Official Magazine for the LEED® Professional." (http://www.usgbc.org/articles/edc-named-official-magazine-leed-%C2%AE-pr...)
To clarify, our project waste will not be incinerated solely to use its byproduct to produce a new material. It will be burned inside the kiln to recover the energy and mineral components from waste for use as fuel. We are actually involving the same company who helped the LEED certified project get the MRc2 credit to do the same process for our waste. However, we got confused in the part of their process where they reprocess waste as fuel by shredding and burning it in the cement kiln (http://www.geocycle.us/our-solutions/co-processing-services.html). We thought it might be similar to the incineration process disapproved by GBCI. But after your response, is it safe to say that since the waste material was reprocessed into fuel for a cement kiln - using waste (which can no longer be recycled) with high flammable properties as fuel; as well as reprocessed waste as a raw material – fly ash in the kiln will be added as raw material to the cement component, there will be high chances for the documentation to be accepted? The company specifically differentiated their process from incineration because the fly ash generated in the process is eventually being thrown to landfills while theirs is repurposed as raw materials to cement.
RETIRED
LEEDuser Expert
623 thumbs up
June 5, 2017 - 11:44 am
Carla - To close the loop on EDC Magazine: I did not include some comments that I had drafted last week where I noted some errors in the article that you referenced. I was just trying to say that sometimes you'll see some LEED misinformation in non-USGBC publications. (And it's a moot point since EDC Magazine is now defunct- http://www.wconline.com/EDC-Magazine.)
RE: Co-processing: Based on your revised statements and my reference to LI ID #2256, I think that you should be able to make the case that your waste product is being made into recycled content commodity and hence is applicable. I would be sure to reference this LI in the Special Circumstances area of the LEED form. Good luck!
RETIRED
LEEDuser Expert
623 thumbs up
June 13, 2017 - 5:06 pm
Carla - I was in the Addenda Database and wanted to ensure you had seen LI ID #1685 - http://www.usgbc.org/content/li-1685.
While it discusses wood derived fuel, I think you'll see how the value-added process parallels your situation.
Katherine Ann Resurreccion
Arcadis Philippines, Inc.159 thumbs up
July 24, 2017 - 11:56 pm
Thank you Michelle!
We'll be submitting the above mentioned type of waste and will include narratives to support how the process of diversion has value-added processes that will comply to the credit requirements.