CI-2009 MRc4: Recycled Content 1-2 points

In the waste diversion process many questions have come up regarding utilizing Waste-to-Energy as a landfill diverstion strategy. Can Waste-to-Energy be utilized as a landfill diversion strategy if; this effort ran parallel to sorting recyclable and reusable materials, and the power plant proposed has approved EPA pollution control devices. Alternatively, can paying additional cost to transport non recyclable trash to a Waste-to Energy power plant to be incinerated and converted into electrical energy count as diverted waste?

Please provide clarification on documentation of recycled content claims and FSC certified claims for woods products such as particleboard, MDF and other composites.

The project team is seeking clarification for our intended use of on-site excavated rock. During excavation and site work at the project, a large amount of limestone rock was encountered. Instead of disposing of the rock off-site, we are using it on-site. We are breaking up the on-site rock into 12 - 18" pieces for use as rip-rap. This eliminates the need to use virgin quarry rock and reduces the amount of the volume of waste sent to the landfill. We would like to apply the market value of the rip-rap to MR credit 4.1, Recycled Content (pre-consumer). We will use the following formula for our calculations: # of Tons of excavated rock used on site * the local quarry price per ton * 1/2 = $ applied to MRc4.1 Since this approach will use what is typically a waste stream and use it to reduce the demand for off-site materials, it seems to meet the overall intent of the LEED process. If the rock cannot be applied to MRc4.1, is there any other credit that it could be applied to?

Our project is a 185,000 SF lab. The lab is served by a Satellite Energy Plant (SEP) of 6,265 SF, being constructed concurrently, but on a separate site. We intend to apply for certification for only the lab building and not the SEP. Both buildings are currently under construction and the contractor is tracking the materials and providing us submittals for the MR Credits. However the contractor is not able to separate the materials\' submittals (e.g. steel) for the two buildings, without considering it a change-order or requiring a re-bid from the sub-contractors. We foresee the SEP materials to be a very small portion of the materials used. We have detailed cost estimates based on construction documents that give us a split between the two buildings. We would like to use these cost estimates to calculate and thus split the relevant material quantities in the contractor\'s submittals so that we can count the materials appropriately for the lab building in our certification documentation. Is this approach acceptable to you? If not, can you suggest another approach, that would be acceptable given our circumstances, that would avoid a re-bid or change order?

This CIR asks for further clarification of the ruling dated 3/23/2004 that states "Incineration cannot be used as an alternative method for diverting waste from the landfill for purposes of credit achievement." Our recycling facility processes construction and demolition (C&D) debris into numerous commodities. One of these products is Wood Derived Fuel (WDF) which is sold to local paper mills to replace virgin wood, natural gas and oil. While the product is burned, it is not incinerated. The USEPA has recently provided a category for such materials and defined them as Biofuel: A gaseous, liquid, or solid fuel that contains an energy content derived from a biological source. WDF has an energy content value of 8,500 Btus per pound of fuel and is derived from the collection, sorting and processing of C&D waste. The LEED Reference Guide defines recycling as "the collection, reprocessing, marketing and use of materials that are diverted or recovered from the solid waste stream." Before accepting co-mingled C&D debris for processing, the recycler we use demands that we provide Asbestos Hazard Emergency Response Act (A.H.E.R.A.) documentation proving the C&D loads have been inspected and abated. In addition, they maintain on-site testing equipment to detect lead & asbestos (such as XRF for lead and a polarized light microscope for asbestos). C&D debris that passes these tests is then accepted and sent through an elaborate sorting system where commodities ranging from LDPE plastic to Steel are separated and sold. Wood represents the largest volume of material they accept and is processed into 4-different commodities including WDF, Colorized Mulch, Pulp Furnish and Alternate Daily Cover. Facilities that purchase WDF have boiler permits that meet the requirements of 40 CFR Part 63 of the USEPA National Emission Standards (http://www.epa.gov/epacfr40/chapt-I.info/). Prior to the development of recycled WDF, most C&D wood waste was land filled and lumber mill saw dust was used as WDF. As the market for recycled WDF has developed, its use has resulted in lumber mill wood waste residuals traditionally consumed as fuel to be up-cycled into particle board, pulp and MDF, which is currently the highest use of this resource. . When C&D wood waste is land filled, the anaerobic conditions present in a landfill result in wood waste generating large quantities of methane gas. Methane gas has a global warming potential that is 23 times more hazardous than CO2 (http://www.rmi.org/sitepages/pid1215.php, November 08, 2006), where as consuming WDF in a modern industrial boiler is considered carbon neutral. The CIR ruling dated 3/23/2004 specifically denies diversion credit for C&D debris delivered to a mass-burn incinerator that uses excess heat to generate electricity, (Waste to Energy, WTE). The CIR recognized that the primary function of a WTE incinerator is to reduce the volume of waste placed in a landfill. The incinerator accepts everything that could be delivered to the landfill and they charge as much or more than is typically charged for landfill disposal. In contrast, our permitted recycling facility creates a recycled content commodity that is sold for profit. They manufacture WDF from a portion of the C&D debris they receive and they sell the WDF to paper mills that operate USEPA permitted industrial boilers to produce the heat energy needed to manufacture and recycle paper. Use of this product as a commodity is consistent with the LEED Reference Guides definition of recycling and with CIR dated 5/17/2004 for the production of Alternative Daily Cover. Audit documentation, such as receipts of sale of WDF to USEPA permitted facilities, can provide evidence of material diversion as WDF. For these reasons, we believe producing Wood Derived Fuel (WDF) meets the intent of the credit and seek to gain a ruling as such from the USGBC materials TAG.

Intent: "Increase demand for building products that incorporate recycled content materials, thereby reducing impacts resulting from extraction and processing of virgin materials." The project targeting LEED-CS certification is located in Ontario, Canada. The LEED-CS Reference Guide requires that "SCMs as a percentage of total cementitious materials" and the "Dollar value of all cementitious materials" are provided by the manufacturer. The Redimix Concrete Association of Ontario states that concrete mixes are confidential, and as such will not divest the "Dollar value of all cementitious materials" as required by the LEED-CS Reference Guide. (For LEED Canada-NC projects, it is standard practice in Ontario for concrete suppliers to provide the overall recycled content of concrete in a signed letter.) To accommodate this situation, we propose the following documentation approach to the LEED-CS version of the SCM calculation. Following these steps will mathematically yield the same result as the procedure outlined in the LEED-CS Reference Guide: 1) The supplier determines the recycled content value due to SCMs for the entire project by multiplying the "SCMs as a percentage of total cementitious materials" and the "Dollar value of all cementitious materials". 2) The supplier provides a signed letter indicating the recycled content value due to SCMs for the entire project. 3) When completing the letter template, instead of providing the value of all cementitious materials and the recycled content, we provide the recycled content value due to SCMs, and indicate that the recycled content is 100% (pre-consumer). Please confirm if this approach is acceptable.

The proposed project site is located on a military base that has potentially unexploded ordnance on-site.Protection from potential detonation during construction is required by the federal government to shield pedestrians and existing housing across the street from the project site. As a part of the project, a detonation barrier is to be constructed prior to start of excavation. This barrier can be built using various material but must have substantial foundations and structural strength to withstand large explosion forces. After construction is completed, the detonation barriers would be deconstructed to allow access to the site.The project team is proposing to incorporate salvaged local material into the design of these barrier walls. May the salvaged material qualify for MR credit 5 for regional material, MR credit 4 for recycled content?

Methodology #1 Each co-mingled load of construction debris is weighted at the MRF and visually inspected then the percentage of each recyclable material is tallied. The recyclable materials are then processed for sale on the secondary market. The tallied data is documented in a running monthly report created by either the MRF or the Hauler and is submitted to the contractor for the project. Methodology #2 The MRF\'s self-reported recycling percentage rate (for the entire facility) is applied toward specific LEED projects\' delivered co-mingled tonnage brought to that facility. We are aware of the CIR ruling dated 12.2.05 stating that a project can use this methodology if a facility has government oversight over a facility\'s recycling rate calculations. In our case we have government oversight of the MRFs overall recovery rates but the reporting methodology required by the oversight agency doesn\'t account for C&D debris - asphalt, gypsum wallboard, and concrete tonnage which is processed through those facilities. LEED NC v2.2 accepts and credits concrete towards MRc2 but this disconnect between how the oversight agency tracks materials versus what is actually processed in a facility doesn\'t allow for accurate reporting and subsequent award of LEED credit in our local market. Please let us know if one or both methods are acceptable for tracking and documenting co-mingled boxes for MRc2.

Our project is located in Los Angeles, California. Construction waste is sorted at the jobsite into various boxes i.e. wood, metal, concrete/inert material, drywall/gypsum, co-mingled recycled waste (small wood scraps, wire cuttings, conduit, metal stud cut offs, etc.), and general trash boxes. A contracted hauler regularly collects these boxes. General trash is taken directly to the landfill where it is weighed and then buried. Separated recycling materials are taken to various certified City of Los Angeles recycling facilities where they are weighed and processed. Co-mingled recycled waste is taken to special certified recycling facilities where the co-mingled mix is weighed and then the recyclable materials are removed from the mix and sent to appropriate facilities for processing. This process does not allow for each recyclable material type from the co-mingled load to be weighed separately. The City of Los Angeles\' Department of Sanitation audits all of the co-mingled sorting facilities on a regular basis and establishes a yearly average recycling percentage rate for "each" facility. The certification recycling percentage rates vary. When calculating the construction waste recycling percentage for MRc2.1, will the USGBC accept the City of Los Angeles\' annual recycling percentage rate for the "specific" facility that accepts this LEED project\'s co-mingled component of the project\'s waste stream?

One of the most significant materials we have specified for this project is a wall system that is comprised of recycled polystyrene embedded in a Portland cement matrix cast into panels to provide both structural support, and a high insulation value. This system (Perform Wall) has an average weight per panel (10"x15"x10\') of 156 lbs. Because polystyrene is so much lighter than cement, the polystyrene within the panel only weighs 37lbs, but comprises 85% of the panel by volume. We have this information documented from the manufacturer. To calculate the percentage of recycled material based on the criteria of weight only, the polystyrene would only be 24 % of the total weight, while the manufacturer states that the polystyrene is 85% of the product volume. We believe we have followed the design intent by specifying a product with a high percentage of recycled content, and would like to be granted an exception to the calculation method and be permitted to utilize the 85% for submittal purposes. We will include the manufacturer\'s information in the submittal.