CI 2009 MRc2: Construction Waste Management

Matt, I think the fact that your client wants to reuse their furniture is great, but I do not think that this could be applied to MRc2. The reference guide states that this credit addresses "how much waste material leaving the site is diverted from landfills." LEED precedent has shown that work performed outside of LEED project boundary (e.g. waste diversion) does not typically contribute to the relevant LEED credit. Similarly, I do not believe the filing system would contribute to MRc2.

However, it sounds like you would have sufficient reused furniture to achieve MRc3.2 - Reuse Furniture and Furnishings. This would especially be true if you can make a case that the high-density filing system fits under Division 12.

SB, my understanding is that recycling this material requires special grinding equpiment that is not yet in market use. (See the EBN article Better Choices in Low Slope Roofing.) I think if anyone is going to do it, it would be the manufacturer, though.

My first question is whether you are actually meeting the intent of the credit. You might want to check out the MRc2 CIRs. While I understand that the v2 public CIRs do not apply to your LEED v2009 project, it does provide some insight into what is acceptable to GBCI for compliance. Getting reusable materials back into service seems to be a significant portion of this credit, beyond simply keeping them out of landfills or incineration. Your concrete and gyp are two of those material types. Although there are CIRs that may appear to support the backfill type approach I thought you might want to be aware of at least 2 USGBC rulings below that clearly go the other way so you could plan accordingly:

6/19/2008 - Ruling
The applicant has requested acceptance of mine backfilling as an equivalent means of accomplishing construction waste management. Based on the description of the process, it does not appear that this practice will meet the intent of the credit. In addition to encouraging the diversion of debris from landfills, the credit intent includes an expectation that projects “redirect recyclable recovered resources back to the manufacturing process.” While it is recognized that using clean waste material from construction rather than other potential materials to back fill deep mines may be environmentally preferable, this practice is not aligned with the intent of the credit. The waste is in essence going to a “landfill” and the specific materials noted (gypsum and glass) are known to be potential feed stocks for manufacturing processes. By using them as fill material, the proposed practice is burying potentially valuable raw materials. Underground waste disposal is not a recognized means of recycling for this credit.

7/2/2008 - Ruling
The project team is requesting that on-site burial of concrete from the wash out area be considered landfill diversion.

No, the intent of this credit is to, “Divert construction, demolition and land-clearing debris from disposal in landfills and incinerators. Redirect recyclable recovered resources back to the manufacturing process. Redirect reusable materials to appropriate sites.” The described actions are not much different than creating micro landfills. While there are environmental benefits to on-site disposal in the avoided vehicle miles, the described actions do not reuse or recycle this material.

To answer your original question, no, these do not sound like comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility. materials. If your containers of materials are already separated on-site by type and volume or weight are calculated individually for your project, then it is considered diverted and not comingled for entries on the LEED credit form. Your term “mixed concrete” and “mixed gyps” are a little confusing. Since it does not sound like these materials are being sent to the recycling facility anyway, then they would not qualify as comingled since you will not be able to get a letter of certification for the annual recycling rate of the facility, nor are the materials being separated off-site from what I can tell.

Thanks for your answer.

I was not accurate in the definition of the process, so I try again:
The general contractor separates on-site the gypsum material but it does not separate on-site the other materials (that are considered as commingled).
All these materials (gypsum+commingled) go out from our jobsite and they are tracked by waste haul receipts defining them with an European Code (that identifies the materials) and the Letter R for Destination of the Waste (R is for waste that will be recovered, D is for Landfill).
All these materials are used as backfill in another building site and the general contractor signed a letter in which it describe the process.

I know that for the intent of the credit we respect the first sentence (Divert construction, demolition and land-clearing debris from disposal in landfills and incinerators) but not exactly the rest (Redirect recyclable recovered resources back to the manufacturing process) even if we can consider that we Redirect reusable materials to appropriate sites.

What is your point of view?
Thank you!

You're allowed to divert materials from the landfill in this way, i.e. to use them as fill.

Kathy: While I have not had this experience on any of our projects nor have I heard of a similar occurrence, I can simply offer an opinion as a practitioner.
I suspect that since you have no way of knowing how much of the stolen HVAC equipment will be reused or salvaged and what portion of the equipment might be dumped, my guess is that it would not be counted towards diverted weight since it cannot be substantiated.
You know more about whether this particular equipment was still serviceable making that the most likely motivation for the theft, or whether it was more valuable for its’ parts or as scrap metal. If you think it might still be in use and it is a very small community, you could have some fun with it and offer a small token reward for whoever comes forward to take “credit” for helping your team keep it out of the landfill! If they would give you a statement or just a photo of it in use, you are back on course. Or if they sold it for scrap, that is okay too! You just want substantiation it got diverted in some way. See if you can make the dumspter divers "partners in green"!

Though I can't help you with your current situation, I have experienced this as well on more than one project. We actually now request that our dumpsters have locking lids to prohibit this from happening in the future.

Rachael:
First, I would make certain that you are interpreting the TCEQ regulation properly. My next question would be “what would it take to meet the new air quality regulations?” If the current recycling equipment and/or processes do not meet the required emissions levels or rates then perhaps that is the first source needing industry modification to reach compliance.

Work with TCEQ towards a solution. TCEQ is the agency who estimated in 2008 that Texas had only 31.6 years remaining until capacity was reached at its landfills. There are many stakeholders here that have a common interest in keeping the gyp board out of the landfills.

Check with specific municipalities as to how they are handling the regulations. Dallas for instance has a construction waste recycling initiative called SEE Less Trash that would be greatly impacted, in addition to their LEED initiative. Taking an advocacy role may not get you immediate results, but will help solve this in the long term. Check with Austin for their take on this as they have a long history of green construction policy.

Approach the Gypsum Association for advocacy towards an industry-wide solution. They may not be aware that this has arisen as an obstacle for their members.

Contact the big manufacturers of gypsum wall board specifically to see what they can offer in the way of solutions. Perhaps they would initiate a take-back program in the interim. Or get involved to help upgrade recycling equipment to meet the regulations.

Consider submitting a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide to GBCI on your hazardous waste question though I am doubtful that it would qualify in this category.

Finding an alternate to gypsum wallboard is possible, but probably not as economical.

LEED-NC and CS projects probably won’t find meeting MRc2 quite as great a hardship as CI projects, simply due to the higher proportion of weight drywall contributes to the waste stream for a fit-out. Collaborate with your contractor along with the drywall subcontractor to plan for minimizing waste. Create an incentive and make it a challenge to see just how little gyp waste they can generate.

Just thinking outside of the box here. I have heard of projects filling interior stud cavities with drywall scraps. Though unconventional, it would divert the material from landfill and actually bolster the acoustic performance of the assemblies (by adding mass). You would need to confirm that this does not compromise required fire rating of partitions and that the building official is on-board with the approach. Your contractor might have some feedback about the potential labor implications.

Rachel- are you interpreting this ruling as a measure that applies to all sheetrock or just those containing fiber? Can you cite the ruling, please? I have not witnessed any changes to sheetrock recycling, and none of our receivers or suppliers have commented. We have reached out to TCEQ and several waste management companies in our area, but feedback may take a day or so. Would love some more information from you as soon as you can. This took many of us by surprise!

Hi Rachel - this took us by surprise as well. We spoke to Shannon Herriott with TCEQ, and she stated that there is not actually a ban on recycling drywall in Texas.

She thinks what may have caused the confusion is that sheetrock (drywall) is specifically excluded from the definition of “clean wood material” for wood composting. So, companies who have a permit to compost only clean wood material cannot accept drywall. (Ref. TAC, Title 30, Ch. 332, part X).

However, there are a few companies who are authorized to compost drywall. They have to get a special permit to do this. Shannon referred me to an interesting online database called Recycle Texas Online: http://www5.tceq.state.tx.us/rtol/. You can search this database to find companies in Texas who can provide recycling for specific products.

In regards to David Intner's post about stuffing wall cavities with scrap gypsum board. I think that that would be a bad idea at best. You have not actually diverted that waste as it is still on site and will have to be dealt with eventually. The practice of stuffing waste of any kind into a wall cavity is not an acceptable practice in my opinion. Debris in a wall cavity creates a host for insects, adds to the building load, harbors moisture, and is a problem in normal building maintenance. Have you ever tried to run new wiring through a cavity packed with waste? Or tried to install molly anchors where secondary pieces of drywall are leaning against the top sheet? Most reputable installers that I work with clean out the cavity before closing it, the best use a shop vac.

In my opinion, the date the project is registered with the GBCI determines when your project formally declares its’ intent to pursue LEED certification and all requirements are in play. Having separate packages and/or contracts for the demo and construction work is insignificant.

If the project is registered after the demo work, it seems to me it then becomes more of an issue of how committed the team is to sustainability. This also represents an opportunity to be an environmental steward and leader in the community, provide deconstruction experience for a team, and create favorable public relations and branding opportunities for the project owner. You might also check to see if there are tax incentives in your area for deconstruction to support your business case. Run some numbers for the financial pros and cons of each scenario. Depending on the type and age of your building, there may be some real interest in the community for that salvage.

Yes, it is required. If you read through the MPRs there is a line in there about having to include all work done prior to construction that was necessary to be complete for the LEED building to be constructed (or some such). If the old building came down to make way for your LEED project, then you need to track it. We've had several projects where road work or demo work has to be included and we've had to coordinate with different contractors and architects.

We took the total amount of the waste stream for the entire retail re-development project and attributed a % to our LEED supermarket project based upon our building and site areas relative to the whole development which consisted of 800,000 sf of retail on a 62-acre site.

I am not sure if that translates to your situation. Depending on the project, core and shell materials can be greater in quantity and/or weight than those of a CI project, but that varies with scope of course.

Kathy, have you received credit for your projects yet?
I also have a CS and a CI project within the same building with overlapping time schedules. I might even have two CI projects in the building before we’re done. How can I separate the waste? There is no way to have different dumpsters for different projects (and make construction workers separate CS and CI waste!). Can I make a reasonable assumption and argument on how much waste that comes from each project? Our company’s goal is to keep 95 % of waste out of landfill, both CS and CI. Anyone else have experience?

The construction waste management plan and documentation would begin with the scope the tenant has control over, which in this case is as you have stated, upon delivery of the the shell space.

I don't have experience with this situation but it seems fundamentally the same as if your hauler were doing the waste diversion and reporting back to you their overall diversion rate for that time period. And that's allowed, so I would say you're good to go.

Anyone have experience with a situation like this?

We had a supermarket LEED project that was part of a 62-acre retail shopping center redevelopment. All of the demo waste was combined due to it being one demo contractor. We simply estimated the amount that could be attributed to our store site and used those figures.

The new construction waste phase was a new contractor with separated dumpsters just for the supermarket, so that was business as usual. This project was in the Retail Pilot and earned Gold. I would check the Retail Rating System for any new provisions related to applying this credit to Retail for ideas or guidance, even if you are CI.

i have recently found two CIRs for the older version of CI on this topic:
"CIR ruling dated 07/08/08 states that “individual buildings and spaces seeking certification need to be accountable for their individual construction waste management diversion rates and should be tracked and documented as such”. Based on this CIR ruling, the project team should note that the material resulting from the renovation of the non-LEED project cannot be commingled with the material from the LEED NC addition project. This inclusion of material would lead to inaccurate calculations for MRc2.1. If the project team can devise and document a method that accurately assigns the waste from the two separate projects before combining, then this would be an acceptable compliance path."

This would imply that the credit is not achievable where waste cannot be reliably and separately accounted for. Again, grateful to hear of others experience in Review!